Welcome to our brainpull.com (the Site).
For Brain Pull Soc. Coop. (Brainpull), your privacy and the security of your personal data are very important, so we collect and manage your personal data with the utmost care and take appropriate measures to keep them safe.
Below you will find information on the treatment by Brainpull sometimes the same as the company of your personal data in relation to your navigation of brainpull.com example roboze.com and the use of services offered. For detailed information on how Brainpull manages your personal data, please read this Privacy Statement.
Some services may be subject to different legal terms, in which case we will take care of all relevant information from time to time.
The data controller is Brain Pull Soc. Coop., via Torino, 44 Conversano - 70014 (BA), VAT Number 07359120727, Fiscal code (social security number) 07359120727 (Brainpull).
The institution Brain Pull Soc. Coop., via Torino, 44 Conversano - 70014 (BA), VAT Number 07359120727, has been designated as Data Processor.
For any clarification, question or requirement related to your privacy and processing of your personal data, you can contact the Data Processor at any time by sending an email to email@example.com inserting “privacy” as object.
Personal data collected
The categories of personal data that Brain Pull Soc. Coop. collects and deals with when browsing Brainpull, are the following:
- we collect the personal data you provide us when you complete one of the brainpull.com contact forms;
- we collect the personal data you provide us when you request a service offered on brainpull.com;
- we collect the personal data you provide us when you sign up for our newsletter service;
- we collect your CV when you send it to us to be considered for an application to a position. The collection will concern only the common data, therefore the candidate must not confer those so-called details, as qualified by the art. 9 of Regulation (EU) 2016/679 or sensitive, as qualified by Legislative Decree 196/2003 (for example the state of health). In the latter case the interested party is invited to express explicit written consent to the processing of data, reporting the following formula at the bottom of the curriculum vitae, or in the accompanying letter: "In accordance with Legislative Decree no. 196 of 2003, I agree that Brain Pull Soc. Coop. will treat my personal data, even sensitive ones, for the purposes and with the methods specified in the information sheet "or another equivalent formula;
- we collect information about your browsing on brainpull.com, such as the pages you visit and how you interact with the single page and save this information on our servers;
We inform you that Brainpull does not process personal data relating to age minors. If you access brainpull.com and use the services offered by Brainpull you declare that you have reached the age of majority.
Purpose of use of personal data
Brainpull collects and processes your personal data for the following purposes:
- upon your explicit consent, management of your requests to Brainpull, using the personal information you provide o fulfill your requests for information and requests for assistance;
- upon your explicit consent, provision of the services offered on brainpull.com. For this purpose Brainpull needs to collect, in relation to each service and its characteristics, the personal data necessary to perform the services you request;
- apply for a job position. If you send us your CV to be considered for a nomination to a position, upon your explicit consent, we will use the information contained in your CV exclusively for this purpose. Your CV will be kept for a maximum period of twelve months, after which it will be deleted: if you want, you can of course send us a new updated version;
- upon your explicit consent, we may use the personal data you have provided us for commercial communications on our products and services in order to update you on news, our offers, promotions and other communications regarding the company and the brands connected to it;
- upon your express consent, we may use your contacts as part of the conduct of statistical research, opinion polls and market research with the aim of improving our services, our products, our activities and the relationship with our users;
- we process personal data related to your browsing such as the pages you visit and how you interact with the single page, ie traffic, in extent strictly necessary and proportionate to ensure network and information security;
- upon your express consent, on personal data collected, we can use automated or non-automated profiling mechanisms, including: behavior analysis for promotional and advertising purposes; creating lists for promotional purposes, for example, for the use and activation of custom and public audiences deemed similar, and similar activities on Facebook, Google and other suitably selected third parties and offering a guarantee of compliance with the rules on the processing of personal data; creating lists for commercial communications; creating lists for sending newsletters; processing of profiles for the provision of targeted and personalized services for customer needs. Such profiling mechanisms do not base decisions that have legal effects and do not significantly affect the natural persons involved.
In relation to all the activities indicated above, we will process your personal data mainly through IT and electronic tools, in full compliance with current legislation on the subject.
Legal basis of treatment
We only process your personal data in the presence of one of the conditions set by current legislation, and specifically according to the following legal bases:
- for our legitimate interest.
Some of your personal data may be processed to a strictly necessary and proportionate extent, to ensure network and information security.
With regard to these data, that we are obliged to know, in order to fulfill the obligations established by law, EU regulations and national legislation, ie, provisions issued by authorities entitled by law and by the vigilance and control, if you do not supply them, it will be impossible to establish or continue the relationship, in the limits in which such data are necessary for the execution of the same.
- based on your consent.
We will carry out the following treatments only if you have given us your express consent:
- to meet your requests for information and assistance requests to Brainpull;
- for the performance of one of the services offered on Brainpull you requested
- if you send us your CV, to be considered for an application to a job position in Brainpull;
- conducting promotional and marketing activities, including the receipt of newsletters;
- conducting statistical research, opinion polls and market research;
- activation and use of automated or non-automated profiling mechanisms, that do not base decisions that have legal effects and do not significantly affect the natural persons involved.
Who deals with data
Your personal data will be processed by Brainpull internal staff, specifically trained and authorized to process.
Your personal data will also eventually be transmitted to third parties that we use to provide our services or carry out our activities; these subjects have been adequately selected and offer a suitable guarantee of compliance with the rules concerning the processing of personal data. These subjects were assigned by Brainpull, they carry out their activity according to the instructions given by Brainpull and under his control.
The third parties in question belong to the following categories: banking operators, internet providers, companies specialized in IT and telematic services; couriers; companies that carry out marketing activities; companies specialized in market research and data processing.
Your data may be disclosed to the police and the judicial and administrative authorities, in accordance with law, for the detection and prosecution of offenses, the prevention and protection from threats to public security, to allow Brainpull to establish, exercise or defend a legal claim, as well as for other reasons related to the protection of the rights and freedoms of others.
Web push notification
Depending on the device from which you surf, you may receive, with your consent, push notifications regarding our company, its products or services.
To turn off notifications, depending on the platform and / or browser, follow the steps listed below:
- Desktop: Click with the right mouse button on the notification > disable notifications from brainpull.com
- Mobile: Access the notification center > Site parameters > Notifications > Block notifications from brainpull.com
- Common browsers:
- Chrome: Settings > Show Advanced Settings > Privacy - Content Settings > Notifications - Manage exceptions > Insert brainpull.com and select "Block"
- Firefox: Options > Contents > Notifications - Choose > brainpull.com - “Block”
- Safari: Preferences > Notifications > From here set the selector to "Reject"
Extra-eu data transfer
Some of the third parties listed in the previous paragraph "Who deals with DATA" could be located in countries outside the European Union that nevertheless offer an adequate level of data protection, as established by specific decisions of the European Commission (http://www.garanteprivacy.it/home/provvedimenti-normativa/normativa/normativa-comunitaria-e-intenazionale/trasferimento-dei-dati-verso-paesi-terzi#1).
The transfer of your personal data to countries that do not belong to the European Union and that do not ensure adequate levels of protection will be performed only after conclusion between Brainpull and aforementioned subjects of specific agreements, containing safeguard clauses and appropriate safeguards for the protection of your personal data called "standard contractual clauses", also approved by the European Commission, or if the transfer is necessary to the conclusion and execution of a contract between you and Brainpull (for registration on the Site or use of services on the Site) or for the management of your requests.
How long we store the data
We keep your personal data for a limited period of time, different depending on the type of activity that involves the processing of your personal data.
After this period, your data will be permanently erased or otherwise rendered anonymous in an irreversible way.
Your personal data are stored in compliance with the terms and criteria specified below:
- data related to user requests: the useful data will be retained until the fulfillment of your request;
- data collected in the context of the use of services offered on brainpull.com: these data are stored until no more than 12 months after the sending of a communication of verification of authorization to the aforesaid treatment by brainpull.com, or, in case of absence of verification communications, no more than 12 months from the authorization for the aforesaid treatment;
- CV: for 12 months from receipt;
- data used for commercial communication activities to users who have given their consent to brainpull.com: these data are stored for up to not more than 12 months from sending an authorization verification message for the aforesaid treatment by brainpull.com, or, in case of absence of verification communications, no more than 12 months from the authorization for the aforesaid treatment;
- data for stastistiche research activities, opinion polls and market research in respect of users who have provided express consent to brainpull.com: these data are stored for up to 12 months from sending an authorization verification message to the aforementioned treatment by brainpull.com, or, in case of absence of verification communications, no more than 12 months from the authorization for the aforesaid treatment;
- personal data related to your browsing, such as the pages you visit and how you interact with the single page, ie traffic, to the extent strictly necessary and proportionate to ensure network and information security: no more than 60 months after acquisition;
- personal data relating to the activation and use of automated, or non-automated profiling mechanisms, that do not base decisions that have legal effects and do not significantly affect the natural persons involved: these data are stored up to no more than 12 months from sending an authorization verification message to the aforementioned treatment by brainpull.com, or, in case of absence of verification communications, no more than 12 months from the authorization for the aforesaid treatment;
However, for technical reasons, the termination of the treatment and the subsequent definitive cancellation or anonymisation being irreversibly related personal information will be final within thirty days from the terms above.
Revocation of consent, access to data and other rights
At any time you can exercise your rights with respect to specific treatments of your personal data by Brainpull. Find below their general description and how to exercise them.
- Access your data and modify them: you have the right to access your personal data and to request that they be correct, modified or supplemented with other information. If you wish, we will provide you with a copy of your data in our possession.
- Revoke your consent: you can cancel a consent at any time that you have provided for the processing of your personal data in relation to the following activities: the satisfaction of your requests for information and requests for assistance; for the performance of one of the services offered by brainpull.com; to apply for a job position; for the carrying out of promotional and commercial activities; for conducting statistical research, opinion polls and market research; for the activation and use of automated, or non-automated profiling mechanisms, that do not base decisions that have legal effects and do not significantly affect the natural persons involved. Once we receive your request, it will be our care to cease the treatment promptly of your personal data that is based on such consent, while different treatments or based on other assumptions will continue to be carried out in full compliance with the provisions in force.
- Oppose to the processing of your data: you have the right to object at any time to the processing of your personal data on the basis of our legitimate interest, explaining the reasons that justify your request; before accepting it, Brainpull will have to evaluate the reasons for your request.
- Delete your data: in the cases provided for by the current legislation you can request the cancellation of your personal data. Received and examined your request, if legitimate, it will be our care to immediately stop processing and delete your personal data.
- Request that the processing of your personal data is temporarily limited: in this case Brainpull will continue to store your personal data but will not process them, unless you have made a different request and the exceptions established by law. You can get the limitation of the treatment when you contend the accuracy of your personal data, when the processing is illegal but you oppose the cancellation of your data, when we no longer need your data, but you need it to exercise your right in court and when you oppose the treatment, in the period in which we evaluate the reasons for your request.
- Request your data or transfer them to a person other than Brainpull ("Right to data portability"). You can ask to receive your data that we process based on your consent or on the basis of a contract with you in a standard format. If you wish, where technically possible, at your request, we will be able to transfer your data directly to a third party that you have indicated to us.
In order to exercise some of your rights described above you can send an email to firstname.lastname@example.org by inserting "privacy" as an object.
To ensure that our users' data are not infringed or illegitimate by third parties, before accepting your request to exercise one of the rights indicated, we will ask you some information to be sure of your identity.
We protect your personal data with specific technical and organizational security measures, aimed at preventing your personal data from being used illegitimately or fraudulently. In particular, we use security measures that guarantee: pseudonymisation or encryption of your data; the confidentiality, integrity, availability of your data as well as the resilience of the systems and services that process them; the ability to restore data in the event of a data breach. Furthermore Brainpull undertakes to test, verify and regularly evaluate the effectiveness of technical and organizational measures in order to guarantee continuous improvement in the safety of treatments.
If you believe that the processing of your personal data has been carried out unlawfully, you can file a complaint with one of the competent control authorities for compliance with the rules on personal data protection.
In Italy, the complaint can be presented to the Guarantor for the Protection of Personal Data.
More information on the methods of presentation are available on the website of the Guarantor, at http://www.garanteprivacy.it.
Amendments to this statement
We invite you, therefore, to periodically check the contents: where possible, we will try to inform you promptly about the changes made and their consequences.
The updated version of the privacy information, in any case, will be published on this page, with indication of the date of its last update.
Legislative references and useful links
The processing of your personal data is carried out by Brainpull, in full compliance with the relevant regulations provided for by Regulation (EU) 2016/679 general regulation on data protection, of the rules concerning the processing of Italian personal data and of the provisions of the Italian Supervisory Authority (http://www.garanteprivacy.it).
Last date update: 02/09/2018