Privacy Policy pursuant to Article 13 of EU Regulation 679/2016

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This page represents the "Privacy Policy" of this website/application and aims to provide information on how the personal data of users interacting with this website/application are processed, who use the services provided by it, as well as to provide the information required by Article 13 of EU Regulation 2016/679.

This information is provided only for this website/application and not for other websites that may be consulted by the user via links found on this website.

Regulation (EU) 2016/679 on the protection of personal data (hereinafter, the "Regulation") sets out rules relating to the protection of individuals with regard to the processing of personal data, as well as rules on the free movement of such data, and protects the fundamental rights and freedoms of individuals, in particular the right to the protection of personal data.

Article 4, no. 1 of the Regulation states that "Personal Data" means any information relating to an identified or identifiable natural person (hereinafter, "Data Subject").

"Processing" means any operation or set of operations performed with or without the aid of automated processes and applied to Personal Data or sets of Personal Data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction (Art. 4, no. 2 of the Regulation).

Pursuant to Articles 12 et seq. of the Regulation, the Data Subject must be informed of the appropriate information regarding the Processing activities carried out by the Data Controller and the rights of Data Subjects.

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Data Controller
Pausetiv Srl
Registered Office: Corso Genova, 27, 20123, Milan (MI)
Email: info@pausetiv.com
Website: www.pausetiv.com
VAT ID: 13504440960

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Purposes of Processing and Legal Bases for Processing

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The user's personal data will be processed for the following purposes and on the legal bases indicated below:

1. For the conclusion and proper execution of the contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the data subject's request, for the registration of the user and the creation/management of a personal profile, the information and/or requested services/products, including subscription to informational newsletters; also to respond to requests sent by the data subject (information/products/services/newsletter subscriptions). The legal basis for the listed processing activities is Article 6(1)(b) of EU Regulation 2016/679.
2. To periodically send, through remote communication technologies (email, phone, SMS, WhatsApp), marketing communications about services, products, and activities offered by the Data Controller; the legal basis is consent, as provided by Article 6(1)(a) of EU Regulation 2016/679.
3. To periodically send, through remote communication technologies (email, phone, SMS, WhatsApp), newsletters and communications about services, products, and activities offered by the Controller's partners and sponsors, in the health and wellness sectors, that may be of interest to the data subject; the legal basis is consent, as provided by Article 6(1)(a) of EU Regulation 2016/679.
4. To send emails with marketing and promotional purposes for the sale of our products/services of the same type previously purchased by the data subject, unless the data subject objects to the processing, which can be done at any time; the legal basis for this type of processing is the legitimate interest of the Controller, as provided by Article 6(1)(f).
5. To respond to requests sent by the user via email and/or the contact form on the website; the legal basis is Article 6(1)(b) of EU Regulation 2016/679.
6. To enable and make functional website navigation, as well as to ensure an adequate level of security, integrity, and availability; the legal basis is the legitimate interest of the Controller, as provided by Article 6(1)(f).
7. For statistical analysis on aggregated or anonymous data, for the purpose of monitoring the proper functioning of the website, traffic, usability, and user interest; the legal basis is the legitimate interest of the Controller, as provided by Article 6(1)(f).
8. To establish, exercise, or defend a legal claim; the legal basis is the legitimate interest of the Controller, as provided by Article 6(1)(f).
9. To comply with legal obligations, regulations, EU legislation, or orders from Authorities; the legal basis is Article 6(1)(c).
10. To ensure that marketing communications regarding the products and services offered by the Controller, as well as those of its commercial partners and sponsors, including online advertising, are relevant to the interests of the data subject. For this purpose, personal data may be used to better understand the interests and preferences of the data subject so that we can anticipate what other products, services, and information may be of most interest, allowing us to personalize communications from the Controller to make them more relevant and engaging; the legal basis is consent, as provided by Article 6(1)(a).
11. To carry out market research to develop and improve our range of products, services, and activities offered by the Controller and its partners; the legal basis is consent, as provided by Article 6(1)(a).

Personal data may be processed, through the platform, by healthcare professionals to deliver their services. In such cases, the professionals act as independent data controllers, and the platform operator acts as a data processor. The healthcare professionals will provide their specific information notice pursuant to Articles 13 and 14 of EU Regulation 2016/679.

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Types of Data

The following data will be collected and processed as necessary for the purposes described above:

• Identifying data
• Contact data
• Data related to the contractual relationship
• Data related to the data subject’s preferences and interests
• Any health-related data
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Navigation Data

The computer systems and software procedures used to operate this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified individuals, but by its nature could, through processing and association with data held by third parties, allow users to be identified.

This category of data includes IP addresses or domain names of the computers used by users connecting to the site, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server's response (successful, error, etc.), and other parameters related to the user’s operating system and IT environment.

These data are used solely for the purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning, and are deleted immediately after processing.

The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site.

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Refusal to Provide Data

Apart from what is specified for navigation data, users/visitors are free to provide their personal data. In some cases, the provision of data is necessary, as any refusal to provide such data could make it impossible to conclude or properly perform the contract in which the Data Subject is involved and/or comply with legal obligations to which the Controller is subject.

The provision of data for processing that requires consent is optional; failure to provide such data will not prevent the use of the products/services offered by the Controller. Even in the case of given consent, the data subject still has the right to later object, in whole or in part, to the processing of their personal data for the purposes described above by simply contacting the Controller at the addresses indicated above.

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Source of Data

The data will be provided by the data subject.

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Methods of Processing

In accordance with Article 5 of the Regulation, the Personal Data being processed will be:

1. Processed lawfully, fairly, and transparently in relation to the data subject;
2. Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
3. Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
4. Accurate and, where necessary, kept up to date;
5. Processed in a manner that ensures appropriate security of the personal data;
6. Kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

Processing will be carried out using manual and/or IT and telematic tools with organizational and processing logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security, integrity, and confidentiality of the data, in compliance with the organizational, physical, and logical measures provided for by applicable regulations.

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Disclosure of Data

Personal data may be communicated to individuals authorized to process them, as well as to external processors appointed by the Controller (the complete list of external processors is available from the Controller), responsible for managing the purposes described above. With your consent, the data may also be disclosed to third-party companies that are sponsors and/or business partners of the Controller, who may use them for the purposes described in point 3) of the above section “Purposes of Processing.” In pursuing the above purposes, the data may be disclosed to other entities acting as autonomous controllers.

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Dissemination of Data

Personal data will not be subject to dissemination.

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Transfer of Data Abroad

For the purposes outlined above, Personal Data will be processed within the European Economic Area (EEA). If transferred to third countries, in the absence of an adequacy decision by the European Commission, the provisions set out in the applicable regulations regarding the transfer of Personal Data to third countries will be complied with, such as the Standard Contractual Clauses issued by the European Commission.

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Data Retention

In general, Personal Data will be retained for the time strictly necessary to pursue the purposes for which they were collected and processed, including the retention period required by applicable law and, in any case, for a maximum period of 10 years after the termination of the relationship with the Controller and for a maximum period of 2 years for the purposes for which your consent is required, unless it is necessary for the Controller to defend a right in court.

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Rights of the Data Subject

Pursuant to Articles 15 et seq. of EU Regulation 2016/679 and the applicable national legislation, the Data Subject may, in accordance with the methods and limits provided by the applicable law, exercise the following rights:

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Article 15 – Right of Access by the Data Subject

The data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning them are being processed, and, if so, access to the personal data and the following information:

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• a. The purposes of the processing;
• b. The categories of personal data concerned;
• c. The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
• d. Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• e. The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing concerning the data subject or to object to such processing;
• f. The right to lodge a complaint with a supervisory authority;
• g. Where the personal data are not collected from the data subject, any available information as to their source;
• h. The existence of automated decision-making, including profiling referred to in Article 22(1) and (4), and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

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Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

The right to obtain a copy of personal data must not adversely affect the rights and freedoms of others.

The data subject may exercise the right by sending a request to the contact details of the Controller. Identification may be required before responding, as this right can only be exercised by the data subject or a delegate.

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Article 16 – Right to Rectification

The data subject has the right to obtain from the controller the rectification of inaccurate personal data concerning them without undue delay. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by providing a supplementary statement.

The data subject may exercise the right by sending a request to the contact details of the Controller. Identification may be required before responding, as this right can only be exercised by the data subject or a delegate.

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Article 17 – Right to Erasure ("Right to Be Forgotten")

The data subject has the right to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller is obliged to erase personal data without undue delay.

If the controller has made the personal data public and is obliged to erase them, taking into account available technology and the cost of implementation, the controller shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested the erasure of any links to, or copies or replication of, those personal data.

The right may be exercised if one of the following grounds applies:

• a. The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• b. The data subject withdraws consent on which the processing is based under Article 6(1)(a) or Article 9(2)(a), and where there is no other legal ground for the processing;
• c. The data subject objects to the processing pursuant to Article 21(1), and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
• d. The personal data have been unlawfully processed;
• e. The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
• f. The personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

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The right to erasure does not apply to the extent that processing is necessary:

• a. For exercising the right of freedom of expression and information;
• b. For compliance with a legal obligation which requires processing under Union or Member State law or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• c. For reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) and Article 9(3);
• d. For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1), insofar as the right is likely to render impossible or seriously impair the achievement of the objectives of that processing;
• e. For the establishment, exercise, or defense of legal claims.
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The data subject may exercise the right by sending a request to the contact details of the Controller. Identification may be required before responding, as this right can only be exercised by the data subject or a delegate.

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Article 18 – Right to Restriction of Processing

The data subject has the right to obtain from the controller restriction of processing.

If processing has been restricted pursuant to the paragraph above, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

A data subject who has obtained restriction of processing pursuant to the initial paragraph shall be informed by the controller before the restriction of processing is lifted.

The right may be exercised if one of the following conditions applies:

• a. The data subject contests the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data;
• b. The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
• c. The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims;
• d. The data subject has objected to processing pursuant to Article 21(1), pending the verification whether the legitimate grounds of the controller override those of the data subject.

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The data subject may exercise the right by sending a request to the contact details of the Controller. Identification may be required before responding, as this right can only be exercised by the data subject or a delegate.

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Article 19 – Notification Obligation Regarding Rectification or Erasure of Personal Data or Restriction of Processing

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1), and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it

‍The data subject may exercise the right by sending a request to the contact details of the Controller. Identification may be required before responding, as this right can only be exercised by the data subject or a delegate.

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Article 20 – Right to Data Portability

The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format, and has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.

In exercising the right to data portability under the paragraph above, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible.

The exercise of the right referred to in the initial paragraph shall not adversely affect Article 17 – Right to Erasure ("Right to Be Forgotten").

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The right may be exercised if the following conditions are met:

• a. The processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a), or on a contract pursuant to Article 6(1)(b); and
• b. The processing is carried out by automated means.

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This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The exercise of the right shall not adversely affect the rights and freedoms of others.

The data subject may exercise the right by sending a request to the contact details of the Controller. Identification may be required before responding, as this right can only be exercised by the data subject or a delegate.

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Article 21 – Right to Object

The data subject has the right to object at any time.

The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.

Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to their particular situation, shall have the right to object to processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

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The right may be exercised if one of the following conditions applies:

• - On grounds relating to their particular situation,
• - To the processing of personal data concerning them pursuant to Article 6(1)(e) (processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller) or (f) (processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child), including profiling based on those provisions.

The data subject may exercise the right by sending a request to the contact details of the Controller. Identification may be required before responding, as this right can only be exercised by the data subject or a delegate.

In the context of the use of information society services and notwithstanding Directive 2002/58/EC, the data subject may exercise their right to object by automated means using technical specifications.

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Exercising Rights

In general, to exercise their rights, the data subject may contact the Controller by writing to the contact details provided above.

Before responding, the Controller may need to identify the data subject, as rights may only be exercised by the data subject or someone delegated by them.

A written response will be provided without undue delay and, in any case, no later than one month from receipt of the request.

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Template Version: 1.0
Last modified: 07/07/2025

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