Request a demo
Product
AI emailAutomationSegmentationForms and popupsTransactional emailGDPR and privacy
DeliverabilityIntegrationsPricingRequest a demo

beMail › Legal › Privacy policy

Privacy Notice for Users

Ketchup Adv S.p.A., with registered office at Piazza Borromeo 14 – 20123 Milan, Italy, tax code/VAT no. 09211640967 (the “Controller”), owner of the website https://www.bemail.it (the “Site”), as controller of the personal data of users who browse and register on the Site (the “Users”), provides this privacy notice pursuant to Article 13 of EU Regulation 2016/679 of 27 April 2016 (the “Regulation” or “Applicable Law”).

This Site and any services offered through it are reserved for people aged eighteen or over. The Controller therefore does not collect personal data relating to people under 18. At Users’ request, the Controller will promptly delete any personal data relating to people under 18 that has been collected unintentionally.

The Controller gives the utmost consideration to its Users’ right to privacy and to the protection of their personal data. For any information about this privacy notice, Users may contact the Controller at any time:

  • By sending a registered letter with return receipt to the Controller’s registered office (Piazza Borromeo 14, 20123 – Milan, Italy);
  • By sending an email to richieste@ketchupadv.com

Users may also contact the Controller’s Data Protection Officer (DPO) at lapo.curinigalletti@ketchupadv.com.

1. Purposes of processing

Users’ personal data will be lawfully processed by the Controller under Article 6 of the Regulation for the following purposes:

  • contractual obligations and provision of the service, to allow browsing of the Site, to perform the Site’s general terms accepted by the User on registration, and to fulfil specific User requests. The data collected by the Controller for any registration on the Site include: the username chosen by the User, email address, name, gender, year or date of birth, postcode, and any personal information the User chooses to publish. Unless the User gives the Controller specific, optional consent to process their data for the further purposes described in the next section, the User’s personal data will be used by the Controller solely to verify the User’s identity (including by validating the email address), thereby preventing possible fraud or abuse, and to contact the User for service reasons only (e.g. sending notifications about the services offered on the Site). Without prejudice to the rest of this privacy notice, the Controller will in no case make Users’ personal data accessible to other Users and/or third parties.
  • administrative and accounting purposes, i.e. to carry out organizational, administrative, financial and accounting activities, such as internal organizational activities and activities needed to fulfil contractual and pre-contractual obligations;
  • legal obligations, i.e. to fulfil obligations imposed by law, by an authority, by a regulation or by European legislation.

Providing personal data for the purposes above is optional but necessary: if the data are not provided, the User will not be able to browse the Site, register on the Site or use the services offered by the Controller on the Site.

The personal data required for the purposes described in this section 1 are marked with an asterisk in the Site’s registration form.

2. Further purposes: marketing (advertising, direct sales and commercial communications)

With the User’s free and optional consent, some of the User’s personal data (name, surname, email address, date of birth, postcode, gender, phone number) may also be processed by the Controller for marketing purposes (advertising, direct sales and commercial communications), so that the Controller can contact the User by email to offer products and/or services of the Controller and/or third-party companies and to present offers, promotions and business opportunities.

If consent is not given, the ability to register on the Site will not be affected in any way. If consent is given, the User may withdraw it at any time by contacting the Controller as described in section 5. The User can also easily object to further promotional emails by clicking the consent withdrawal link included in every promotional email. Once consent has been withdrawn, the Controller will send the User an email confirming the withdrawal. The Controller informs Users that, after they object to promotional emails, they may still receive a few further promotional messages for technical and operational reasons (e.g. contact lists already compiled shortly before the Controller received the objection). If the User continues to receive promotional messages more than 24 hours after objecting, please report the problem to the Controller using the contact details in section 5.

3. Processing methods and data retention

The Controller will process Users’ personal data using manual and electronic tools, with logic strictly related to the purposes themselves and, in any case, in a way that ensures the security and confidentiality of the data.

Users’ personal data will be kept for as long as strictly necessary to fulfil the primary purposes described in section 1, or in any case as necessary to protect the civil-law interests of both the Users and the Controller.

In the cases described in section 2, Users’ personal data will be kept for as long as strictly necessary to fulfil the purposes described there.

4. Disclosure and dissemination of data

Users’ personal data may become known to the Controller’s employees and/or contractors in charge of managing the Site. These people, formally appointed by the Controller as “persons authorized to process”, will process User data solely for the purposes set out in this notice and in compliance with Applicable Law.

Users’ personal data may also become known to third parties that may process personal data on behalf of the Controller as “Data Processors”, such as providers of IT and logistics services needed to operate the Site, outsourcing or cloud computing providers, professionals and consultants.

Users have the right to obtain a list of any processors appointed by the Controller by contacting the Controller as described in section 5.

5. Data subject rights

Users may exercise the rights granted to them by Applicable Law by contacting the Controller:

  • By sending a registered letter with return receipt to the Controller’s registered office (Piazza Borromeo 14, 20123 – Milan, Italy);
  • By sending an email to richieste@ketchupadv.com

Under Applicable Law, the Controller informs Users that they have the right to be informed of (i) the source of the personal data; (ii) the purposes and methods of processing; (iii) the logic applied when processing is carried out by electronic means; (iv) the identity of the controller and processors; (v) the people or categories of people to whom the personal data may be disclosed or who may learn of them as processors or authorized persons.

Users also have the right to obtain:

  • access to, updating, rectification or, where they have an interest, completion of the data;
  • erasure, anonymization or blocking of data processed unlawfully, including data whose retention is not necessary for the purposes for which they were collected or subsequently processed;
  • confirmation that the operations in points a) and b) have been notified, including their content, to those to whom the data were disclosed or disseminated, unless this proves impossible or involves a manifestly disproportionate effort compared to the right protected.

Users also have:

  • the right to withdraw consent at any time, where processing is based on consent;
  • where applicable, the right to data portability (the right to receive all personal data concerning them in a structured, commonly used and machine-readable format), the right to restriction of processing and the right to erasure (“right to be forgotten”);
  • the right to object:
    • in whole or in part, on legitimate grounds, to the processing of personal data concerning them, even if relevant to the purpose of collection;
    • in whole or in part, to the processing of personal data concerning them for sending advertising material, direct sales, market research or commercial communications;
    • where personal data are processed for direct marketing, at any time, to processing for that purpose, including profiling to the extent it is related to such direct marketing.
  • if they believe that the processing concerning them infringes the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State where they habitually reside, where they work or where the alleged infringement took place). The Italian supervisory authority is the Garante per la protezione dei dati personali, Piazza di Monte Citorio n. 121, 00186 – Rome (http://www.garanteprivacy.it/).

6. Registration via “Connect with Facebook” (where applicable)

The Controller informs Users that those registered on Facebook may register on the Site through “Connect with Facebook” or an equivalent service, where this option is available on the Site. The data Facebook may share with the Controller through “Connect with Facebook” are: first name, surname, profile picture, the email address at which Facebook can contact the User (the actual address or an address on the proxymail.facebook.com domain), address and date of birth. The Controller will process these data solely for the purposes set out in this notice, in line with the consents given by the User from time to time. By joining “Connect with Facebook” and clicking “Allow”, the User agrees that the above data be transferred from Facebook to the Controller. The Controller will use these data to simplify registration by pre-filling the User’s registration form with the data provided by Facebook. Users of Facebook Connect can access the Site with the credentials they normally use for Facebook. For more information on “Connect with Facebook” and to change the related privacy settings, see: http://www.facebook.com/help/405977429438260/ and https://www.facebook.com/about/privacy/your-info-on-other.

The Controller is not responsible for keeping all the links in this notice up to date; whenever a link is broken and/or out of date, Users acknowledge and accept that they must refer to the document and/or section of the website referenced by that link.

This English version is a translation provided for convenience. In case of discrepancy, the Italian version prevails.