Privacy Policy

Preamble

This website, deskbell.com, hereafter referred to as “our website”, is owned and managed by MPNWORK S.R.L. Unipersonale, hereafter referred to as “MPNWORK” or “we” or “data controller” or “controller”.

This privacy policy shall be read together with our website terms of use and cookies info.

Our website visitors and users are hereafter referred to as “user” or “users” or “you” or “data subject” or “data subjects”.

This privacy policy describes how we use and store the data that we gather from users in order to provide our products and services offered through our website which may include, but not limited to: Browsing; Registering; Managing your account; Posting content; Messaging; Using any section and functionalities of our website as forums, question and answers, polls, blogs, calendars, downloads, galleries, shops, pages, articles, feeds, groups, clubs; Advertising; Using paid services; Making sales enquiries; Asking for commercial information regarding our services; Sending of a resume; Sending of e-mails to the addresses or using the contact forms indicated on our website.

This privacy policy does not apply to other websites consulted by user through links in our website or through a frame in our website. In such and similar cases user shall refer to the other website terms of use and privacy policy.

Our commitment to privacy

Processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with EU Regulation 2016/679 (General Data Protection Regulation) and in accordance with national data protection regulations applicable to MPNWORK. By means of this privacy policy, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this privacy policy, of the rights to which they are entitled.

Definitions

This privacy policy should be legible and understandable for the general public, as well as our customers and business partners. To accomplish this, we would like to explain the terminology used. In this privacy policy, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, 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.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

f) Pseudonymization

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; Where the purposes and means of such processing is determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor or data processor

The processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, is authorized to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Name and address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

MPNWORK S.R.L. Unipersonale (a Ltd. Company with sole shareholder)
Sede Legale/Registered Office: Via Marcello Malpighi, 4 - 09126 Cagliari – Italy
Capitale Sociale/Share Capital: Euro 10.000,00 i.v.
C.F., P.I. e n. iscr. al Registro Imprese di Cagliari/Tax, VAT and registration no. in Cagliari: 03894130925
n. REA/REA no.: CA – 304833

Any inquiries relating to privacy may be forwarded in writing to MPNWORK registered office address or via the Contact Us link at the bottom of this page.

Data processor and location of the personal data

Our website, including all of the data associated with it, is hosted in servers located in the USA and managed by a premium hosting provider, a USA headquartered company.

Data may be transferred and processed in the United States and anywhere in the world where we and/or our Subprocessors maintain data processing operations. Any transfer of the personal data to any third countries or international organizations in the future shall only be done to the extent such transfer is permitted and done in accordance with the applicable law.

Processing of personal data of users, in some instances, may take place at and by MPNWORK, this when necessary for the data to be processed outside of hosting facilities. One of such cases, but without limitations, would be for instance when we answer to an email from a user of the website. This will be carried out by means of manual or automated instruments for the time strictly needed for the purposes for which the data were collected and the data may be stored in paper or in electronic format in our paper files or computers.

Google

On our website we use third party Google services as Google Analytics, to track and report our website traffic, and Google Adsense to display ads served by Google and its partners. Please refer to third party google privacy policy to know how Google gathers and uses information from our website.

Cookies

Our website as other websites in the Internet, uses cookies. Cookies are text files that are stored in a computer system via a browser. Many websites and servers use cookies. Many cookies contain a cookie ID, which is a unique identifier of the cookie, it consists of a character string through which web pages and servers can be assigned to the specific browser in which the cookie was stored. This allows visited websites and servers to differentiate the individual browser of the data subject from other browsers that contain other cookies. A specific browser can be recognized, identified and authenticated using the unique cookie ID.

Through the use of cookies, MPNWORK can provide the users of our website with user-friendly services that would not be possible without the use of cookies. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. A user that uses cookies does not have to enter access data each time our website is accessed and our website preferences are retained for user convenience. Where available, our shopping cart and client systems also utilize cookies to ensure a seamless experience.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the browser used, and may thus permanently deny the setting of cookies. Existing cookies may be deleted at any time via a browser or other appropriate software; a function that exists in all major Internet browsers. If the data subject deactivates the setting of cookies in the browser used, not all functions of our website will be entirely usable.

Please check also cookies info.

Type of data processed and purpose of the processing

Navigation of our website is free and does not require registration by the user except in cases where the collection of personal data is needed to achieve certain objectives such as for instance, but not limited to: Registering; Managing account; Posting content, messaging or interacting in any section of our website as forums, question and answers, polls, blogs, calendars, downloads, galleries, shops, pages, articles, feeds, groups, clubs; Advertising; Using paid services; Making sales enquires; Asking for commercial information regarding our services; Sending of a resume; Sending e-mails to the addresses or using the contact forms indicated on our website. Therefore, during access to our website, it is possible to distinguish the data from the single user navigation and the data voluntarily provided by the user in relation to certain purposes.

Collection of general data and information

MPNWORK collects a series of general data and information when a data subject or automated system accesses our website. This general data and information is stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to our website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our systems and infrastructure.

When using this general data and information, MPNWORK does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website, (3) ensure the long-term viability of our systems and infrastructure and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack. Therefore, MPNWORK analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our organization, and to ensure an optimal level of protection for the personal data we process. The anonymous data within relevant logs are stored separately from all personal data provided by a data subject.

Data deriving from the user's browsing

During normal operation, computer systems and software procedures acquire some personal data whose transmission is implicit when using Internet communication protocols. This information is not collected to be associated with identified individuals, but, due to its very nature and through processing and association with data held by third parties, could identify users. MPNWORK never commissions or has third parties carry out the processing and association of data. This category of data includes IP addresses or the domain names of the computers used by users who connect to our website, Uniform Resource Identifier addresses of resources requested, 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 reply given by the server (successful, error, etc.) as well as other parameters relative to the operating system and the user's computing environment. This data is used by MPNWORK exclusively in anonymous form for statistical purposes related to the use of our website and its proper functioning. The data could be used and stored in case of suspected computer crimes against our website, for which MPNWORK reserves the right to resort to the competent authorities to ascertain any liability.

Registration on our website

The data subject has the ability to register on our website with the indication of personal data. What personal data is transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors or sub processors that also uses personal data for an internal purpose which is attributable to the controller.

By registering on our website, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration is also stored. The storage of this data takes place in the background and is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate misuse of our systems and services. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to transmit the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data is stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.

Data provided voluntarily by the user

Personal data provided voluntarily by users who interact with our website by giving their personal data to MPNWORK for the attainment of certain services as for instance, but not limited to: Browsing; Registering; Managing account; Posting content, messaging or interacting in any section of our website as forums, question and answers, polls, blogs, calendars, downloads, galleries, shops, pages, articles, feeds, groups, clubs; Advertising; Using paid services; Making sales enquiries; Asking for commercial information regarding our services; Sending of a resume; Sending of e-mails to the addresses or using the contact forms indicated on our website are used solely to provide the service or provision requested, and are communicated to third parties only when strictly necessary for the performance of the service (shipment of materials provision of assistance, etc.). Specific summarized information will be reported or displayed in the pages of our website dedicated to on-demand services in order to draw the attention of the party for which the personal data will be processed. Apart from the information specified above regarding navigation data, the transfer of personal data is optional, although functional to the provision of certain services; therefore, in these cases, failure to provide data may impair or prevent the provision of service.

Other data we collect

We collect the content, communications and other information you provide when you use our website, including when you sign up for an account, create or share content and message or communicate with others. This can include information in or about the content that you provide (e.g. metadata), such as the location of a photo or the date a file was created.

We collect information about the users, content, hashtags and groups that you are connected to and how you interact with them across our website, such as people you communicate with or groups that you are part of.

We collect information about how you use our website, such as the content that you view or engage with, the features you use, the actions you take, the users you interact with and the time, frequency and duration of your activities. For example, we log when you're using and have last used our website, and what posts and other content you view on our website.

If you use our website for purchases or other financial transactions, we collect information about the purchase or transaction. This includes payment information, other account and authentication information, and billing, delivery and contact details.

We also receive, communications and information that other users provide when they use our website. This can include information about you, such as when other users share or comment on a content you provided, send a message to you.

We collect information from and about the computers, phones and other web-connected devices you use when you use our website. For example, we use such information to better personalise the content served or for the security of your account.

How do we use data

We use the information that we have, subject to choices you make, as described below, and to provide and support the use of our website and related services described in our website terms of use.

We use the information we have to deliver our website, including to personalise features and content, make suggestions for you such as groups or events that you may be interested in or topics that you may want to follow. To create personalised services that are unique and relevant to you. We use your connections, preferences, interests and activities based on the data that we collect and learn from you and other users how you use and interact with our website; and the people, places or things that you're connected to and interested in on and off our website.

We use the information that we have to verify accounts and activity, combat harmful conducts, detect and prevent spam and other bad experiences, maintain the integrity of our website security. For example, we use data that we have to investigate suspicious activity or breaches of our terms of use or policies.

We use the information that we have to send you marketing communications, communicate with you about our products and services, to let you know about our terms of use and policies.

We use your information to respond to you when you contact us.

Sharing of data

Using our website you can post information which can be public, therefore can be seen by anybody browsing our website, or restricted and can be seen only to selected users or groups of users. When you share and communicate information using our website, you choose the audience for what you share.

For example you could post information visible only to you or to another user or to a group of users, if respectively only you or that user or group of users have read access to that information, which is seldom the case while more commonly the information you could post on our website would be public if not for specific cases.

Public information can be seen by anyone, including if they are just browsing our website and are not registered users. This includes your username, any information you share with a public audience in any section of our website, information in your public profile.

Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, RSS feeds and by apps, websites and other services that integrate with our website.

You should consider who you choose to share with, because people who can see your information on our website can choose to share it with others on and off our website, including people and businesses outside the audience that you shared with. For example, when you share a post or send a message to a specific user, they could download, screenshot or reshare that content to others across or off our website, in person or online. Also, when you comment on someone else's post or react to their content, your comment or reaction is visible to anyone who can see the other person's content, and that person can change the audience later.

Users can also use our website to create and share content about other users with the audience they choose. For example, people can share a photo you posted, mention a post you published, or share information about you in their posts or messages. If you are uncomfortable with what others have shared about you on our website, you can report that to us.

People can see signals telling them whether you are active on our website, including whether you are currently active on any section of our website or when you last used it.

When you choose to use third-party apps, websites or other services that use, or are integrated with, our website, they can receive information about what you post or share. Information collected by these third-party services is subject to their own terms of use and privacy policies.

Data the users shall not provide to us or make public or share through our website

Our website is mainly about hotels and related subjects. We do not ask that users, and users shall not, provide to us data with special protections as for instance about religious views, political views, who you are "interested in" or your health, racial or ethnic origin, philosophical beliefs or trade union membership.

Our website allows user to publish information which then becomes public and accessible to anyone. It also allows user to share information with other users or with groups of users.

User shall not include other person’s personal data in such information which will become public or will be shared with other users or groups of users.

We strongly recommend user to not include his or her personal data in information which will become public or will be shared with other users or groups of users, as this would result in the personal data becoming public beyond his or her control.

Subscription to our website newsletters

Users are given the opportunity to subscribe to our website newsletter, hereafter referred to as the newsletter. The input mask used for this purpose determines what personal data is transmitted, as well as when the newsletter is ordered from the controller.

MPNWORK informs our website users, customers and business partners regularly by means of the newsletter about product improvements and promotions. The newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject, for legal reasons, as part of a double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties, unless such transfer is necessary exclusively for the processing and delivery of the newsletter to the data subject. The subscription to the newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for delivery of the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on our website.

Newsletter tracking

Newsletters delivered by MPNWORK may contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which is sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of marketing campaigns. Based on the embedded tracking pixel, MPNWORK may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters is stored and analyzed by the controller in order to optimize the delivery of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, this personal data will be deleted by the controller. MPNWORK automatically regards a withdrawal from the receipt of the newsletter as a revocation.

Contact possibility via our website

Our website contains information that enables a quick electronic contact to our company, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller is stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties, unless necessary to deliver further correspondence.

Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the data controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements. If a statutory purpose for storing data no longer exists, all personal data and applicable purchase information is erased and purged from our system after a period of five (5) years.

Rights of the data subject

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her is being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

- the purposes of the processing;

- the categories of personal data concerned;

- 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;

- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;

- the existence of the right to lodge a complaint with a supervisory authority;

- where the personal data is not collected from the data subject, any available information as to their source;

- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data is transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary (eg. in cases where a financial transaction has occurred):

- The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;

- The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing;

- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR;

- The personal data have been unlawfully processed;

- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by MPNWORK, he or she may, at any time, contact any employee of the controller. An employee of MPNWORK shall promptly ensure that the erasure request is complied with in accordance with applicable laws and regulations.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, the personal data, as far as processing is not required. An employee of MPNWORK will arrange the necessary measures on an individual basis.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use;

- 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 defence of legal claims;

- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by MPNWORK, he or she may at any time contact any employee of the controller. The employee of MPNWORK will take the appropriate steps to restrict further processing.

f) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact any employee of MPNWORK.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR.

This also applies to profiling based on these provisions. MPNWORK shall no longer process the personal data in the event of the objection, unless we can demonstrate 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.

If MPNWORK processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to MPNWORK to the processing for direct marketing purposes, MPNWORK will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by MPNWORK for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of MPNWORK. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, MPNWORK shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of MPNWORK.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of MPNWORK.

Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations is necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which is necessary for carrying out pre-contractual measures such as inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. The processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which is not covered by any of the aforementioned legal basis, if processing is necessary for the purposes of the legitimate interests pursued by our company 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.

The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

It may sometimes be necessary to determine, under contractual obligation, the data subject provide us with personal data, which must subsequently be processed by us. The data subject is, for example, obligated to provide us with personal data when our company enters into a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee shall clarify to the data subject whether the provision of the personal data is required by law or contract or is necessary for the execution of the contract, whether there is an obligation to provide the personal data and the related consequences of not providing the personal data.

Third Parties

a) Google Analytics

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services. Please visit google partner sites and google privacy policy to know how Google gathers and uses information from our website.

a) Google Adsense

Google Adsense is used in our website to display ads served by Google and its partners. Please visit google partner sites and google Privacy Policy to know how Google gathers and uses information from our website.

b) Invisible reCAPTCHA

This site may use a CAPTCHA to ensure humans are performing certain actions. The CAPTCHA provider may set a session cookie and get information about your internet browser and device accessing this website. Please visit google partner sites and google privacy policy to know how Google gathers and uses information from our website.

New owner

If the ownership or control of all or part of our website or its assets changes, we may transfer, without prior notification to users, users information to the new owner including the personal data of users and all information provided by and relevant to the users.

In such cases the present privacy policy will be updated by the new owner to reflect the change in ownership, to update the data controller information and, if the case, to update the data processor information.

Revision of the privacy policy

Although we will try to avoid unnecessary changes to this privacy policy, we will make changes when we feel these are required, as for instance when legislation or our website changes, therefore users are required to check this privacy policy regularly.

Date of last revision: 16 February 2021.