Privacy Policy – ThePlatform

Privacy Policy

Processing of personal data of website and app users.

When you use our services, you agree that our company collects certain personal data about you. This page is intended to explain who we are, what data we collect, how we handle it, to whom it may be disclosed, where it may be transferred and what your rights are. The following information is provided pursuant to Article 13 of EU Regulation 679/2016 “European Regulation on the Protection of Personal Data – GDPR” to all users interacting with the web services accessible by telematic means, starting from the address of the official Virgilius Wealth website vplatform.simonebaldini.dev and from the apps concerning all the entities of the Company. The information is provided exclusively for the website and the apps in question and not for other websites that may be consulted by the user through links.
Virgilius Wealth is committed to the protection of the Personal Data entrusted to it. Therefore, their management and security are guaranteed with the utmost care, in accordance with the requirements of the privacy legislation (EU Regulation 2016/679).

Data controller

Your data will be processed, as Data Controller, by Virgilius Wealth S.r.l. – Via Emanuele Filiberto di Savoia, 47 – 35122 Padova – Tel.+39 049 7351189 – Email: direzione@virgiliuswealth.com. Virgilius Wealth has also appointed its own Data Protection Officer, who can be contacted at the Data Controller’s address or through the “Contacts” section on the website vplatform.simonebaldini.dev or by sending an email to direzione@virgiliuswealth.com.

Place of data processing

The processing operations connected to the web services of this website and of the Virgilius Wealth apps take place at the Virgilius Wealth premises and are carried out only by authorised technical personnel of the competent office, in charge of the processing, or by the software provider – appointed as external data processor for the maintenance and technical management of the website. No data deriving from the web service is communicated or disseminated.
The personal data provided by users who request dispatch of informative material are used for the sole purpose of performing the service or provision requested and are communicated to third parties only if necessary for that purpose and in any case always and only for the purpose of performing institutional activities.

Types of data processed

Navigation data

Computer systems and software procedures used to operate this website and Virgilius Wealth apps acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the files obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment.
This data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and the apps and to check their correct functioning. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the site: the data is deleted after 12 months.

Data provided voluntarily by the user

The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this website and in the Virgilius Wealth apps entails the subsequent acquisition of the sender’s address, which is necessary to reply to requests, as well as any other personal data included in the message. Specific summary information will be progressively reported or displayed on the pages of the website
prepared for particular services on request.

Candidate CV data processing

With regard to the processing of data contained in the CVs of candidates to work in Virgilius Wealth, please refer to the specific privacy policy.

 

Storage time of processed data
 
The data acquired while browsing the site and apps will be retained for 12 months, while the data provided by the user in connection with the sending of e-mail communications will be deleted immediately after the cessation of the voluntarily requested activities, unless explicitly requested by the data subject.

 

Cookies

 
No personal user data is acquired by the site in this regard.
No persistent cookies of any kind or user tracking systems are used. The use of so-called session cookies (which are not stored persistently on the user’s computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable the safe and efficient exploration of the site.
The so-called session cookies used in this site avoid the use of other IT techniques potentially prejudicial to the confidentiality of users’ browsing and do not allow the acquisition of personal data identifying the user.
 
Optional supply of data
 
Apart from what has been specified for navigation data, the user is free to provide the personal data indicated in the request forms to the Company or in any case indicated in contacts with the Office to request the sending of informative material or other communications. Failure to provide such data may make it impossible to obtain what has been requested.
 
Processing methods
 
Personal data are processed by automated tools for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorised access.
 
Rights of the data subjects
 
The parties to whom the personal data refer have the right at any time to obtain confirmation of the existence or otherwise of such data and to be informed of their content and origin, check their accuracy or request that they be supplemented or updated, or corrected (Art. 7 of Legislative Decree no. 196/2003). Pursuant to the same article, data subjects have the right to request the deletion, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, their processing.
 
Requests should be addressed to Virgilius Wealth S.r.l. – Via Emanuele Filiberto di Savoia, 47 – 35122 Padova – Tel.+39 049 7351189 – Email: direzione@virgiliuswealth.com.

This privacy policy applies between you, the User of this Website, and THEPLATFORM LTD, the owner and provider of this Website. THEPLATFORM LTD takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy policy carefully.

 

Definitions and interpretation
1. In this privacy policy, the following definitions are used:

 

Data
collectively all information that you submit to THEPLATFORM LTD via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

 

Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;

 

GDPR
the UK General Data Protection Regulation;
THEPLATFORM LTD, we or us
THEPLATFORM LTD, a company incorporated in England and Wales with registered number 14501530 whose registered office is at 37-38 Long Acre, United Kingdom, WC2E 9JT;

 

User or you
any third party that accesses the Website and is not either (i) employed by THEPLATFORM LTD and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to THEPLATFORM LTD and accessing the Website in connection with the provision of such services; and

 

Website
the website that you are currently using, www.theplatform.finance, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
2. In this privacy policy, unless the context requires a different interpretation:
a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. “including” is understood to mean “including without limitation”;
e. reference to any statutory provision includes any modification or amendment of it;
f. the headings and sub-headings do not form part of this privacy policy.

 

Scope of this privacy policy
3. This privacy policy applies only to the actions of THEPLATFORM LTD and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
4. For purposes of the applicable Data Protection Laws, THEPLATFORM LTD is the “data controller”. This means that THEPLATFORM LTD determines the purposes for which, and the manner in which, your Data is processed.

 

Data collected
5. We may collect the following Data, which includes personal Data, from you:
a. name;
in each case, in accordance with this privacy policy.

 

How we collect Data
6. We collect Data in the following ways:
a. data is given to us by you; and
b. data is collected automatically.

 

Data that is given to us by you
7. THEPLATFORM LTD will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
b. When the user fills out the contact form;
in each case, in accordance with this privacy policy.

 

Data that is collected automatically
8. To the extent that you access the Website, we will collect your Data automatically, for example:
a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

 

Our use of Data
9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. internal record keeping;
b. transmission by email of marketing materials that may be of interest to you;
c. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
in each case, in accordance with this privacy policy.
10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
11. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
a. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
c. if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
12. We may use your Data to show you THEPLATFORM LTD adverts and other content on other websites. If you do not want us to use your data to show you THEPLATFORM LTD adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed “Cookies” below).

 

Keeping Data secure
13. We will use technical and organisational measures to safeguard your Data, for example:
a. access to your account is controlled by a password and a user name that is unique to you.
b. we store your Data on secure servers.
14. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address:  management@theplatform.finance.
15. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

 

Data retention
16. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
17. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

 

Your rights
18. You have the following rights in relation to your Data:
a. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase – the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
e. Right to data portability – the right to request that we move, copy or transfer your Data.
f. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
19. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address:  management@theplatform.finance.
20. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
21. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

 

Links to other websites
22. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

 

Changes of business ownership and control
23. THEPLATFORM LTD may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of THEPLATFORM LTD. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
24. We may also disclose Data to a prospective purchaser of our business or any part of it.
25. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

 

General
26. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
27. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
28. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
29. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

 

Changes to this privacy policy
30. THEPLATFORM LTD reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations

 

You may contact THEPLATFORM LTD by email at  management@theplatform.finance.
 
Attribution
31. This privacy policy was created using a document from Rocket Lawyer (https://www.rocketlawyer.com/gb/en).