PRIVACY POLICY
(customers)

Pursuant to and in accordance with Art. 13, of EU Regulation no. 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EECX ART. 13-14 REGULATION EU 679/2016 (GDPR)

R5 Labs Europe S.r.l., (hereinafter also “Data Controller”) with registered office in Via dell’Olimpo 30/a, ZIP code – 90141, Palermo (Italy), with VAT No.: 06860340824, as the data controller (hereinafter “Data Controller”), informs you, pursuant to Art. 13 EU Regulation 679/2016 (hereinafter “GDPR”), that the data you provide are processed in the manner and for the purposes described below:

1. IDENTIFYING EXTRACTS OF THE PERSONAL DATA PROTECTION RESPONSIBLE (DPO)
Pursuant to the Regulations, your personal data will be processed by R5 Labs Europe S.r.l., with registered office in via Dell’Olimpo 30/A, ZIP code – 90141, Palermo (Italy), contactable at info@edgemony.com The Personal Data Protection Officer (DPO) is the company Keplera S.r.l. traceable at info@edgemony.com

2. SUBJECT OF THE PROCESSING AND TYPES OF DATA
The Data Controller processes the personal data you provide, such as your name, surname, company name, e-mail, telephone number, IP address, browsing choices (hereinafter “Data”) collected when browsing the website at www.edgemony.com as well as when communicating via chat for assistance and filling out the online contact request or collaboration forms, through the Partner Program, or application and platform registration forms, published on the aforementioned website. Such Data will be used to process your requests.

The Data being processed belong to the following categories:

• common data, identifiable by way of example in first and last name, place and date of birth, residence, telephone number, e-mail, picture of the person, billing information;
• other common data, such as, those related to electronic communications (via the Internet or telephone) related to communications put in place through e-mail accounts, support chats, forms and telephone contacts, as well as data related to social profiles (e.g., LinkedIn, Facebook; Google);
• where there is, pending the execution of the activities you requested, the need to process additional data not falling into the above category will be promptly informed by R5 Labs Europe S.r.l.
  
  

3. COOKIES AND SITE TRACKING
In compliance with EU Dir. 2009/136/EC of 25/11/2009, the Owner informs you that this site uses cookies or similar tools to allow us to improve our service and offer you some useful features. This may include cookies from business partners that are stored by your computer or device when you visit our site (Cookie Policy). Please visit the websites of our business partners for information about their cookie and privacy policies.

Cookies are small text files that are transferred to your computer or device via your web browser to enable us to recognize your browser and help us track visitors to our site, thus enabling us to better understand the products and services that will be most suitable for users. A cookie contains contact information and useful information to allow us to identify your computer or device when you visit our site with the purpose of helping you during booking and search activities and get a better user experience while browsing. Most web browsers automatically accept cookies, but if you wish, you can change these browser settings by accepting, rejecting, and deleting cookies. If you choose to change these settings, certain functions and features may not operate as expected. The cookies used do not detect information on your computer or device.

For more information about cookies and how to prevent your browser from accepting them, visit the following website: http://www.allaboutcookies.org.

4. LEGAL BASIS AND PURPOSE OF PROCESSING
Your personal data are processed, for the sole purposes of managing and processing the requests made, to the Pursuant to Art. 6.1.b of the GDPR (processing necessary for the performance of pre-contractual measures required by the person concerned). In addition, to only following your explicit consent (Art. 6.1.a of the GDPR), they will be processed for purposes (i) direct marketing, (ii) User profiling, (iii) communication to third party partners for own purposes.

5. PROCESSING METHODS AND STORAGE

The processing will be carried out using computer systems (cloud, internet, computer and mobile devices) and, residually, in paper form, with the appropriate methods to ensure confidentiality and security. The data will be kept in the Owner’s databases only for the time strictly necessary to process your request, in accordance with the law and as specified above, with the exception of the cases in which the regulations in force do not require the retention of data for longer periods. In the case of processing for the purposes referred to in section 4. (i) and (ii) data will be retained for a maximum of 24 months.

6. NATURE OF PROVISION OF DATA AND CONSEQUENCES OF REFUSAL
The provision of your data is optional. However, failure to fill in the fields marked, and considered as necessary, may affect the total or partial processing of the request made, as well as the successful completion of registration for the service and its provision.

7. ACCESS TO DATA
Your Data will be processed for the purposes and in the manner described above by personnel and/or collaborators of the Owner specifically authorized of the processing and based on the instructions received, as well as by third parties (e.g., suppliers, professionals, banks, affiliates, business partners) where they perform outsourced activities on behalf of the Data Controller, in their capacity as external data processors.

8. COMMUNICATION OF DATA
The Data Controller may communicate your data to public bodies in order to comply with the obligations provided for by laws, regulations or EU and national legislation, or imposed by the Authorities, which will process them in their capacity as autonomous data controllers. They may be communicated to Third Parties (e.g., suppliers, professionals, partners) where they carry out activities that are instrumental or ancillary to the services requested and the above purposes, on behalf of the Controller in their capacity as external data processors.
An updated list of these individuals can be obtained from the Data Controller at the addresses above indicated. The data, subject to your consent under 4 (iii) above, will be disclosed to third parties, such as client companies or principals, for its own purposes as an autonomous owner.

Typically, the chosen service providers operate through data centers located on the territory of the European Union.

Should your data be transferred outside the European Economic Area (EEA), for purposes of technical or statistical management of the collected data, this will be done exclusively in the full compliance with EU Regulation 2016/679, to third countries, for which the European Commission has Recognized specific guarantees of adequacy or adequate data protection safeguards have been provided personal, by means of signing the Standard Contractual Clauses approved by the European Commission under Decision 2010/87/EU for the transfer of personal data between EU countries. To non-EU COUNTRIES, indicating the additional security measures taken, for the protection of confidentiality Of the person concerned.

Data may, therefore, be disclosed to:

• all persons to whom the right of access to such data isrecognized under regulatory provisions;
• To our contributors and employees;
• Individuals appointed as External Data Processors by the Owner for the processing of personal data;
• to all those natural and/or legal, public and/or private persons when the communication is necessary or functional for the establishment and management of the relationship, in the manner and for the purposes outlined above, in particular to:

– accountant,
– legal advisors;
– labor consultants;
– business partners;
– providers;
– banking institutions;
– public institutions;
– In charge of administrative activities.

9. RIGHTS OF THE DATA SUBJECT
At any time, you may exercise your rights vis-à-vis the data controller, pursuant to Articles 15-22 of EU Regulation 2016/679, and in particular the rights of access, rectification, integration and, in permitted cases the portability of the data provided, as well as to obtain the deletion, restriction or opposition to the processing of the Data for legitimate reasons and to object to automated decision-making, including profiling, as well as the right to complain to the Data Protection Authority.

ART. 15 – RIGHT OF ACCESS
The data subject has the right to obtain from the data controller confirmation as to whether or not personal data concerning him or her are being processed, and if so, to obtain access to the personal data and information concerning the processing.

ART. 16 – RIGHT OF RECTIFICATION
The data subject has the right to obtain from the data controller the rectification of inaccurate personal data concerning him/her without undue delay. Taking into account the purposes̀of the processing, the data subject has the right to obtain the integration of incomplete personal data, including by providing a supplementary statement.

ART. 17 – RIGHT TO CANCELLATION (RIGHT TO OBLIGATION)
The data subject has the right to obtain from the data controller the erasure of personal data concerning him or her without undue delay, and the data controller has the obligation to erase the personal data without undue delay.

ART. 18 – RIGHTTO LIMIT THE PROCESSING
The data subject has the right to obtain from the data controller the limitation of processing when one of the following cases occurs:
(a) the data subject disputes the accuracy of the personal data, for the period necessary for the owner of the
processing to verify the accuracy of such personal data;
(b) the processing isillimited and the data subject objects to the deletion of personal data and instead requests
That its use be restricted;
(c) although the data controller no longer needs it for the purpose of processing, the personal data
are necessary for the data subject to establish, exercise or defend a right in the
judicial;
(d) the data subject has objected to the processing in accordance with Article 21(1), pending verification
As to whether the legitimate motives of the data controller prevail over those
Of the person concerned.

ART. 20 – RIGHT TO PORTABILITY OF DATA
The data subject has the right to receive in a structured, commonly used and machine-readable format personal data concerning him or her that have been provided to a data controller and has the right to transmit such data to another data controller without hindrance from the data controller to whom he or she has provided them.
When exercising his or her rights regarding data portability under paragraph 1, the data subject has the right to obtain direct transmission of personal data from one data controller to another, if technically feasible.

ARTICLE 21 – RIGHT OF OPPOSITION
The data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her in accordance with Article 6(1), letters (e) or (f), including profiling on the basis of these provisions.

ART. 22 – RIGHT NOT TO BE SUBJECTED TO AUTOMATED DECISION PROCESSING, INCLUDINGPROFILING
A data subject has the right not to be subjected to a decision based solely on automated processing, including profiling, that produces legal effects concerning him or her or that significantly affects him or her in a similar way.
The above rights can be exercised by sending an e-mail to the Holder at info@edgemony.com.

In order to ensure the protection of the data subject’s personal information, we may need to request additional specific information that confirms the identity of the requesting data subject and thus guarantee his or her right to access the information (or to exercise any of the other rights) only to persons entitled to receive such communications. This is another suitable security measure for the protection of personal data.

Requesting access to your personal information (or to exercise any of the above rights) is free of charge. However, if the request is clearly unfounded or excessive we may charge a reasonable fee taking into account the administrative costs incurred in providing the information or refuse to comply with the request under such circumstances.

10. UPDATING THE DISCLOSURE
R5 Labs Europe S.r.l. will keep this policy constantly updated and will be responsible for posting the updated policy on the relevant websites.

Please note that, pursuant to Art. 7 of the EU Regulation Regulation 2016/679,, is recognized the right to withdraw consent to the processing of personal data in writing.

Last update date: March 2023