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Data protection policy

Last modified : March 24, 2023

FlashStart Group Srl manufactures, sells, distributes, and markets security solutions and systems, filtering, and protection of computer networks.

FlashStart Group Srl, together with its subsidiaries, is seriously committed to the protection of the personal data that it collects from interested parties (hereinafter referred to as “User”) offline, through, for example, paper forms, contracts, statements (hereinafter referred to as “Forms”), or online, through the website www.flashstart.com, www.flashstart.it , www.flashstart.es (here in after referred to as “Site”), and through, but not limited to, FlashStart Group Srl’s (web) applications, software, and digital tools (hereinafter referred to as “Applications”).

Pursuant to the European General Data Protection Regulation (EU) 679/2016 (GDPR), for the pur-pose of:

» providing transparency about the nature of the personal data that FlashStart Group Srl collects offline, via Forms, or online, via the Site and/or via the Applications;
» ensuring transparency in the use of the personal data collected;
» facilitating data subjects in exercising their rights;

The protection of personal data is important to FlashStart Group Srl.  The company seeks to process personal data in a lawful, appropriate, and transparent manner.

Please read this data protection notice and its key terms, indicated below in capital letters.

In this regard, if you have any questions or comments, please contact FlashStart Group Srl directly.

1. Data controllers, data controllers and data processors

FlashStart Group Srl and its subsidiaries, as established within the European Union, are subject to the General Data Protection Regulation (EU) 679/2016 (GDPR) and any future legislation, pursuant to the aforementioned regulation, that becomes law in the member state in which they are located.

The Data Protection Officer (DPO) is attorney Francesco Amato, with an office in Forlì at Corso Mazzini 16 and email address avvocati.cancroamato@gmail.com.

1.1 Data controllers

Personal data submitted by the user offline, through forms, or online, through the website and/or applications, are used for the purposes described below by FlashStart Group Srl, headquartered in Italy, in Cesena, via Cervese 1424 (P.IVA: IT03187460401), in its capacity of data controller.

The subsidiaries of FlashStart Group Srl act as data controllers with regard to the processing of personal data collected offline, via forms, or online, via the website and/or applications.

1.2 Data controllers

In the future, it is possible that FlashStart Group Srl, together with its subsidiaries, will jointly establish, on the basis of a written agreement, the purposes and methods of processing personal data as data controllers (by way of example, but not limited to, in all cases where the subsidiary is particularly involved in processing personal data locally for the development of a project).

In the above cases, subjects whose personal data are to be processed by the data controllers will be informed accordingly.

1.3 Data processor

FlashStart Group Srl may also act as a data processor on behalf of its subsidiaries for any online or offline processing of personal data.

Subsidiaries of FlashStart Group Srl may act as a data processors on behalf of and at the instruction of FlashStart Group Srl, where data processing agreements are in place.

2. Personal data collected by FlashStart Groyup Srl and purpose

FlashStart Group Srl, to the necessary extent, collects, processes, records, stores, and transfers personal data of users provided offline, via forms, or online, via the website and/or the applications in, but not limited to, the following instances:  visiting the Website, using the applications, completing offline or online registration forms; reporting instances of non-compliance; contacting FlashStart Group Srl; submitting job applications; clicking social media buttons; providing feedback (e.g. on forms, products, applications, website, customer support); responding to surveys and other activities.

Personal data are collected on an optional or mandatory basis.  If it is mandatory to provide personal data, it will be marked accordingly.  In the event that a user omits or refuses to provide the personal data that FlashStart Group Srl has marked as mandatory, the company will consequently be unable to perform the processing or activity requested by that data subject.

An example of personal data marked as mandatory is the situation in which a user wishes to submit registration forms.  In this case, FlashStart Group Srl requires certain personal data in order to process the relevant registration request.  If the user wishes to register but does not provide the personal data marked as mandatory, FlashStart Group Srl will not be able to accept and process the registration request.

FlashStart Group Srl may collect personal data on the basis of consent or without the consent of the user if:

» it is necessary to satisfy a legal obligation;
» a contract to which the person concerned is a party must be made or executed;
» there are legitimate, public, or vital interests to be protected that override the rights of the data subject involved;
» an authority has requested FlashStart Group Srl to process personal data.

FlashStart Group Srl may further process personal data only:

» if the purpose of further processing is compatible with the purpose of the initial collection of the user’s personal data;
» if the user gives his or her consent to the further processing of data for a new purpose that is incompatible with the purposes of the initial collection of personal data.

In subparagraphs 2.1 and 2.2, the personal data collected by FlashStart Group Srl and the purposes of the collection are reported.

2.1 Personal data that FlashStart collects from the user or third parties

The user may be required to provide to FlashStart Group Srl, depending upon the purposes of each transaction and to the necessary extent, different types of personal data including, but not limited to, first name, last name, title, address, telephone, cell phone , email address, language, country, natio-nality, personal social media URL, preferences, interests, feedback.

FlashStart Group Srl also uses personal data, which are provided by the user to third parties, such as service providers, or personal data in the public domain, such as commonly recognized personal data, personal data visible on its website or blog, or posted on publicly accessible social media profi-les.
FlashStart Group Srl may also receive personal data through third parties as a result of mergers, acquisitions, or any other transformation operation.

2.1.1 Purposes of Personal Data Collection.

After being collected, the above-mentioned personal data are used for a number of purposes, listed below:

» Business administration and client management

FlashStart Group Srl must be able to execute contracts properly and correctly, and perform all necessary accounting and legal procedures.  Accordingly, FlashStart Group Srl will need some personal data provided by users offline, via forms, or online, via the website and applications.  Pursuant to Regulation (EU) 679/2016, for the purposes of contract execution, the consent of the data subject, who is or will be a party to a contract, is not required.

With reference to managing customer relationships and providing customer services, FlashStart Group Srl uses personal data (e.g., name, country, nationality, email address, customer code) in order to:

  • assess whether or not it would be feasible to sell products or provide services to a customer before entering into a contract;
  • process written customer requests, customer orders for products and services, and cashback requests;
  • identify and contact customers for a discount;
  • inform customers of their additional rights and services related to the purchased product or service;
  • inform customers of Daikin’s events and promotional campaigns and send them invitations;
  • manage access to FlashStart Group Srl’s premises, site and applications;
  • organize and perform customer and installer support;
  • inform customers of an upcoming maintenance deadline;
  • communicate important network information safety information to customers and contacts in general.

» Product distribution

FlashStart Group Srl uses personal data to distribute products and, specifically, to:

  • assist its European subsidiaries in distributing products and in providing services through authorized agencies, business partners, the website, and/or through applications;
  • assist distributors in the delivery of products, parts, and services (e.g., personal data is included in the delivery notes that accompany the transportation of a purchased product);
  • optimize sales and services by developing offers for customers;
  • improve and accelerate the distribution of FlashStart Group Srl’s products and services;
  • review technical data of facilities and the status of contracts and projects;
  • organize and provide training for customers, installers, employees, and subcontractors.

» Supplier management

FlashStart Group Srl uses personal data to keep records related to suppliers and service providers, to record and manage purchase orders, business expenses, and invoices provided by suppliers and service providers.

» Direct marketing

As a leading manufacturer and provider of network security solutions, FlashStart Group Srl is able to provide information tailored to the user and his or her needs (e.g., by using transaction data, FlashStart Group Srl is able to inform the user about services, offers, and suggestions related to the purchase (called “direct marketing”).

FlashStart Group Srl uses collected personal data, publicly available personal data (e.g., information available on the internet, through search results, social media results) or personal data received from third parties (e.g., internet service providers) for direct marketing purposes and to attract new customers.

FlashStart Group Srl also conducts direct marketing activities with the goal of organizing internal events, trips, presentations, and meetings for employees, customers, and business partners.

FlashStart Group Srl conducts direct marketing through a variety of media, including, but not limited to, text messages on cell phones, surveys, email, the website, online advertising, database marketing, applications, and events.

FlashStart Group Srl conducts direct marketing based on its legitimate interest in pursuing business objectives.

FlashStart Group Srl may engage in direct marketing.  If the user does not wish to receive a highly personalized offer, the user may, at any time, withhold consent to receive direct marketing when requested.

FlashStart Group Srl is committed to ensuring that direct marketing information is provided in a clear and appropriate manner, and this is done using the channel designated by the recipient in order to minimize the inconvenience of being disturbed.

» Improving the quality of products and services.

FlashStart Group Srl uses personal data collected through forms, job applications, surveys, comments, feedback sent to FlashStart Group Srl to improve its products and services, conduct additional surveys, develop analytical, risk, marketing and other models, and to produce statistics.  FlashStart Group Srl also uses user transaction data to develop comprehensive models and perform analysis.

Example: FlashStart Group Srl may need to process the number of people who have purchased a certain product or have requested a specific service.

For this purpose, FlashStart Group Srl strives as much as possible to combine personal data in an anonymous or pseudo-anonymous form, in order to ensure that such personal data are not easily identifiable or are no longer identifiable as user data.

The practice of processing personal data for statistical purposes is particularly justified by FlashStart Group Srl’s desire to implement strategic choices, in order to have better performance in the market and to provide the user with better products and services.

Personal data may also be used to assess, simplify, and improve FlashStart Group Srl’s processes, for example, to optimize campaigns, procedures, and sales, both offline and online, through the website and/or applications.

Example: if the user did not complete a procedure or sales transaction, FlashStart Group Srl may contact the user to find out what the problem was and whether help can be provided to the user.  In that case, FlashStart Group Srl limits its contact to providing technical and administrative support for that specific procedure or specific transaction.

» Recruitment and selection.

In order to recruit “talent,” FlashStart Group Srl collects personal data, such as, but not limited to, name, email, phone number, resume information, and social profile URLs of open and targeted candidates applying, e.g., for job openings, international internships, student internships.

Personal data provided by candidates (through filling out forms or registering and creating a personal account on the website or when accessing applications) will be used to process applications, contacting candidates for activities related to human resources management, managing recruitment processes ( e.g., inviting candidates to interviews and conducting written tests), and entering into employment contracts.

FlashStart Group Srl is committed to deleting from its archives the personal data belonging to candidates who are not hired at the end of the selection process, and there is no legitimate reason to retain them.

» Personnel management and salary benefits.

FlashStart Group Srl uses personal data for personnel management purposes and, in particular, to:

  • manage and keep track of labor contracts and payroll;
  • pay salaries
  • keep track of employee attendance, travel, and training activities;
  • communicate with health insurance companies;
  • provide employees with insurance, company assets, and performance-related compensation benefits.

» Record keeping and accounting.

FlashStart Group Srl uses personal data for record keeping and accounting purposes and for the purpose of:

  • keeping track of transactions;
  • issuing invoices for sales and services provided;
  • filing tax returns and related forms to fulfill tax obligations;
  • compile statistics based upon transaction data (e.g., on the number of transactions made and in which area);
  • comply with current legislation and regulatory requirements at national, as well as European and international, levels.

» Grievances and legal disputes.

FlashStart Group Srl may use personal data as evidence and to ascertain, exercise, and protect its own rights or the rights of those whom the company represents (e.g., Srl to defend itself against acts of unfair competition or FlashStart Group Srl’s right to solicit fulfillment of an unpaid invoice).

» Fraud and crime prevention.

FlashStart Group Srl may also use personal data to prevent, detect, and investigate crimes and cyber risks for legitimate interest or when a public authority requests it.

» Business operations and office management.

FlashStart Group Srl transmits and/or jointly uses personal data collected with its subsidiaries and/or business partners only when necessary and for the purpose of preparing periodic reports on results and aspects of the company’s business, business plan, and strategies.

FlashStart Group Srl provides for the processing of legally collected personal data of European citizens, unless there is a legal impediment (e.g., an obligation of confidentiality or a provision of data protection laws).

FlashStart Group Srl is committed to implementing all appropriate measures for the protection of personal data with regard to intra-group communications in line with Regulation (EU) 679/2016.

2.2  Personal data otained by using the website and/or applications

2.2.1 Purposes of Personal Data Collection.

When the user visits the website and/or applications, FlashStart Group Srl collects some of his or her personal data for the following purposes:

» Making it easier to use the website and/or applications.

By collecting certain personal data (e.g., IP address, login data), FlashStart Group Srl is able to fully customize the website and/or applications according to the user’s needs.

» Monitoring the interests and preferences of users.

3. Disclosure of collected personal data to third parties

For the above purposes, FlashStart Group Srl may need services, advice, and/or assistance from third parties, including, but not limited to, for application maintenance and bug fixes, purchase of applications, hosting of data, advice on compliance with laws and regulations, application development, human resources services, provisioning services, internet provider services, production of statistics, and more.

In this regard, to the necessary extent, FlashStart Group Srl may transmit or disclose collected personal data to any human or legal entity, subcontractors, or business partners who are third parties with respect to FlashStart Group Srl. It does not sell or acquire any personal data or data from third parties for its own use.

If FlashStart Group Srl needs to transmit or disclose to a third party some collected personal data, except in the case of the legitimate interest of the third party, FlashStart Group Srl will ensure that it has a data processing agreement with such third party under the provisions of Regulation (EU) 679/2016, requiring the third party to comply with the principles and provisions of that regulation and to comply with the appropriate security standards.

4. Transfer of personal data to non-european union countries (NON-EU)

For the purposes described above, FlashStart Group Srl jointly transmits and uses collected personal data belonging to data subjects present in the European Union, with DIL and/or other Daikin Group companies and/or business partners based in any non-European Union country.

FlashStart Group Srl has established appropriate standard contractual clauses and adequate safeguards regarding the possible transfer of personal data between subsidiaries.  In every occurrence of the transfer of personal data to a non-EU country, FlashStart Group Srl is committed to:

  • ensuring an adequate level of protection by establishing appropriate safeguards and complying with the provisions of Regulation (EU) 679/2016;
  • handling the transfer of personal data on the basis of:

(a) European Union adequacy decisions; OR

(b) standard contract clauses/binding corporate standards; OR

(c) code of conduct approved by the competent supervisory authority/official safety certifications.

  • handling the transfer of personal data on the basis of the consent of the data subject whose personal data is to be transferred, or on the basis of the exceptions in Article 49 of Regulation (EU) 679/2016, if the transfer cannot be made on the basis of cases (a),  (b), (c).

5. Data storage and related criteria

FlashStart Group Srl does not store the user’s personal information forever.  FlashStart Group Srl uses personal data to the necessary extent and only for the purpose of fulfilling the purposes described above.  Once the purpose is fulfilled, FlashStart Group Srl agrees to delete the user’s personal data unless its storage is required by law or at a national, European, or international level.

The starting point for the storage of personal Data is the legal storage period (which is often ten years and lasts until the expiration of a contract or the end of the business relationship).  The period may be longer where necessary for FlashStart Group Srl to exercise its rights.

If no storage period is stipulated by law, the storage period may be shorter in accordance with, but not limited to, one of the following criteria:  duration of contract and legal obligations; business and organizational needs; long-term business relationship; pursuit of direct marketing, statistics.

Some ideas become clearer only when they are considered over a longer period of time.  Therefore, for some types of personal data, a longer time line may be necessary (e.g., for those needed to design risk and marketing models).

As mentioned, FlashStart Group Srl is committed as much as possible to working with aggregated, anonymized, or anonymized pseudo-personal data, and, in any case, will terminate connections with individuals as quickly as possible.

6. Rights of the interested party and related operating procedures

If there are any questions regarding the protection of one’s personal data or the exercise of one’s rights, the user may contact FlashStart Group Srl, at any time, by writing to FlashStart Group Srl or to one of its subsidiaries, by calling FlashStart Group Srl or one of its subsidiaries, by sending an appropriate form via email, or by submitting the form available online in each “contact FlashStart Group Srl” section through the website and/or applications.

Following the processing of personal data, the user has various rights, as an interested party, which can be exercised as indicated below.

The user must be as specific as possible whenever he or she wishes to exercise his or her rights.  FlashStart Group Srl can only respond appropriately to requests expressed in sufficient detail.  FlashStart Group Srl must verify the user’s identity in as much detail as possible in order to prevent someone else from trying to exercise his or her rights. The user will therefore be asked to provide valid identification when sending such a request.

The user can access his or her own personal data.

If the user wishes to access the personal data that FlashStart Group Srl processes or would like more information about:

» the purposes of processing;
» the categories of personal data involved;
» the categories of recipients to whom personal data have been or will be disclosed;
» the expected data retention period or the criteria used to establish this period;
» the rights of the interested party;
» the rights that the interested party may exercise with respect to the processing by FlashStart Group Srl;
» the existence of an automated decision-making process, including profiling, and the expected consequences;

FlashStart Group Srl will use the personal data provided by the user, by way of the form, for the sole purpose of verifying and processing the request.

If the user exercises the right of access, FlashStart Group Srl will provide as complete a list as possible or a copy of the personal data.

The user may supplement/rectify/delete/limit the processing of his/her personal data.

It may happen that some personal data held by FlashStart Group Srl are not (or have ceased to be) correct.  It may also happen that the user wants to add something to his or her personal data that has been submitted to FlashStart Group Srl. The user may at any time request the correction or integration of his or her personal data by sending an email to: privacy@flashstart.com.

If the user wishes FlashStart Group Srl to delete his or her personal data, the request will be processed, unless an impediment or incompatibility emerges under the law or by virtue of legitimate interests in the deletion.  If the user wishes to request the deletion of his or her personal data, an email must be sent to: privacy@flashstart.com.

The user may obtain, at any time, the limiting of the processing of his/her personal data by sending an email to: privacy@flashstart.com.

The user may request portability of his or her personal data for himself or herself or for third parties.

If the personal data has been collected through electronic means, the user may request portability of the personal data provided for oneself or for third parties by sending an email to: privacy@flashstart.com.

The user may withdraw consent to the processing of his or her personal data.

If the user provides FlashStart Group Srl with his or her consent to the processing of personal data, he or she may subsequently revoke that consent, at any time, by following the suggested procedure, just as easily as he or she provided it.

If the user wishes to revoke his or her consent, he or she may do so, at any time, by sending an email to: privacy@flashstart.com.

The user may object to the processing of the data or to processing by automated decision-making systems.

If the user disagrees with the manner in which FlashStart Group Srl manages its legitimate interests in the processing of certain personal data, the user may object by sending an email to: privacy@flashstart.com.  FlashStart Group Srl shall process objections, unless there are legitimate reasons not to do so or reasons provided by law (for example, an objection will be rejected if the processing of personal data was conducted to combat fraud).

If the user does not consent to processing by automated individual decision-making for direct marketing carried out by FlashStart Group Srl, he or she may object at any time by sending an email to: privacy@flashstart.com.

If the user disagrees with the way in which FlashStart Group Srl manages the processing of personal data, or if he or she has other questions about it, he or she can always contact the data protection authority in his or her country of residence (for example, if residing in Italy, the user can contact the Data Protection Authority concerned: www.garanteprivacy.it; Privacy Commission, Rue de la Presse, 35, 1000 Brussels).

7. Data protection officer

Below is the contact information for the Data Protection Officer of FlashStart Group Srl:

» email address: privacy@flashstart.com;
» by mail:  (to the attention of) FlashStart Group Srl Data Protection Officer, via Cervese 1424 – 47521 Cesena (FC) – Italy.

8. Minors

Through its website or applications, FlashStart Group Srl does not process personal data of people under the age of sixteen, nor does it make commercial offers to them or attempt to contact them, unless their legal representative has given his or her consent.

9. Security measures for the protection of personal data

FlashStart Group Srl has implemented appropriate security measures in order to maintain the integrity and security, as well as to prevent the destruction, loss, accidental or unlawful alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed, in line with Regulation (EU ) 679/2016.

10. Further changes to this data protection policy

FlashStart Group Srl regularly seeks to improve its efforts in the protection of personal data.  This data protection policy may be amended or updated in light of future laws, at the international, European, or national level.

FlashStart Group Srl will inform the user of any material changes to this data protection policy offline or through online means (e.g., through the website, during the first visit or each time this data protection policy is updated).

The user can always find the most recent version of FlashStart Group Srl’s data protection policy at www.flashstart.com/privacy-policy or, for each application, by clicking on the “Data Protection Policy” section.