PERSONAL DATA POLICY

Notice on the Processing of Personal Data collected through this website

1. Introduction and regulatory references
This notice describes the processing of personal data collected through this website, including data acquired by means of cookies, tracking technologies and — where present — contact forms and any other features that may be active on the site.
This notice is addressed to anyone who accesses or uses this website, describing how the user’s personal data is collected, used and protected, as well as the rights granted by law.
These provisions do not concern other websites, pages or online services accessible through external links that may be present on the site, in respect of which you are invited to consult the relevant privacy notices.
This notice is provided in compliance with the principal national and international regulations on the protection of personal data, including:

• Regulation (EU) 2016/679 (GDPR) and Directive 2002/58/EC, known as the ePrivacy Directive
• Other regulations that may be applicable.

2. Who manages your data and how can you contact us?
Your personal data is processed by:
Reply Studio S.r.l.
Via Suvereto 247
privacy@replystudio.com
VAT ID: 13305521000

For any information concerning the processing of personal data or to exercise the rights granted by law, data subjects may contact the Data Controller.

3. On what legal bases do we process your data?
The processing of personal data collected through this site (including data collected by means of cookies, similar technologies, contact forms and any other features that may be active on the site) is based on one or more of the following legal bases:

1. Performance of pre-contractual or contractual measures: where processing is necessary to respond to user requests, provide requested services and, where the site so provides, manage orders, accounts or contractual relationships.
2. Compliance with legal obligations: where processing is necessary to comply with tax, accounting, administrative or security obligations or with requests from the authorities.

A further legal basis, the legitimate interest of the Data Controller, may be used for specific purposes (e.g. ensuring IT security, preventing fraud, protecting the Data Controller’s rights in legal proceedings).

Failure to accept or the withdrawal of consent may limit certain features or services of the site.

4. What data do we collect when you visit the site?
While browsing this site, the following data may be collected, including by means of cookies and similar technologies such as pixel tags, web beacons, local storage and equivalent technologies – namely:

• Navigation and technical data: information such as IP address, device identifiers, data relating to the operating system and browser, requested URLs, connection times, technical logs, technical preferences, and usage data collected through cookies and tracking technologies (pixel tags, web beacons, local storage and equivalent tools).

5. How do we process your data, how do we protect it and how long do we keep it?
The personal data collected through this site is processed mainly by electronic and digital means in accordance with the principles of lawfulness, fairness, data minimisation, integrity and confidentiality.

Appropriate technical and organisational measures are adopted to prevent unauthorised access, loss, alteration or unauthorised disclosure of data, including:

• Encryption of communications (https): communications between your browser and the site are protected by HTTPS encryption, a measure aimed at reducing the risk of interception or manipulation of the data transmitted during browsing;

Data is retained according to the following timeframes:

• Cookie preferences and consents: retained for 180 days, as set out in the Cookie Policy on this site.
• Navigation and technical data: retained for the time strictly necessary for security purposes and, as a rule, no longer than 12 months, after which it is deleted or anonymised, save for longer periods imposed by legal obligations or by the need to establish, exercise or defend a right in legal proceedings.
• Data connected to any contractual relationships established with the Data Controller: where they exist, it is retained for the duration of the relationship and, thereafter, for the time required by the applicable legal obligations (for example in accounting and tax matters).
• Data entered through forms or specific requests: retained for the time necessary to respond to the request and to fulfil the related purpose, and thereafter for any period required by legal obligations.

6. Who can receive your data?
The following may access the personal data collected through this site, within the limits of their respective responsibilities and purposes:

• Authorised internal persons designated by the Data Controller, duly instructed on privacy and security matters;
• Suppliers and third parties appointed as Data Processors (for example: technical providers and IT services, site maintenance, e-mail providers, consultants, where applicable);
• Third parties that provide services integrated into the site (e.g. fonts, maps, image display), which may process technical data as independent controllers in accordance with their own notices (in which case please also consult the individual notices of such third parties);
• Competent public authorities and supervisory bodies, within the limits imposed by law or in order to comply with requests from the judicial authority;

The updated list of external recipients can be made available on request by writing to the Data Controller’s contact details.

7. Where can your data be transferred?
The personal data collected through this site may be processed within the European Union / European Economic Area. In some cases, the use of third-party services may involve a transfer to third countries. Where transfers to the United States take place, these are made to providers that adhere to the EU-US adequacy framework (Data Privacy Framework) or, failing that, on the basis of Standard Contractual Clauses.

8. What are your rights regarding the data collected?
The user, under the applicable legislation, has the right to:

• Obtain confirmation as to whether or not personal data concerning them is being processed and, if so, obtain access to that data and the related information (right of access).
• Request the rectification, updating or erasure of data that is inaccurate or no longer necessary (right to rectification and erasure).
• Request the restriction of, or object to, the processing of data, including for promotional/profiling purposes, where provided for.
• Request the portability of data in a structured and interoperable format (where technically possible).
• Withdraw at any time any consent given, without affecting the lawfulness of processing based on consent carried out before the withdrawal (for example for the sending of commercial communications or newsletters, where active).
• Withdraw the consent given to the use of non-technical cookies and to the processing of data collected through tracking tools.
• Report any irregularities or abuses to the competent supervisory authorities.

To exercise these rights, it is sufficient to send a request to the Data Controller’s contact details. The Data Controller will respond without undue delay and, in any case, within one month of receiving the request, a period that may be extended by a further two months in the case of particular complexity or a high number of requests, in which case the data subject will be informed.

9. How is minors’ data processed?
The protection of minors is a fundamental priority.

This site is not directed at minors and does not intentionally collect their data through its forms. Where, in the context of a request or query, the user provides personal data relating to third parties — including any minors — they must ensure that they are authorised to do so; such data will be processed within the limits and for the purposes of the request, in compliance with the applicable legislation. For requests for rectification, restriction or erasure, you may write to the Data Controller’s contact details.

10. How can you make reports or complaints to the authorities?
If you believe that the processing of your personal data through this site does not comply with the applicable legislation, you may lodge a complaint free of charge with the competent supervisory Authorities, including:

• The Data Protection Authority or personal data protection authority of your country of citizenship or residence;

11. How do we inform you of changes to this notice?
This notice is subject to periodic revision to reflect regulatory changes or modifications to the services offered through the site. Any significant change will be communicated through this page.