Data Protection Notice

1. Introduction and identification of the Data Controller

This Data Protection Notice outlines the data protection practices and procedures of Pomilio Blumm s.r.l. (referred to as “Pomilio”) in compliance with the General Data Protection Regulation (GDPR). Pomilio acts as the data controller for the personal data collected and processed as described in this policy.

Enquiries concerning the processing of personal data through this platform can be sent to the following contact details: Pomilio Blumm S.r.l. – via Venezia 12, 65121 Pescara – PEC: gdpr@pec.pomilioblumm.it

2. Categories of Data Processed

Pomilio processes the following categories of personal data:

– Name

– Surname

– Email address

– Partner Agency

3. Purposes of Processing

The processing of personal data is carried out by Pomilio for the following purposes:

– Facilitating the exchange of information and opportunities among members of the network

– Ensuring compliance with legal and contractual obligations

– Enabling the exercise of rights related to personal data

4. Legal Basis for Processing

Pomilio relies on the consent of the user as the legal basis for processing personal data. By providing their personal data and agreeing to this Data Protection Policy, users explicitly consent to the processing of their data for the purposes outlined above.

5. Data Hosting and Storage

Pomilio ensures that all personal data collected and processed through the platform is stored in an EU-located data center managed by an EU company (namely, OVH). This arrangement is chosen to maintain compliance with GDPR regulations and provide adequate protection for the personal data.

6. Data Sharing, Disclosure and Access from non-EU countries

Personal data collected by Pomilio will not be shared or disclosed to any third parties, except in the following circumstances:

– When required by law or under a legal authority, Pomilio may disclose personal data to public authorities or government agencies.

– Personal data may be disclosed to third parties if necessary to fulfill legal or contractual obligations, subject to appropriate safeguards and data protection agreements.

As the platform facilitates communication and collaboration among partners from various countries, it is possible for the platform’s content to be accessed from outside the European Union (EU) and through partners’ internet connections. This scenario may result in the transfer of personal data to countries that do not have an equivalent level of legal protection for personal data as provided within the EU.

7. Data Retention

Pomilio will retain personal data only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this policy. Once the purpose of processing is fulfilled or when the user withdraws their consent, the personal data will be securely deleted or anonymized, unless retention is required by applicable laws or regulations.

8. Data Subject Rights and their exercise, complaint

Pomilio acknowledges and respects the rights of data subjects as defined under the GDPR. Users have the right to access, rectify, restrict, and delete their personal data, as well as the right to object to the processing and the right to data portability. To exercise these rights, users can contact Pomilio’s designated representative at PEC: gdpr@pec.pomilioblumm.it.

If a data-subject believes that his rights under the GDPR have been violated or if he has any concerns regarding the processing of his personal data by the Company, he has the right to file a complaint with the Italian Data Protection Authority (www.garanteprivacy.it). Alternatively, it is possible to seek a remedy through the competent court.

9. Data Security and risks for the data-subjects

Pomilio takes the necessary technical and organizational measures to ensure the security and confidentiality of personal data. These measures may include encryption, access controls, regular data backups, and employee training on data protection best practices.

The platform does not utilize any trackers or logging sessions at the server level. This means that no information regarding users’ browsing behavior or activities within the platform is tracked or recorded by Pomilio’s servers.

The platform provided by Pomilio is specifically designed as a business-to-business (B2B) communication tool, facilitating the exchange of information and opportunities related to business activities among its participants. As such, the nature of the shared data is primarily focused on professional and business-related information. Considering this context, the risk of a personal data breach significantly impacting the freedom and fundamental rights of the participants is very low.

10. Data Protection Notice Acknowledgment

By using or accessing this platform, you acknowledge that you have read and understood this Data Protection Notice.

You also acknowledge that, you are aware that due to the nature of the platform and the possibility of accessing its content from outside the European Union (EU) and through partners’ internet connections, there is a potential for the transfer of personal data to countries with a lesser level of legal protection.

11. Explicit Consent Gathering, consequences of the refusal to provide consent

You hereby agree to the processing of your personal data in accordance with the purposes stated in this Data Protection Notice, the legal basis of consent, and the measures taken by Pomilio to protect your data.

By logging in, you explicitly consent to the processing of your data as described in this notice.

If you do not agree with any aspect of this Data Protection Notice or the processing of your personal data, please refrain from using this platform.

I hereby declare that

• I have carefully read and understood the Data Protection Notice provided by Pomilio.
• I give my explicit consent to the processing of my personal data in accordance with the terms and conditions specified in the Data Protection Notice.

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Privacy Policy

Pomilio’s Platform Acceptable Use Policy

This Acceptable Use Policy (the “Policy”) outlines the responsibilities and guidelines for users of Pomilio’s Platform (referred to as “you” or “users”) regarding the content you publish or share. By using Pomilio’s platform, you agree to comply with this Policy and understand that you bear all legal responsibility for the content you publish.

1. Legal Authority:

1.1. You agree to publish or share only those contents for which you have the legal authority to do so. This includes, but is not limited to, content that you own the intellectual property rights to, or for which you have obtained the necessary licenses, permissions, or consents from the relevant parties.

1.2. You acknowledge and agree that you are solely responsible for verifying and ensuring that you have the legal authority to publish or share any content on our platform or services.

2. Prohibited Content:

2.1. You must not publish or share any content that

• infringes upon or violates any third party’s intellectual property rights, including but not limited to copyright, trademark, patent, or trade secret rights.
• contains confidential, sensitive, or personally identifiable information without the explicit consent of the individuals concerned.
• is defamatory, libelous, misleading, fraudulent, or violates any applicable laws, regulations, or third-party rights.
• that promotes or incites violence, hatred, discrimination, harassment, or any form of illegal or unethical behavior.
• contains viruses, malware, or any other malicious code that may harm, disrupt, or interfere with our platform, services, or other users’ devices or data.

3. Content Responsibility:

3.1. You understand and accept that you bear all legal responsibility for the content you publish or share, and you will be held liable for any consequences arising from such content.

3.2. You agree to indemnify and hold us harmless from any claims, demands, losses, liabilities, costs, or expenses (including legal fees) arising out of or in connection with the content you publish or share, including any claims by third parties alleging infringement of their rights.

3.3. You are solely responsible for ensuring that the content you publish or share complies with all applicable laws, regulations, and intellectual property rights.

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