Información de remisión

underline}

_{INFORMATION
BUSINESS REFERRAL}

_{Oh
pursuant to art. 13 Regulation (EU) 2016/679 (GDPR) on the subject
of the processing of personal data}

_{With
In this information we would like to explain to you what are the
information that we collect if you log in to the referral program that
We activate for business partners (so-called business referral) or to that
provided for private users.}

_{OWNER
OF THE TREATMENT}

_{La
Sportwig e-learning platform is managed, in quality
of Data Controller,
by SW Holding S.r.l., with
registered office in Via Sansovino 6 — 20045 Lainate (MI). In this
As a matter of fact, we decide which personal data to process, with which
means and purposes. For any request you can write to us,
filling out the appropriate form
present on the site.}

_{We have
also appointed a Data Protection Officer, Avv.
Andrea Baldrati, who will be able to answer any questions you may have
or clarifications regarding precisely the ways in which
we process your data. It can be contacted at the following email: privacy@sportwig.com .}

_{BASICS
LEGAL PURPOSES}

AND PURPOSES

_{Every
processing must be based on an appropriate legal basis,
taking into account the purposes for which personal data are
treated.}

_{La
The following table is intended to represent in a clear and concise manner
What are the purposes and legal bases of the treatments
carried out as Data Controller, to execute the program of
referrals.}

_{Purposes
processing activities}

_{Description
processing activities}

_{Base
legal processing activity}

_{Program
by Referral}

_{Ti
we will assign a Referral URL
that you can share with
I
your customers inviting them to visit
our service .}

_{Respect
to all users who will access Sportwig.com Through
That specific referral URL you will be recognized a
Compensation like
by agreements, while to the user who has subscribed to
our service will be offered an ad hoc discount.}

_{For
Private individuals the mechanism concerning the flow of data is the
Same, only the prize changes, here represented by a
credit that can be spent on the platform}

_{Execution
of the contract for
the activation of the course.}

_{Legitimate
Sportwig's interest in
the storage of the registration cookie.}

_{Legitimate interest
of the Owner for
the data processing carried out by SignRequest in accordance
to the EU eIDAS Reg for digital signature}

_{Obligation
Say law in
relationship to tax or accounting obligations}

_{SE
DO NOT RELEASE YOUR DATA}

_{For
follow up on our agreement that involves the activation of a
a tracking URL, we ask you for your email and other data, such as
your IBAN, necessary for the subsequent management of
compensation due.
We remind you that, however, you are in no way obliged to
provide us with such data, but in the absence of them, it will be
impossible for us to continue with the agreement}.

_{Ti
Let's inform us,
Furthermore, that we use the SignRequest provider for signing
digital of the Referral Agreement and that the same supplier,
to comply with Reg. EU eIDAS, processes some data and metadata in
course of document signing operations (e.g.: e-mail; Address
IP when signing; Time and date of signing; Hash code of the
signed document). For more information, please read THIS
LINK.}

_{PERIOD
O DATA RETENTION POLICY}

_{I
your data will be kept for the time necessary to pursue the
purposes that we have indicated to you previously. Nello
specific:}

_{The cookies installed
They have a deadline of 10 days in order to recognize the user
if you return to the Sportwig site to register without logging in
with the dedicated URL;}
_{Le
payment receipts and invoices we will keep them for 10 (ten)
years since their issue;}
_{We will conserve
for 10 years from the conclusion of our commercial agreement also
those data that we may need to protect ourselves in the case of your}
disputes or complaints;
_{The data collected by
SignRequest during digital signature operations follow
instead the supplier's policy.}

_{RECIPIENTS
AND OTHER SUBJECTS TO WHOM THE DATA ARE COMMUNICATED}

_{Exclusively
for the purposes indicated above, your data could be}

_{PEOPLE
AUTHORIZED TO PROCESS:
are our employees or internal figures who process your data in
reason for their respective duties.}

_{MANAGERS
OF THE TREATMENT :
They are third-party collaborators who deal
data on our behalf, by entering into a special agreement of
appointment as Manager, by means of which the operations are defined
delegated, as well as the security measures that they must
adopt in order to better protect the information they obtain
from us.}

_{In
In particular, they could process your data:}

_{AWS
(Amazon Web Services, Inc.), such as Web Site Hosting with data
center in EU;}
_{Sendinblue ,
which SaaS solution for relationship marketing, with}
location of the servers in the EU; you can learn more at this link;
_{Vimeo
LLC ,
a video hosting and sharing platform that also declares
to adhere to the new standard contractual clauses}
;
_{OVHcloud ,
which email provider with a data center in the EU;}
_{Legalmail
by Infocert,
our Italian PEC provider;}
_{Adam ,
the management system used for invoicing and accounting purposes
which guarantees the processing of data within the EU;}
_{SignRequest
for the digital signature of the agreement of
partnership between the parties, who declare that they adhere to the new
standard contractual clauses (see this
link);}
_{Professionals
external ,
Like our accountant for obligations of nature
fiscal;}

_{RECIPIENTS :
They are the ones who receive
Our
communications of personal data, but that, as a result of this
communication, they act as autonomous Data Controllers. Among these:}

_{Stripe,
which payment intermediation service}
;
_{Banks
o Credit institutions ;}
_{Authority
Judicial and/or Public Security Authority,
in cases expressly provided for by law or in the context of
legal proceedings also to ascertain or defend one of our
right.}

_{I
YOUR RIGHTS
Nella
in your capacity as an interested party in the processing, you have the right to obtain
from the Data Controller access to your personal data, in addition to
rectification or cancellation of the same; you also have the right to
limit or object to the processing that concerns you (arts. 15 et seq.
GDPR). In addition, you have the right to lodge a complaint with the Privacy Guarantor
(art. 77 GDPR), or to go to appropriate courts (art. 79
GDPR).}