The data processing carried out by Objectway is based on the principles of correctness, lawfulness and transparency, and is determined by the minimum purposes and the assurance of security and confidentiality of the data in compliance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
PURPOSE AND LEGAL BASIS FOR PROCESSING
Data are processed both manually and in electronic form, exclusively for the period of time that is strictly necessary for the accomplishment of the purposes for which data are gathered and in relation to Objectway’s activities.
Data derived from requests for information
In case of requests for information received via web or other channels, Objectway processes the provided data with the sole purpose of responding to the request.
Data are processed on the legal basis of fulfilling the data subject’s request.
Data from commercial contacts
In the case of commercial contacts and requests for commercial information, Objectway processes data with the sole purpose of being able to contact the individual who has requested the information.
Data are processed on the legal basis of fulfilling the data subject’s request.
For commercial communications, consent is requested to the data subjects and can be withdrawn any time.
Newsletter mailing list and event promotion
In case of requests to receive the newsletter, Objectway processes the provided data with the sole purpose of sending the newsletter to the indicated address.
Data are processed on the legal basis of fulfilling the data subject’s request. The data subject can always delete its subscription, as reminded in every newsletter.
Suppliers and Partners
Data from our suppliers and partners may be personal, including telephone numbers, email addresses, and other company information. These data are, in any case, instrumental to the provision of goods and/or services.
Suppliers’ and partners’ data are gathered directly from themselves or from other promotion channels. In the case that personal data are not provided or there is a request to block the processing, the beginning or the continuation of professional relations with Objectway may be impeded.
Data from our clients are of a personal, including telephone numbers, email addresses, and other company information which is, however, instrumental to the provision of goods and services.
Clients’ data are collected directly from them. In case that personal data are not provided or there is a request to block the processing, the beginning or the continuation of professional relations with Objectway may be impeded. Furthermore, please note that Objectway can use the clients’ data without their prior consent to send them promotions of products or services similar to those used by customers. Data subjects can always oppose the purpose as is outlined below.
When receiving a curriculum vitae and during the following interviews, Objectway processes the provided data with the sole purpose of evaluating and selecting candidates for future collaborations.
Data are processed on the legal basis of fulfilling the data subject’s request.
Data are processed under the consent given by the data subject when signing up, in order to fulfill their requests and for the company’s legitimate interest (tracking its interactions with users, assessing its public image, marketing).
Data are maintained and stored by the social network providers, according to their rules.
Technical and analytical cookies
Websites www.objectway.com and www.eximiusaas.com install cookies onto users’ terminals to improve the browsing experience (technical cookies), to collect anonymous data regarding the use of the site, and to analyze its service performance (analytics). Some cookies are for profiling and they are described below.
Technical and analytical cookies are supplied by third parties to whom only anonymous data are disclosed. These third parties are indicated below along with the links to their policies:
- Google Analytics (https://policies.google.com/privacy)
- StatCounter (https://statcounter.com/about/legal/)
- Hubspot (https://legal.hubspot.com/product-privacy-policy)
- Microsoft Edge (https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy)
- Google Chrome (https://support.google.com/chrome/answer/95647)
- Mozilla Firefox (https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer)
- Apple Safari (https://support.apple.com/et-ee/guide/safari/sfri11471/mac)
It is also possible to manage preferences regarding cookies through services made available to third parties.
Objectway’s goal is to minimize the use of personal data and in this perspective we retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for.
In some cases, personal data can be communicated to third parties such as but not limited to: payroll companies, audit companies, consultancies companies (legal, administration, fiscal consultancy), banks, mailing services (for newsletters), IT support services for contacts management.
Objectway and its third parties has contractually agreed that data will be processed for the sole purpose of providing the service and that appropriate security and control measures are adopted. Third Parties list is available at Objectway headquarters.
For IT cloud providers, Objectway will preferably use providers based on the European Economic Area. If that would not be possible, Objectway will use providers that are compliant with the current applicable rules and regulations on data transfer outside EU.
All the third parties involved ensure their collaboration with the aim to guarantee the fulfillment of data subject’s rights, the efficacy of incident management and the right to audit.
RIGHTS OF DATA SUBJECTS
Under the Data Protection legislation, data subjects have the following rights with regards to their personal information:
- the right to be informed about the collection and the use of their personal data
- the right to access personal data and supplementary information
- the right to have inaccurate personal data rectified, or completed if it is incomplete
- the right to erasure (to be forgotten) in certain circumstances
- the right to restrict processing in certain circumstances
- the right to data portability, which allows the data subject to obtain and reuse their personal data for their own purposes across different services
- the right to object to processing in certain circumstances
- the right to complain to the Public Authority
Data subjects can exercise their rights referring to the following contacts
CONTROLLER AND PROCESSORS
The contact details of the Data Controller and the Data Protection Officer (DPO) are available below.
The personal data controller is:
Objectway S.p.A., Via G. Da Procida 24, 20149 Milan, ITALY
Tel: +39 02 898001 – Fax: +39 02 89800285
Tel: +39 02 898001 – Fax: +39 02 89800285
The complete list of data processors is available at the controller’s legal headquarters.
Data subjects have the right to raise complaints against Objectway Group through the aforementioned emails or through a claim to the Public Authority.
TERMS FOR THE USE OF THE COMMUNITY SERVICES AND THE BLOG
Data collected from the User community are disclosed by data subjects themselves on the platform.
Data are processed by Objectway with the purpose of product and service analysis. No user profiling is performed.
In case that personal data are not provided or there is a request to block the processing, the data subject’s complete or partial use of the platform is impeded.
Data are processed on the legal basis of fulfilling the data subject’s request (i.e. its participation to the community).
Data will be maintained as long as the data subject will not request their deletion.
Potential regulations and/or special conditions can be published on the Site by Objectway as necessary. These may refer to specific Community Services and to the Blog (regulations and special conditions are hereinafter referred to as “Regulations”, both when considered individually and/or collectively). The Regulations are an integral and substantial part of the Conditions of Use. In the event of discrepancies between the provisions set by the Regulations and those by the Conditions of Use, the provisions from the Regulations shall prevail.
Users are advised to print or save a local copy of the Conditions of Use and of the Regulations for future reference.
The User must also insert his or her personal details in the relevant registration form, along with a username and a password.
The personal details entered by the User in the Site’s registration form must be true and complete.
The username and the password entered upon registration are personal and should not be disclosed under any circumstance. The User is responsible for keeping this information strictly private. The User must, therefore, respect the confidentiality of these data in order to prevent unauthorised third parties from using the Site, the Community Services and some Blog features.
The User is directly responsible for any use of the above-mentioned data by authorized or unauthorized third parties which occurs as a result of the violation of the normal diligence required for their safe-keeping. Notwithstanding that which is stated above, in the event of any unauthorised third-party use of the username and/or password, the User to which they pertain must inform Objectway immediately, by sending an email to email@example.com. Users can request the cancellation of their registration at any time by sending an email to firstname.lastname@example.org
Subject to the so-called “point & click” acceptance of the Conditions of Use and any Regulations which may be applicable (hereinafter, referred to, jointly, as the “Conditions”), Objectway offers registered Users of the Site, the possibility to use some Blog features and Community Services available on the Site itself such as comment and idea-sharing spaces, upload initiatives, the “Ambassador Programme” and the “Support” (hereinafter, individually and collectively referred to as “Community Services”). These features and services allow Users, among other things, to freely insert, save, publish, spread and communicate, on the relevant virtual spaces that Objectway provides Users to enable interaction on the Site, their contributions in the form of text, images, photos, videos, diagrams, audio recordings, data and any other general content of which the User is the author or the holder of the rights, or the entity who has the rights of their full disposal (hereinafter “User Content”).
The Community Services and the Blog are at the User’s disposal solely for direct, personal, private/individual and professional use. Furthermore, the purpose of such use must be non-profit and/or not directly or indirectly commercial. The use must also fully comply with the Conditions.
COPYRIGHT LICENCE FOR PUBLICATION OF USER CONTENT ON THE SITE
By accepting the Conditions, the User authorises Objectway to publish User Content as and when he or she uploads it to the Site, Blog and/or the relevant section dedicated to the chosen Community Services.
In addition, the User gives Objectway a non-exclusive, unlimited and transferable licence to reproduce, publish, process, carry out, represent, transmit, transfer to other formats (so-called “format shifting”), communicate and make available to the public, process and/or edit, re-edit, translate, distribute, rent and/or lend and, in general, use User Content in any way, way or form with reference to the profile of the personality (name and image), examples of which may include, although are not limited to, his or her related copyrights and intellectual property. The User acknowledges and agrees that when exercising the licensing rights, Objectway is entitled to, but in no way obligated to, mention the name of the User who owns the User Content. The latter will simply have the right to claim the authorship of his or her work within the limits established by current copyright legislation. This possibility shall not force Objectway or its assignees to mention the User concerned nor does it necessitate any responsibility, expenses or duties from Objectway. By accepting these conditions, the User acknowledges and agrees that no other compensation will be given for the licence foreseen by this paragraph.
INTELLECTUAL PROPERTY RIGHTS
Users acknowledge Objectway’s current and future ownership of all intellectual property rights related to the contributions published on the Site such as text, images, photos, videos, diagrams, audio recordings, data and content of which Objectway is the author or the holder of the rights, or the entity who has the rights of their full disposal (hereinafter “Objectway Content”). The unauthorised use, copying, reproduction, editing, republication, updating, downloading, mailing, transmission, distribution and/or duplication or any other unlawful use of the aforementioned Objectway Content is, therefore, forbidden.
Equally, Users acknowledge Objectway’s ownership of all intellectual property rights related to products and/or services which could be potentially developed by the latter based on User Content published on the Site.
The User states and guarantees Objectway and its assignees that the User Content that he or she publishes on the Site is original and that he or she is the holder of the related copyright, personality and any other related rights. He or she also guarantees that the content is not obscene, violent, slanderous, blasphemous, horrifying, disturbing for minors and that it does not in any way infringe the rights of third parties (including, but not limited to, moral rights, image rights, honour, decorum, reputation, confidentiality, copyrights, rights to privacy and data protection, publication rights and others) or legal provisions. The User also states that he or she has obtained all the necessary permission and releases from all eligible subjects and/or the responsibility to provide those permits as far as the User Content and its use by Objectway. He or she declares that neither the User Content nor its use constitute the infringement of third parties’ personal or proprietary rights and/or legal provisions, taking into consideration also possible authorisations or permits granted by public authorities, self-regulation entities or similar.
If the User is not the sole owner of the User Content copyrights, he or she must acquire all the documents certifying that eligible parties have provided the User with all the necessary authorizations and provide Objectway with these documents upon its request. In particular, with regards to the publication of photos or videos of minors, the User declares that he or she is the owner or that he or she has already acquired the necessary written authorization (which the aforementioned User is obligated to provide Objectway with upon request) from the parent or guardian.
If Objectway or its assignees become the object of legal or disruptive actions, reprimands or claims by third parties regarding the management or use of the Community Services and/or Blog by a User and/or regarding User Content, the same User explicitly agrees to indemnify and hold Objectway and its assignees harmless from and against any liability, loss, damages, cost, legal or professional cost and any other costs which may arise or be suffered as a consequence of the use of the web space made available, without prejudice to the compensation for damages.
SUSPENSION AND ELIMINATION OF USER CONTENT AND/OR USER-GENERATED CONTENT AND/OR USER REGISTRATION
Objectway does not check nor monitor User Content published on the Site, nor are they obligated to approve the aforementioned content prior to publication, and, therefore, cannot be held liable for User Content, nor for potential mistakes and/or omissions in it or for potential direct and/or indirect damages caused by its publication on the Site by Users and/or third parties. Having said that, if Objectway becomes aware of the presence of User Content which breaches, even if the breach is simply suspected, these Conditions of Use and/or if User Content on the Site is believed to be illegal or inappropriate, at the sole discretion of Objectway, the relevant User Content, Community Services, Blog features, and/or the User registration shall be suspended and/or deleted, completely or partially, or the User may even be banned indefinitely from using Community Services and/or the Blog.
In the event that Objectway is notified by third parties that one or more items of the User Content allegedly infringe individual rights (including, but not limited to, copyrights, trademark rights and/or personality rights), Objectway reserves the right to immediately suspend and/or delete the User Content and/or Community Services and/or Blog features and/or User registration in question. Alternatively, Objectway may, at their own sole discretion, send the User concerned an email informing them of the third-party notification and requesting that he or she removes the User Content of their accord within 3 (three) days from the sending of the notification or that he or she provides appropriate evidence of the legitimacy of his or her use of the aforementioned User Content and of the related rights. If the User fails to do so within that period, Objectway shall immediately suspend and/or delete the User Content and/or Community Services and/or Blog and/or User registration, and possibly ban the User indefinitely from using Community Services and/or the Blog.
CODE OF CONDUCT FOR THE USE OF COMMUNITY SERVICES
When using Community Services and/or the Blog, the User agrees to respect general principles of good behaviour, commonly known as “Netiquette Rules” and to respect the following general rules of conduct:
a) Avoid posting identical messages in more than one comment (so-called “cross posting”);
b) Do not fuel “opinion wars” or arguments: if there are personal debates, it is better for those concerned to resolve them privately;
c) Give comments titles which are pertinent to the topic in question;
d) When replying to the message of another user, simply quote the part which is strictly necessary for the reply to be comprehensible.
In addition, the User is expressly forbidden to publish: (The publication of material of this kind can cause the automatic termination of the Conditions by Objectway as well as the consequent removal of the User Content published on the Site and possibly also of the User registration)
a) Emails, without the explicit consent of the sender and the recipient;
b) Pornographic, obscene or sexually explicit content;
c) Content that involves evident and/or gratuitous violence (physical or moral);
d) Other content that involves evident and/or gratuitous abhorrent or immoral scenes or content that may offend in any way the common sensibility;
e) Content that is not appropriate for minors under 18 years of age;
f) Content that may constitute an infringement of copyright or other intellectual property rights (for example, famous brands – that is to say trademarks and/or high-reputation brands – or symbols of other types), or a violation of personality rights;
g) Content that may be considered blasphemous, slanderous or insulting by anyone, including, but not exclusively, expressions of fanaticism, racism, hatred, irreverence or threat;
h) Content that includes information which is known to be false or deceiving, or that may jeopardize in any way other Users’ behaviour;
i) Content that refers to initiatives involving gambling, competitions or games in which participation is subject to payment;
j) Content that may be considered advertising or sponsorship of any type, that is to say content which refers to deals and to the sale of any product or service or that is connected in any way to commercial initiatives;
k) Content that violates or leads to the violation of any legal or regulatory provisions intended for the protection of private entities or an order which is lawfully issued by Public Authorities.
It is also expressly forbidden to: (Actions of this kind may cause the automatic termination of the Conditions by Objectway as well as the consequent removal of the User Content published on the Site and possibly also of the User registration.)
a) Disclose personal information including mobile telephone numbers, email addresses, home addresses, names and surnames, etc.;
b) Use software tools or other devices that interfere or risk interfering with one of the operating features of the Site, for example those which contain viruses or harmful components;
c) Send unnecessary emails or threats via email or other media to other Users;
d) Use the Objectway Content available on the Site for commercial purposes, in any way, shape or form, even partially, including User Content inserted by other Users;
e) Violate in any way third parties’ personal data and/or personality rights;
f) Promote or provide information that could favour, make possible or contribute to the execution of any illegal activity or that could jeopardise third parties.
The User acknowledges and agrees that his or her use of Community Services and/or the Blog is entirely at his or her own risk and exclusive responsibility.
The User acknowledges and agrees that Community Services and the Blog are provided “as they are” and “as available” and that they could be temporarily inaccessible or contain flaws or be subject to delays.
Objectway shall not be held liable for any loss or damage caused by or in any way linked to the Users’ use of the Community Services and/or the Blog, including – but in no way limited to – damages for loss of business, loss of profits, business interruption, loss of commercial information and/or any other type of pecuniary loss, except in cases of Objectway’s willful misconduct or gross negligence.
In the event that a User detects any User Content which he or she deems to be illegal, inappropriate, offensive or vulgar, he or she is asked to promptly notify Objectway, sending an email to the following email address: email@example.com.
Such aforementioned notifications must be verifiable and must come from an identifiable subject. In the absence of those requirements, Objectway will not be able to remove the notified content from the Site.
The User is asked to use notifications responsibly. The User will be held responsible for notifications that she or he makes that turn out to be unfounded and/or illegitimate.
CHANGES TO THE CONDITIONS OF USE AND/OR COMMUNITY SERVICES
Objectway reserves the right to modify terms and conditions of the Conditions of Use at any time and to communicate such changes to Users through a general notice on the Site or through a link to that notice. After the changes have come into force, the use of Community Services and/or the Blog entails the User’s complete acceptance of the changes. Any User that disagrees with the new terms and conditions of the Conditions of Use is asked not to use the Community Services and/or the Blog or to cancel his or her User registration.
Objectway also reserves the right to send an email to Users to communicate possible technical variations, updates or news concerning the Site’s Community Services and/or the Blog.
Unless a previous agreement states otherwise, any message to Objectway must be sent to the following email address: firstname.lastname@example.org
The invalidity or inefficacy of any provision of the Conditions of Use shall never imply the invalidity or inefficacy of other provisions.
These Conditions of Use are regulated by Italian law.
The content, which is disclosed and/or published on the Community Services (as defined in Article 2 of Terms and Conditions for the Use of the Community Services and the Blog) and on the Blog available on the site http://in.objectway.com, and of which Objectway Financial Software S.p.A (hereinafter, Objectway) is the author, or the holder of the rights, or the entity which has the rights at their full disposal, (hereinafter, Objectway Content), cannot be anyway used in breach of the regulations concerning copyright since it belongs to the author. It is, therefore, forbidden to copy, reproduce, edit, update, mail, transmit or duplicate such Objectway Content in any way, shape or form. In addition, unless explicitly authorized by the author, the publication and the redistribution of the abovementioned Content is forbidden.
The blog is not updated cyclically, the frequency of the posts is not established in advance and, therefore, it cannot be considered an editorial product or a newspaper pursuant to Law nr. 62 of 7th March 2001.