Privacy Policy

Information on the processing of personal data pursuant to Articles 13 and 14 of EU Reg. n. 679/2016

Identity Event S.r.l. collects and uses your personal data when you browse or use the online services on https://drivetodream.eu

By personal data we mean any information that can be used to identify an individual.
The purpose of this policy is to provide you with a clear and detailed explanation of how, when and why we collect and use personal data, and it is designed to give you a simple and transparent explanation of our data protection policy, as well as to show you how to effectively exercise your rights. 
This information refers only to the data processed by Identity Event S.r.l. through this website and does not concern other websites, platforms or social network pages that may be reached through links: in these cases, you should always refer to the information available on the respective pages.
This information may be subject to changes and variations over time, so we invite you to regularly consult this page to be updated on the processing of personal data.

INDEX:

1. When do you collect my data?
2. What data do you process? For what purposes and on which legal basis?
3. With whom will you share my data?
4. For what further purposes can you use my data?
5. How will you process my data?
6. Will my data be processed outside Europe?
7. How long will you keep my data?
8. Links to third party sites and social networks
9. What are my rights and how can I protect my privacy?
10. Can I lodge a complaint?
11. Possible changes

1. Who is the Data Controller?

Identity Event S.r.l. (C.F. 91426780374) is the Data Controller, as it determines the means and purposes of the processing of personal data involved in the use of this website.
For further information, you can contact the Data Controller by sending a communication to the following:

• mail: Identity Event S.r.l., Viale Matteotti 45, 20095, Cusano Milanino (MI), Italy;
• PEC: identityeventsrl@legalmail.it.

2. When do you collect my data?

Identity Event S.r.l. will collect information directly provided by you:

• when you access and navigate the site;
• when you send questions or ask for advice through the dedicated sections or contacts;
• ­­­­­­­when you register on the Site;
• when you make a purchase on the e-commerce platform;
• when you register and participate in the prize competition.

3. What kind of data do you process? For what purposes and on what legal basis?

When you browse or use the services on https://drivetodream.eu, the following types of data may be processed:

1. Navigation data

Some personal data whose transmission is implicit in the navigation on this website are acquired by the computer systems that allow its proper functioning, including but not limited to data traffic and concerning the location, weblog and other data regarding the resources you access through your device. Although this information is not collected to be associated with identified data subjects, it could allow users to be identified - by its very nature and through processing and association with data held by third parties. For example, navigation data include IP addresses or domain names of computers used by users who connect to the Site, the addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response given by the server and other parameters relating to the operating system and browser used.

• Purpose of the processing: allow you to browse the website safely and correctly;
• Legal basis for the processing: the legitimate interest of Identity Event S.r.l. in the proper functioning of the site and the safety of navigation, regularly balanced with the rights of the person concerned (art. 6, paragraph 1, lett. f, GDPR).

2. Request for information through the indicated addresses

You can contact us at the addresses indicated on the site, as well as through the mailto links incorporated on the site, to request information or assistance; this involves the acquisition of data required to identify the request (your e-mail address and the information you decide to include in the text of the message) and authorizes us to send you any reply communications using the contact details you provided at the time of the request.

• Purpose of processing: ensure adequate support in relation to your needs and to respond to your requests;
• Legal basis for the processing: the provision of the service you have requested (art. 6, paragraph 1, lett. b, GDPR).

3. Purchase of services

From the Site it is possible to purchase the services and courses made available by the Data Controller on the virtual catalog: to complete the purchase procedure, you will be asked for the data necessary to identify yourself (and verify your suitability, in case of purchase of reserved services, for example, for over 16 years), contact you, to make the payment and billing. For the service purchase procedure, we use the WooCommerce platform provided by the company WooCommerce Ireland Ltd.; for more information, please consult the relevant Privacy policy (https://automattic.com/privacy/ ) or contact it at the e-mail address: privacypolicyupdates@automattic.com . For the payment service, we use Stripe Inc. as an intermediary: for more information, please consult the relative Privacy policy (https://stripe.com/it/privacy ) or consult the DPO at the e-mail address dpo@stripe.com . In any case, the Data Controller never becomes aware of the payment data, but only receives confirmation or not of the correct outcome of the payment procedure carried out by the user.

If you request the cancellation of your personal account, the data relating to the purchases made will be stored by the Data Controller for the time required by law, in particular in the tax and fiscal fields.

In relation to this service, you will be able to receive communications via e-mail, concerning the purchase confirmation, as well as any interruption of the process (eg. "Abandoned cart") or any problems (for example, in the event of errors in the method of payment).

• Purpose of processing: make purchases through our platform;
• Legal basis for the processing: the provision of the service you have requested and the execution of a contractual relationship of which the data subject is a party (art. 6, paragraph 1, lett. b, GDPR).

4. Registration and access to the personal account

When you purchase services from the Site, you will be asked to create a personal account by filling out the form on the appropriate page in order to verify the information relating to the purchase made and to use the requested service.

For registration and access to the reserved area, the following personal data of the user are collected: name and surname; email address, telephone number, Steam ID, residential address, age. The provision of this data is mandatory because it allows the Data Controller to verify the possession of the participation requirements by the user both in the online course purchased and in the Competition promoted by the Data Controller. The password will be chosen and can always be freely changed by the user, based on the security features set by the Data Controller (for example, number and type of characters that can be used). When you have created your personal account, your page will store information relating to your identification and contact details, your purchases (including payment methods and billing addresses).

You will also have the option at any time to cancel the account and all data stored there: in this case, some data must still be kept by Identity Event S.r.l. for the time periods required by applicable law (for example, billing data relating to purchases made). After deleting your account, only the data relating to the registration of your requests, registration and cancellation will be kept by the Data Controller, necessary to demonstrate the correct fulfillment by the Data Controller.

• Purpose of processing: provide the service requested by the data subject and take advantage of the features and services reserved for holders of a personal account, including the ability to make purchases, view the history of purchases;
• Legal basis for the processing: the execution of a contractual relationship of which the data subject is a party (art. 6, paragraph 1, lett. b, GDPR).

5. Prize competition

To participate in the Competition it is necessary to register through the appropriate page on the Site and fill in the form with the required data: this information is necessary to verify that the user is in possession of the requirements to participate in the Competition as provided for by the Regulations (for example, the date of birth is required to verify that the user requesting to participate is at least 16 years old) and to manage the subsequent phases of the competition and the awarding and delivery of prizes.

The data thus acquired will be used exclusively for participation in the Competition and will be kept for the time required by law, within the limits of what is strictly necessary. In particular, in relation to the Competition, user data will be processed for activities functional to participation, to manage communications relating to the competition phases and the collection of prizes in the event of a win and to fulfill the obligations envisaged by law (in particular, DPR 430/2001) provided for the organization and management of the Competition.

• Purpose of processing: allow the user's participation in the Prize Competition and manage the preparatory and instrumental activities for the Competition itself;
• Legal basis for the processing: the execution of a contractual relationship of which the data subject is a party (art. 6, paragraph 1, lett. b, GDPR).

6. Sending communications for marketing purposes in the context of legitimate interest and soft spam

In some cases, we may use the e-mail address communicated by the user using the site to send some promotional communications, even without requesting the user's prior consent. This treatment will be carried out in compliance with the provisions of art. 6, lett. f), GDPR and art. 130, co. 4, of Legislative Decree 130/2003. In particular, users are informed of the processing activity through this information and they are always granted the right to object, in a simple and freeway, to such processing: every communication sent by the Data Controller, in fact, contains a reference to this information. and the indications on how to request the interruption of the treatment (by opt-out), by contacting the Data Controller.

• Purpose of processing: inform you about products similar to those of your previous purchase and of your possible interest
• Legal basis for the processing: the regulatory provision referred to in art. 130, paragraph 4, legislative decree 196/2003 which legitimizes the sending of communications regarding products or services similar to those already requested (Article 6, paragraph 1, letters c and f, GDPR)

7. Cookies

What are cookies? A cookie is a small text file that stores brief information about your browsing on a particular website and is installed on your device when you log in. Each cookie contains various data (e.g., the name of the server it comes from, a numeric identifier, etc.), and it may remain on your system for the duration of a session (until you close your browser) or for long periods and may contain a unique identifier.
When you visit the site again, they will be redirected to the site that generated them (first-party cookies) or to those provided by third parties able to recognize them (third-party cookies).

What are they for? Identity Event S.r.l. would like to reassure you about the security of the cookies on its website: they do not damage your device in any way, but they will allow you to navigate faster, giving you a better experience. Cookies are used for different purposes depending on their nature.

What type of cookie is present?

a. Technical and functional cookies (which do NOT require your consent).

These cookies are necessary for the functioning of the site and allow you to access its functions (so-called navigation cookies) or to authenticate the session.

There is also the use of functional cookies, which allow you to store your preferences and settings, thereby improving your browsing experience on the site.

To ensure their functionality, these cookies are not deleted when you close the browser. However, they have a fixed duration (usually up to a maximum of 2 years) and after this period they are automatically deactivated. These cookies and the data they collect will in no way be used for any further purposes.

The installation of technical cookies occurs automatically after accessing the site or to activate certain features (e.g. by selecting the "remember me" option). At any time you can decide to disable them by changing the settings of your browser: but in this case you may experience some problems in viewing the site.

• Purposes of the processing: ensure the proper functioning and security of the site;
• Legal basis for the processing: exception to the need for user consent, allowed by art. 122 of Legislative Decree 196 of 2003 (art. 6, paragraph 1, lett. c, GDPR).

b. Analytical and statistical cookies (which may require your consent)

These cookies keep track of the choices made on the site and data relating to users' online browsing (for example, pages viewed, dwell times on a page, etc.), in order to perform statistical analysis, in anonymous and aggregate form. These tools can be used only after expressing the user's consent. An exception to this rule is only the case in which the following circumstances occur:
- the IP address has been duly anonymized;
- the information obtained with analytical cookies refer to a single IT resource (site, app, etc.) and are used only in anonymous and aggregate form;
- the cookie provider does not combine the information with other processing and does not pass it on to third parties.

If these requirements are met, the complete anonymization of the data collected is guaranteed and even the cookies falling into this category can be activated without the need for the user's consent, precisely because the data processed cannot be linked to any identifiable user.

• Purposes of the processing: to have statistics relating to user behavior on the Site, based on aggregated and anonymized data.
• Legal basis of the processing: depending on the case:
  - the legitimate interest of Identity Event S.r.l. to optimize the performance of the Site and improve the services provided through the Site, regularly balanced with the rights of the data subjects (Article 6, paragraph 1, letter f, GDPR);
  - the user's consent (Article 6, paragraph 1, letter a, GDPR), freely provided and revocable at any time, via the cookie banner or by following the instructions below and in the Cookie Policy -link.

Disabling via browser

From the site http://www.youronlinechoices.com/it/ it is possible not only to acquire further information on cookies, but also to check the installation of cookies on your browser/device and also to disable them.
Commonly used browsers (e.g., Internet Explorer, Firefox, Chrome, Safari) accept cookies by default, but this setting can be changed by the user at any time. This applies to both PCs and mobile devices such as tablets and smartphones: it is a generally and widely supported feature.
Therefore, cookies can easily be deactivated or disabled by accessing the options or preferences of the browser used and generally only third party cookies can be blocked; in general, these options will only take effect for that browser and on that device, unless options are active to unify preferences on different devices. Specific instructions can be found on the options or help page of the browser itself.
Disabling technical cookies, however, may affect the full and/or proper functioning of various sites, including this Site.
As a rule, the browsers used today:

• offer a "Do not track" option, which is supported by some (but not all) websites. As a result, some websites may no longer collect certain browsing data;
• offer the option of anonymous or incognito browsing: this means that no data will be collected in the browser and no browsing history will be saved, but browsing data will still be collected by the operator of the website visited;
• allow the deletion of all or part of the stored cookies, but on a new visit to a website they might be installed.

We indicate the links to the support pages of the most popular browsers (with instructions on how to disable cookies on these browsers):

• https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie);
• https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies);
• https://support.apple.com/it-it/guide/safari/sfri11471/mac) and
• https://support.google.com/chrome/answer/2392971?hl=it).

4. For what further purposes can you use my data?

Your personal data may also be used in order to:

1. comply with legal obligations and requests from public or governmental authorities;
2. manage any disputes or litigation and therefore defend the rights of Identity Event S.r.l. both in and out of court.

In such cases, the legal bases of the treatment will be:

• for point a), the fulfilment of a legal obligation (art. 6, paragraph 1, letter c, GDPR);
• for point b), the legitimate interest of the Data Controller in the protection of its rights, provided that it is adequately balanced, from time to time, with the rights of the data subject (art. 6, paragraph 1, lett. f, GDPR).

5. With whom will you share my data?

In compliance with the purposes indicated in the previous section, the staff of Identity Event S.r.l. may oversee processing your data, in order to provide you with the services, information or support requested. Therefore, access to your personal data will be expressly authorized by the Data Controller, who, if necessary, may appoint the subjects to whom it applies for the provision of services and for the activities of its competence as Data Processors to rule of articles 28 and 29 of the GDPR.
In particular, also for the management of the Site and the Prize Competition, the Data Controller has appointed the companies Ak Informatica of AK BOSS S.r.l. as data processors. & C. S.a.s. and Espservice S.r.l. (delegated subject pursuant to art. 5 of Presidential Decree 403/2001).
The data collected for the aforementioned purposes may also be disclosed to associated companies or companies belonging to the same corporate group as the Data Controller and to subjects authorized for this purpose by provisions of law and European legislation.The data of the participants in the Competition (name and surname), together with the scores / times achieved, will be published on the Site on the page relating to the classification of the races and may be published on the social pages of the Owner. User data will in no case be transferred to third parties except in the case in which the nature of the services rendered requires it, or in the case in which, by virtue of a legal obligation or in the presence of a legitimate interest, the Data Controller has the need to communicate them to the competent judicial or supervisory authorities.

6. How will you process my data?

Your personal data will also be processed with the aid of electronic means for the time strictly necessary to achieve the purposes intended at the time of their collection.
Identity Event S.r.l. will take appropriate technical and organizational measures to prevent loss, illegal or incorrect use of data, as well as to prevent possible unauthorized access by third parties. Therefore, Identity Event S.r.l. will protect the security of your personal data, limiting the number of people who will be allowed access to servers or databases and providing protection systems to limit the risk of cyber-attacks.

7. Are my data processed outside Europe?

The data processed by Identity Event S.r.l. reside in servers located within the Italian territory, owned by Aruba SPA.
However, some service providers used on the Site (for example Stripe Inc. and Google Inc.) are based in non-European countries, in particular in the United States. In these cases, personal data may also be collected on servers located in the United States, but they will still be processed in compliance with European legislation. The transfer of data, in particular, will only take place in compliance with the provisions of Articles 45 et seq. of the GDPR. Therefore, all necessary precautions will be taken in order to ensure the most complete protection of personal data basing such transfer: a) on adequacy decisions of the third country recipients expressed by the European Commission; b) on adequate guarantees expressed by the third party recipient pursuant to art. 46 of the Regulation; c) on the adoption of corporate binding rules.

8. How long will you keep my data?

Identity Event S.r.l. will process your personal data for the reasonably necessary time to achieve only the purposes listed above, which can be found in the Sections "What data do you process? For what purposes and on what legal basis?" and "For what further purposes may you use my data?" or o for the retention terms provided for by the sector legislation: for example, the data relating to the purchases made will be kept for the period provided for by the laws on fiscal and tax matters and indicatively for a period of 10 years. For the terms of cancellation of data processed by cookies you can find the information in our Cookie Policy.
At the end of the retention period, your personal data will be deleted or irreversibly anonymized and aggregated.

9. Links to third party sites and social networks

The Website may contain links to and from the websites of our partners, as well as to advertisers and social networks. Please note that the Data Controller assumes no responsibility for the personal data that may be collected through these sites and the use of the related services and that, if the user follows a link to any of these websites, he is invited to consult the Privacy policy provided by each external party.

10. What are my rights and how can I protect my privacy?

In relation to your personal data and in accordance with the GDPR, Identity Event S.r.l. informs you that you have the right to request:

• access to your data;
• the modification and rectification of any errors in our databases relating to your data;
• The cancellation of your data if they are held in the absence of the legal prerequisites;
• the limitation of the processing of your data;
• opposition to the processing of your data;
• the portability of your data.

Any templates and more information are also available here: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1089924.

In the following table we explain in detail how to exercise your rights:

Identity Event S.r.l. guarantees that any request concerning your rights will be answered within thirty days of receipt.

11. Can I file a complaint?

You have the right to lodge a complaint with the Authority for the protection of personal data, if you believe that the treatment carried out by Identity Event S.r.l. does not comply with the requirements of the European Regulation No. 679/2016 and national legislation.
In Italy, the competent authority is the Garante per la protezione dei dati personali, whose contact details are available at http://www.garanteprivacy.it/.
More information and the sample document to be used for the complaint are available here: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524.
In addition, if the prerequisites set out in Articles 78 and 79 of the GDPR are met, you have the right to bring an appeal before the competent judicial authority.

12. Possible changes

The information we are providing you with now may change over time, when processing activities change, when data is collected or when legislative or regulatory changes occur, as well as when technological developments occur. We therefore advise you to periodically consult this page to keep up to date on the processing carried out.