My Private Welfare – VAT IT06943400488 (MPW) is the data controller for the processing of your personal data. Below, MPW has provided an overview of the processing activities in which personal data are processed, including among others the purpose thereof and the legal basis.
Categories of personal data, purpose and legal basis
When you visit MPW’s website www.myprivatewelfare.com, MPW will process personal data about you, for instance, location data, cookies and your IP-address. The purpose of the processing of your personal data, which MPW obtains when you visit the website, is to provide you with the content of MPW’s website, including providing you with a better website experience and to prepare website statistics.
The legal basis for the processing of your personal data is your consent, which you will be asked to give when you visit the website, cf. Article 6(1)(a) of the GDPR.
Member account on MPW
MPW offers subscribers, who have created an account, to use all the services corresponding to the activated subscription form.
When you create a member account on our website, MPW will process personal data about you, for instance, your email address, name, location data, telephone number, your picture if you provide this, your comments to posts and conversations with other members, your followers and who you are following, your IP-address, etc. The purpose of the processing of your personal data is to provide you access to our platform and give you the possibility to use the technical solutions in our platform.
The legal basis for the processing of your personal data is that the processing is necessary for the performance of a contract entered into between you as subscriber and MPW, cf. article 6(1)(b) of the GDPR. The legal basis for such processing of your personal data might also be or alternatively be that processing is necessary for the purposes of legitimate interests pursued by MPW and that it is our assessment that our legitimate interests override your interests or fundamental rights and freedoms, cf. article 6(1)(f) in the GDPR. Our legitimate interests constitute maintaining and enhancing customer relationships, business development, and providing our customers with our services.
Customer support inquiries
If you submit an inquiry relating to MPW’s services to our customer support, MPW will process personal data included in your inquiry and any other personal data of relevance to the inquiry. The personal data processed will be your name, your email address, the personal data included in your inquiry, etc.
The legal basis for such processing of your personal data is that the processing is necessary for the purposes of legitimate interests pursued by MPW and that it is our assessment that our legitimate interests override your interests or fundamental rights and freedoms, cf. article 6(1)(f) in the GDPR. Our legitimate interests constitute customer support.
If you subscribe to our newsletter, MPW will process your name and email address. The purpose of the processing of your personal data is to provide you with our newsletters.
The legal basis for such processing of your personal data is that the processing is necessary for the purposes of legitimate interests pursued by MPW and that it is our assessment that our legitimate interests override your interests or fundamental rights and freedoms, cf. article 6(1)(f) in the GDPR. Our legitimate interests constitute marketing of MPW’s services, including maintaining and enhancing customer relationships.
Recipients of your personal data
Where relevant, MPW may disclose or transfer your personal data to vendors, business partners or other collaborators for business purposes.
Certain recipients process personal data on behalf of MPW and may only process your personal data in accordance with documented instructions given by MPW and further terms and conditions stated in a data processor agreement entered into with MPW. These data processors are not permitted to process your personal data for their own purposes.
Transfer of your personal data to a third country (outside of eu/eea)
In certain cases, MPW will transfer your personal data to third countries outside of EU/EEA, for instance the U.S. If your personal data are transferred to such third countries, MPW will ensure that such transfer will be carried out in accordance with applicable data protection legislation so that an adequate level of protection is ensured. If the personal data are transferred to recipients established in so-called ”unsafe” third countries that are not approved by the EU-Commission, we ensure an adequate level of protection for instance by entering into the EU-Commission”s standard contractual clauses or by transferring personal data to recipients that adhere to approved certification mechanisms such as the EU-U.S. Privacy Shield Agreement in case of transfers to the U.S.
If in exceptional cases, none of the above legal bases apply, MPW will obtain your explicit and prior consent to the transfer of your personal data to the specific third country.
Storage of your personal data
MPW will only store your personal data as long as it is deemed necessary to fulfill your personal data processing.
If you have a subscriber account on our website, we will store your personal data as long as you have a subscriber account. If you choose to delete your account, we will delete the personal data about you shortly thereafter.
MPW will store your personal data to the extent necessary for bookkeeping purposes, such as personal data related to invoicing. Such personal data will be stored for a period of 10 years from the expiry of the fiscal year to which the accounting records relate to. The purpose is to comply with the obligations in the Italian Bookkeeping Act.
We have implemented a number of measures to protect your personal data and ensure your rights. As a data subject, you can exercise the rights listed below. However, some of the rights only apply under certain circumstances.
The Italian Data Protection Agency has prepared guidelines regarding the data subjects’ rights.
Right of access
You have the right to request access to, including the disclosure of a copy of, the personal data that we process about you as well as the right to receive information on:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries and in that connections the necessary measures carried out prior to the transfer;
- the envisaged storage period or the criteria used to determine that period;
- the existence of the right to request rectification, erasure, restriction or objection against processing of your personal data, including especially processing of personal data in connection with direct marketing purposes;
- the right to lodge a complaint with the Danish Data Protection Agency;
- where your personal data are obtained from if the personal data are not collected from you; and
- the existence of automated decision-making, including profiling, and as a minimum meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
Right to rectification
You have the right to have inaccurate personal data about yourself rectified as well as the right to request completion of incomplete personal data concerning you.
Right to erasure (”right to be forgotten”)
Under certain circumstances you have the right to obtain from MPW the erasure of personal data concerning your, for instance if the processing is based on your explicit consent and you withdraw this consent.
Right to restriction of processing
You have the right to restrict MPW’s processing of your personal data, for instance, in the event you dispute the accuracy of the personal data.
Right to data portability
When our processing of your personal data is carried out automatically and is based on your consent or a contract with you, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format and the right to transmit those personal data to another data controller, if this is technically feasible.
Right to object
You have the right to object, on grounds relating to your particular situation, at any time to our processing of your personal data which is based on point (e) or (f) of Article 6(1) in the GDPR. This applies at any time where personal data are processed for direct marketing purposes.
Right to not be subject to automated individual decision-making
You have the right not to be subject to a decision based solely on automatic processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Right to withdraw a consent
If you have given us your consent to the processing of your personal data, you have the right to withdraw such consent at any time. However, the withdrawal of your consent will not affect the lawfulness of processing of your personal data based on consent before its withdrawal.
Questions or complaints
You can also file a complaint to the Italian Data Protection Agency, which is an independent public authority that is, inter alia, responsible for monitoring and enforcing the application of the GDPR.
March 31, 2021