Privacy Policy

Information on the processing of personal data pursuant to articles 13 and 14 of EU Reg. No. 679/2016

3Labs Srl collects and uses your personal data when you browse or use the online services available on the website www.tomshw.it and on forum.tomshw.it. 
By personal data we mean any information that can be used to identify you as an individual.
The purpose of this information is to provide you with a clear and detailed explanation of how, when and why we collect and use your data. It has been designed to simply and transparently show you our privacy policy and show you how to effectively exercise your rights.
This information refers only to the data processed by 3Labs Srl through this Website and does not concern other websites, platforms or social network pages that may be reached via links on the Website: in these cases, it is always necessary to refer to the information available on the respective pages.
This information may undergo modifications and variations over time, so we invite you to consult this page regularly to be updated on the processing of personal data carried out.

INDEX:

  1. Who is the data controller?

  2. When do you collect my data?

  3. What data will you process?

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

  5. Who will you share my data with?

  6. How will you process my data? 

  7. Are my data processed outside Europe?

  8. How long will you keep my data?

  9. Links to third party sites and social networks

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

  11. Can I file a complaint?

  12. Any changes

1. Who is the data controller of my data?
Since 3Labs Srl, PI 04146420965, determines the means and purposes of the processing of personal data involved in the use of this website, it is the Data Controller.
You can contact the Data Controller by sending a communication to the following addresses:

  • by post: 3Labs Srl, Milan (MI) Via Dante 16;

  • e-mail: privacy@tomshw.it;

  • PEC: 3labs@pec.it.

2. When do you collect my data?
3Labs Srl will collect the information you provide directly:

  • when you access and browse the site;

  • when you send questions or advice through the sections or contacts dedicated to this;

  • when you ask for assistance on our services;

  • when you register on the Site;

  • when you use the services (e.g. forums, comments); 

  • if you are applying to work with us;

  • if you subscribe to the newsletter service.

3. What data will you process?
When you browse, use the services or make purchases on the 3Labs Srl website, the following types of data may be processed:

a) Navigation data
Some personal data whose transmission is implicit in the navigation of websites, including but not limited to data traffic and regarding location, weblog and other communication data for any billing purposes or regarding the resources accessed through the device, are acquired by the computer systems that allow them to function correctly. Even if this information is not collected to be associated with identified interested parties, it could allow users to be identified - by their very nature and through processing and association with data held by third parties. For example, they include the IP addresses or domain names of the computers used by users who connect to the Site, the unique 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 response given by the server and other parameters relating to the operating system and browser used.

  • Aims of treatment: allow you to use the Website safely and correctly;

  • Legal basis of the processing: legitimate interest of 3Labs Srl to the correct functioning of the Website and to the safety of navigation, regularly balanced with the rights of the interested party (Article 6, paragraph 1, letter f, GDPR).

b) Request for information
You can contact us via the contact form or using the contact details indicated on the site to request information or assistance; this entails the subsequent acquisition of the data you have communicated to us (name, surname, e-mail address and the information contained in the communication) and, obviously, it implies that you allow us to send you any response communications using the contact details you provided us at the time of the request.

  • Aims of treatment: ensure adequate support in relation to your needs and respond to your requests;

  • Legal basis of the processing: the provision of the service you have requested (Article 6, paragraph 1, letter b, GDPR).

c) Collaborate with us
You can contact us to submit your application for open job positions, by filling in the appropriate form in the "Collaborate with us" section or by using the contact details provided therein, and thus authorizing the Data Controller to process personal data for the aforementioned purpose. To this end, identification data (name and surname), a contact e-mail address will be requested and the curriculum vitae, a personal description, the position of interest and the texts to be examined may also be requested, as this is information necessary for 3Labs. Srl to evaluate your collaboration proposal.

The provision of these data is mandatory only for the presentation of one's candidacy and therefore it is left to the will of the individual candidate to decide whether to proceed with the sending of their curriculum vitae: any refusal will make it impossible to use the service, without further consequences. 

The consent to the processing is not necessary, pursuant to art. 111bis of Legislative Decree n. 196/2003 (the so-called Privacy Code, as amended by Legislative Decree no. 101/2018) and art. 9, paragraph 2, letter b) of the GDPR, when the processing concerns data contained in the curricula spontaneously transmitted by the candidates for the purpose of the possible establishment of the employment / collaboration relationship, even in the case of data falling within the particular categories provided for by art. . 9 of the GDPR (for example, in the hypothesis in which the data in question must be known due to the establishment of a working relationship, with particular reference to the possible belonging of the candidate to the protected categories or to the need to carry out pre-employment medical examinations). At the time of any interview, the interested party will be provided with all further information on the processing of their personal data.

The data will be kept for the period necessary to evaluate your request and, in any case, for a maximum period of two years. Furthermore, the cancellation of the data sent will be carried out at any time, in case of sending a specific request from the candidate to the Data Controller.

  • Aims of treatment: provide the service requested by the interested party and evaluate the application request received for the possible establishment of an employment relationship;

  • Legal basis of the processing: to execute the contractual relationship of which the interested party is a party (Article 6, paragraph 1, letter b GDPR).

d) 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 (for example, in the case of a personal account or specific requests) to send some promotional communications, even without asking the user for 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 free way, 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 processing (by opt-out), by contacting the Data Controller or by directly selecting the appropriate link made available at the bottom of each communication.

  • Aims of treatment: inform you about products similar to those of your previous purchase and of your possible interest;

  • Legal basis of the processing: the regulatory provision pursuant to art. 130, paragraph 4, of 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).

e) Newsletter
The 3Labs Srl newsletter is sent via e-mail to those who explicitly request it, by filling out the appropriate form on the Site with their e-mail address and authorizing 3Labs Srl to process their personal data for the aforementioned purpose. The service is provided exclusively upon explicit and unequivocal manifestation of consent by the user (issued by selecting the appropriate box on the Site) and the provision of data is mandatory only for the purpose of receiving the newsletter and any refusal will make it impossible. to use the service, without further consequences.
The newsletter service is provided through the “Elastic Mail” platform made available and managed by the company Elastic Mail Inc., based in British Columbia at PO Box 9038 Stn. Prov. Govt., Victoria, BC V8W 9A4 (privacy policy: https://elasticemail.com/resources/usage-policies/privacy-policy).
In any case, to stop receiving the newsletter, simply select the unsubscribe link, present at the end of each e-mail, or send a specific request to the e-mail address privacy@tomshw.it. The cancellation is managed in a partially automated way, so further newsletters could be received for a period subsequent to this request, in any case no later than 72 hours from the cancellation request, and the sending of which was planned before receiving the cancellation request.

  • Aims of treatment: send the interested party e-mail communications relating to 3Labs Srl products and services, news and updates on related topics, as well as offers and promotions reserved for subscribers to the service;

  • Legal basis of the processing: the consent of the interested party (Article 6, paragraph 1, letter a, GDPR).

f) Sending communications for marketing and / or commercial promotion purposes
The data communicated to 3Labs Srl can be used to carry out market surveys in order to improve the experience and quality of the services offered and to send you commercial communications from 3Labs Srl through suitable means of communication (such as e-mail or direct mail, SMS or telephone calls), in relation to the products and services offered, special events or the promotion of dedicated offers only in the event of the express consent given by the user for this treatment through the appropriate forms on the site.
On the site there are various requests for consent for marketing purposes, because commercial communications could be sent by 3Labs Srl and / or by third parties, commercial partners of the Data Controller: the processing needs in any case distinct and specific consents from the 'user. It is always possible to refuse consent to all these treatments, or to consent to the treatment only by 3Labs Srl or only by its commercial partners. In any case, after having granted it, it is always possible to revoke the consent issued and request the interruption of these processing activities. To this end, it is possible to use the specific links present in each communication received or to make a specific request to 3Labs Srl through the contact details indicated in this information.

  • Purpose pursued: carry out market surveys in order to improve the experience and quality of the services offered and send you commercial communications relating to the products and services of 3Labs Srl

  • Legal basis of the processing: the user's consent (Article 6, paragraph 1, letter a GDPR), freely provided and revocable at any time, by sending a communication to the Data Controller at the addresses indicated on the Site or by selecting the unsubscribe link at the bottom of each communication .

g) Data provided voluntarily by the user (to download guides, catalogs and other materials)
The user may decide to provide the Data Controller with the personal data requested from time to time to download the guides, catalogs and additional materials made available through the pop-ups and forms on the Site. By expressing explicit consent, the User may also consent to the receipt of advertising material. These and the other contents downloaded from the site represent material owned by the Owner. Therefore, the data provided for this purpose are used to identify the subject and to respond to his request. 

  • Purpose pursued: allow you to download the materials made available to users on the site.

  • Legal basis of the processing: the provision of the service you have requested (Article 6, paragraph 1, letter b GDPR).

h) Geolocation
If the user expressly agrees, the use of the Site may involve the collection of data relating to the geographical location of the device used by the user (geolocation): in this way, in fact, the User can receive content, including of an advertising nature, customized according to its geographical location. This function can be activated on the Site only if the User has previously consented to the detection of its location through the settings of the browser or of the device used for navigation. At any time, the geolocation services can be deactivated by accessing the appropriate section of the permissions for the localization of the operating system of the User's device.
The nature of the provision is optional; failure to provide it will make it impossible for the user to use the services based on geolocation, but the main services of the Platform can still be used; in this case, you can still use the search service by manually entering the area of ​​your interest. The data relating to the detection of the User's position are kept exclusively for the duration of a browsing session on the Platform.
Purpose: improve the functioning and efficiency of the services rendered through the Site.
Legal basis: the free and explicit consent of the user, pursuant to art. 6, lett. a), EU Reg. 679/2016, released via a specific button displayed on the Site to activate the geolocation service.

i) Cookies
What are? The term cookie indicates a small text file in which brief information relating to navigation on a particular website is stored, which will be installed on your device when you log in. Each cookie contains different data (for example, the name of the server from which it comes, a numeric identifier, etc.), it can remain in the system for the duration of a session (until the browser is closed) or for long periods and can contain a unique identification code.
When you visit the site again, they will be sent back to the site that generated them (first-party cookies) or to those provided by third parties able to recognize them (third-party cookies).
3Labs Srl intends to reassure you about the safety of the cookies on its website: they do not damage your device in any way, but will allow you to browse faster, offering you a better experience.
What are they for? Cookies are used for different purposes depending on their type: some are strictly necessary for the correct functionality of a website (technical cookies), while others optimize its performance to offer a better user experience or allow you to acquire statistics on the website. '' use of the Site, such as analytics cookies, or allow you to view personalized advertising, such as profiling cookies.
The 3Labs Srl site uses both cookies that do not require your consent for their installation (such as technical cookies), and cookies that require your prior consent in order to be used (such as profiling cookies).
In particular, the following can be activated on the site:

to. Technical 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 yourself in the session.
The use of functional cookies is also envisaged, which allow you to store your preferences and settings, thus improving your browsing experience within the site.
To ensure their functionality, these cookies are not usually deleted when the browser is closed; however, they have a predefined duration (generally 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 other purposes.
The installation of technical cookies takes place automatically following access to the site or to activate certain features (eg by selecting the "remember me" option). At any time you can always decide to disable them by changing the settings of your browser: in this case, however, you may encounter some problems in viewing the site.

  • Purpose pursued: ensure the correct functioning and security of the site;

  • Legal basis of the processing: the legitimate interest of 3Labs Srl in the correct functioning of the site and in the safety of navigation, regularly balanced with the rights of the interested party (Article 6, paragraph 1, letter f, GDPR).

b. Anonymized analytical cookies (which DO NOT 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.

  • Purpose pursued: 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 3Labs Srl in optimizing the performance of the Site and improving the services provided through the Site, regularly balanced with the rights of the interested party (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, through the cookie banner or by following the instructions below and in the Cookie Policy.

c. Profiling and marketing cookies (which require your CONSENT):

This site also uses profiling and third-party cookies, whose installation is subject to your prior consent issued through the banner or also managed at any time through the Cookie Policy
Profiling cookies can include different categories, including advertising profiling, retargeting or Social cookies. 

  • Advertising profiling cookies: create a user profile that allows you to view advertising content in line with the preferences shown while browsing the site;

  • Retargeting cookies: they are created in order to send you advertising content relating to the products you have purchased or viewed on the site and in which you have expressed interest;

  • Social cookies: this site provides for the installation of cookies relating to social network plug-ins. These cookies are managed directly by third parties and allow the display of advertising messages in line with your preferences.

When you access the Site, through a special banner you will be informed of the presence of profiling and retargeting cookies and, through it, you can consent or not to their installation, possibly selecting the individual cookies you want to install.
At any time you can still revoke the consent previously given, without compromising the possibility of visiting the site and using its contents.
The installation of profiling, retargeting, analytical and social cookies, including any other activity connected to them, is managed through third-party services. For more information and to enable or disable these cookies, you can access the information provided directly by third-party companies: the relevant list is available to you in our Cookie Policy.
The user is informed both through the brief information (banner displayed until consent is given or denied) and through our Cookie Policy that we invite you to read carefully for all the other information on the cookies used on the site and for information on their disabling.

  • Purpose pursued: analyze the user's browsing behavior to present personalized advertising;

  • Legal basis of the processing: the user's consent (Article 6, paragraph 1, letter a, GDPR), freely provided and revocable at any time, through the cookie banner or by following the instructions below and in the Cookie Policy.

d. Social media plugin

SOn the Site there are some buttons that refer the user to the Controller's profiles on social networks. Only after clicking on these buttons, some cookies could be activated for marketing and profiling purposes by the third parties that manage the social networks. The Owner of the Site does not manage these tools directly, but informs you of the possibility that, by making use of the Site's features, they may be activated. For more information, including how to disable these cookies, please read the information on the processing of personal data on social networks:

Disabling via browser

We point out that from the site http://www.youronlinechoices.com/it/ it is possible not only to acquire further information about cookies, but also to verify the installation of numerous cookies on your browser / device and, where supported, also to disable them.
Commonly used browsers (e.g. Internet Explorer, Firefox, Chrome, Safari) also 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 function.
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 have 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, can affect the full and / or correct functioning of various sites, including this site.
As a rule, the browsers used today:

  • offer the “Do not track” option, which is supported by some (but not all) websites. In this way, some websites may no longer collect certain navigation data;

  • offer the option of anonymous or incognito browsing: in this way no data will be collected in the browser and the browsing history will not be saved, but the browsing data will still be acquired by the operator of the website visited;

  • allow you to delete the cookies stored in whole or in part, but when you visit a website again they are usually installed where this possibility is not blocked.

The links to the support pages of the most popular browsers are indicated (with instructions on disabling cookies on these browsers):

4. For what other purposes can you use my data?
Finally, your personal data may also be used in order to:
a) comply with legal obligations and requests from public or government authorities;
b) manage any disputes or disputes and therefore defend the rights of 3Labs Srl, both in court and out of court.

In such cases, the legal bases of the processing will be:
- for point a), the fulfillment of a legal obligation;
- for point b), the legitimate interest of the Data Controller in the protection of their rights, provided that they are adequately balanced, from time to time, with the rights of the interested party.

5. Who will you share my data with?
In compliance with the purposes indicated in the previous section, the staff of 3Labs Srl may be responsible for 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 this regard, we specify that:

  • The newsletter service is provided through the “Elastic Mail” platform made available and managed by the company Elastic Mail Inc., based in British Columbia at PO Box 9038 Stn. Prov. Govt., Victoria, BC V8W 9A4 (privacy policy: https://elasticemail.com/resources/usage-policies/privacy-policy) ..

We also remind you that the list of data processors is available from the Data Controller, from which you can request it using the contact details indicated above.
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 envisaged with the collection.
3Labs Srl will take the necessary technical and organizational measures to prevent the loss, illicit or incorrect use of data, as well as to prevent any form of unauthorized access by third parties.
Therefore, 3Labs Srl will guarantee the security of your personal data, limiting the number of subjects who will be allowed access to the servers or databases and setting up protection systems aimed at averting the risk of cyber attacks.

7. Are my data processed outside Europe?
The data processed by 3Labs Srl reside on servers located within the European Union.
However, some service providers are based in non-European countries, particularly in the United States, as also specifically indicated in our Cookie Policy and in the previous paragraph 5 1. (With whom will you share my data?).
In these cases, personal data may also reside on servers located in the United States, but always in compliance with the provisions of articles 45 and following of the GDPR. All the necessary precautions will therefore be taken in order to guarantee the most complete protection of personal data, basing this transfer: a) on adequacy decisions of the recipient third countries 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 binding corporate rules, cd. Corporate binding rules.

8. How long will you keep my data?
3Labs Srl will process your personal data for the time reasonably necessary to achieve only the purposes listed above, which can be consulted in the section "What data will you process?" 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. Furthermore:
- the data relating to your Curriculum vitae and your application request will be kept for two years;
- the data used to send the newsletter will be kept until your request for cancellation;
- the data used for softspam communications will be kept until your request for cancellation or for two years from the last time you expressed interest in 3Labs Srl (for example, by contacting us via the Site);
- for the terms of cancellation of data processed by cookies you can find the information in ours Cookie Policy.
At the end of the retention period, your personal data will be deleted or made irreversibly anonymous.

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 with respect to the Website.

10. What are my rights and how can I protect my privacy?
In relation to your personal data and in compliance with the provisions of the GDPR, 3Labs Srl 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 conditions; 

  • the limitation of the processing of your data; 

  • opposition to data processing;

  • data portability. 

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

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

YOUR RIGHT

HOW CAN YOU EXERCISE IT?

Access

You can ask to:

  • Ask for confirmation on any processing concerning your personal data;

  • Get one copy of your data;

  • Provide you with other information about your personal data that are not already present in this statement.

Grinding

You can ask for the rectification of inaccurate or incomplete personal data.

Before proceeding with the rectification, we will verify the accuracy of the data in our archives.

Cancellation/

Right to be forgotten

You can request the deletion of your personal data, but only if:

  • Their stay is no longer needed in relation to the purposes for which they were collected; 

  • You have denied your consent previously loaned (where the processing is based on consent);

  • The processing has been carried out in such a way illegitimate;

  • It is necessary to comply with a legal obligation to which 3Labs Srl is subject (in relation to an order from an Authority).

Limitation

You can ask to limit your personal data, but only if:

  • Their accuracy has already been contested;

  • They are no longer necessary for the purposes for which they were collected, but there is a legal dispute regarding their use;

Following your request for limitation, the use of your personal data it is however allowed when: 

  • However, your consent remains;

  • It is necessary to exercise or resist legal action;

  • To protect the rights of another natural or legal person involved in the processing.

Portability

You can request a copy of your personal data in a structured, readable and commonly used format. 

Opposition

You can oppose the processing of your personal data at any time that concern you when:

  • the basis of lawfulness of the processing is legitimate interest of the owner;

  • the personal data are processed for direct marketing purposes including profiling to the extent that it is connected to such direct marketing.

When you object:

  • to the processing of personal data for direct marketing purposes they will no longer be processed for these purposes;

  • in case of legitimate interest of the owner, the processing may continue only if he can demonstrate the existence of compelling legitimate reasons for proceeding to the treatment that prevail over the interests, rights and freedoms of the interested party or for the assessment, exercise or defense of a right in court.

It is also possible to exercise the right to object by automated means that use technical specifications, such as those made available on the site in the personal page and in the e-mails (link for cancellation).

3Labs Srl guarantees that any request regarding your rights will be acknowledged within thirty days of its receipt.

11 Can I file a complaint?

You have the right to lodge a complaint with the Guarantor Authority for the protection of personal data, if you believe that the processing carried out by 3Labs Srl does not comply with the provisions of the European Regulation no. 679/2016 and national legislation. 
In Italy, the competent authority is the Guarantor for the protection of personal data, whose contact details are available at the address http://www.garanteprivacy.it/. 
More information and the sample document to use for the complaint can be found here: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524 Furthermore, if the conditions envisaged by art. 78 and 79 of the GDPR, you have the right to lodge an appeal before the competent judicial authority.

12 Any changes

The information we are providing you now can be modified over time, when the processing activities, the data collected or when legislative or regulatory changes occur, or in the event of technological evolutions. We therefore recommend that you periodically consult this Privacy and cookie policy, which is always updated on this page.