Privacy Policy

This Website collects some Personal Data of its Users.

This document can be printed out using the print command in the settings of any browser.

Data Controller

Modefinance S.r.l.
Edificio H AREA Science Park
Padriciano, 99(34149) Trieste

email: info@modefinance.com

Types of data collected

Among the Personal Data collected by this Website, either independently or through third parties, are: Tracking Tools; Usage Data; number of Users; session statistics; clicks; interests; education; phone number; email; country; pageviews; geographic location; physical address; company name; date of birth; device information; IP address; job position; profession; work history; professional skills; industry; academic background; geographic region; company size; company revenue; gender; first name; last name; unique device identifiers for advertising purposes (such as Google Advertiser ID or IDFA); city; business sector.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific informational texts displayed prior to the collection of such Data.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website.

Unless otherwise specified, all Data requested by this Website is mandatory. If the User refuses to provide it, this Website may be unable to provide the Service. In cases where this Website specifically states that certain Data is optional, Users are free to withhold such Data without affecting the availability or functionality of the Service.

Users who are uncertain about which Personal Data is mandatory are encouraged to contact the Owner.

The use of Cookies—or other tracking tools—by this Website or by the owners of third-party services used by this Website is intended to provide the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Website.

Methods and place of processing of the collected data

Methods of processing

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data. Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the operation of this Website (administrative, commercial, marketing, legal staff, system administrators) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) may also have access to the Data, if necessary, appointed as Data Processors by the Data Controller. An updated list of Data Processors can always be requested from the Data Controller.

Place

The Data is processed at the Data Controller’s operational offices and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller. The User’s Personal Data may be transferred to a country other than the one in which the User is located. For more information on the location of the processing, the User may refer to the section detailing the processing of Personal Data.

Retention period

Unless otherwise stated in this document (e.g., business information data), Personal Data is processed and stored for as long as required by the purpose for which it was collected and may be retained for a longer period due to legal obligations or based on the User's consent.

Purpose of the collected data processing

User Data is collected to allow the Data Controller to provide the Service, fulfill contractual obligations, manage the technical delivery of the Service, handle mandatory, contractual, and fiscal/accounting relationships, for archiving and backup of your report requests (including for the purpose of verifying the correct fulfillment of contractual obligations), for sending reports or updates related to purchased reports, to enable S-peek Team functionalities and the related sharing of information within the TEAM.

Data will also be processed for legal purposes, to respond to requests or enforcement actions, to protect its own rights and interests (or those of Users or third parties), to detect any malicious or fraudulent activity, and for the following purposes: Traffic optimization and distribution, Tag management, Displaying content from external platforms, Heat mapping and session recording, Statistics, Remarketing and behavioral targeting, Advertising, Contact management and message sending, and Contacting the User.

Any business information services

If the Service requested by the Client through the S-peek platform constitutes "business information", Modefinance will collect the Client’s personal data and identification document to comply with the tracking and identification obligations provided by Royal Decree No. 773/1931, and subsequent amendments and additions, containing the Consolidated Law on Public Security (TULPS) and its implementing regulations and by Ministerial Decree No. 269/2010. Providing the data required for the Service is optional, but failure to provide certain information will make it impossible to deliver the requested output or to correctly deliver the Service. The legal basis for processing is Art. 4, paragraph 1, letters B and C of Regulation 679/16 (data processed in the execution of a contract and data processed due to legal obligation).

As part of Modefinance’s activities involving the investigation and processing of business information, data concerning the profiled subjects (the Client or third parties indicated by the Client) will be processed in accordance with the guidelines of the “Code of Conduct for the processing of personal data in business information” approved by the Italian Data Protection Authority under Art. 40 of Regulation 679/16 with resolution dated June 12, 2019. In particular, the information will be processed using statistical processes or automated models, or through analyses and evaluations carried out by experts, also based on predefined classifications, in order to issue an assessment of the subject's soundness, solvency, and reliability, which may be expressed in predictive, probabilistic terms, or in the form of alphanumeric indicators, codes, or symbols, as required under the TULPS. The data collected refers to the company under evaluation (e.g., data from public registers, publicly accessible sources, financial statements, Central Credit Register reports, data submitted by the Client, etc.) and to individuals holding positions within it. All data processed for business information purposes is handled by Modefinance on the basis of the legitimate interest of the Controller pursuant to Art. 6, paragraph 1, letter f) of the GDPR. It is specified that when the Client transmits to Modefinance personal data and corporate information relating to the profiled subject (e.g., data relating to financing requests, technical forms, purposes, Central Credit Register data, unpublished or interim financial statements, data regarding mutual business relationships, labor, tax, etc.), the same Client declares that they have provided the profiled subject with adequate information, which includes the possibility of disclosing such data to business information companies for the purpose of verifying reliability or solvency, obtaining the consent of the data subjects or declaring a legitimate interest in such data transmission. The full privacy notice for the processing of personal data carried out for business information purposes is the one prepared by the companies adhering to the Code of Conduct for the processing of personal data in business information (Resolution of June 12, 2019), available on the ANCIC website.

In addition to what is described therein, the data transmitted and the related reports processed by Modefinance on behalf of the Client will be stored for archiving and backup purposes and to demonstrate proper fulfillment in the event of Service disputes, until the expiration of the statute of limitations for contractual rights. Financial, commercial, or balance sheet data referring to legal entities will be anonymized and used for statistical analysis and interconnection purposes and to enhance and improve the Service.

To obtain detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section “Details on the processing of Personal Data".

Details on the processing of personal data

Personal Data is collected for the following purposes and using the following services:

for the provision of the Service and technical management, management of mandatory, contractual, and accounting/tax relations, for archiving and backup purposes of the report requests made by you (also to possibly verify the correct fulfillment of contractual obligations)
sending reports or updates related to purchased reports
enabling the functionalities of S-peek Team and the related sharing of information within the TEAM
contacting the User and managing contacts and sending messages
tag management
heat mapping and session recording
pptimization and distribution of traffic
advertising
remarketing and behavioral targeting
statistics
displaying content from external platforms.

Information on how to opt out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users can read more about how to opt out of interest-based advertising in the relevant section of the Cookie Policy.

Cookie Policy

This Website uses Tracking Tools. To learn more, Users may consult the Cookie Policy.

Additional information for users

Legal basis for processing

The Data Controller processes Personal Data relating to the User if one of the following conditions applies:

the User has given consent for one or more specific purposes;
processing is necessary for the performance of a contract with the User and/or for any pre-contractual obligations;
processing is necessary to comply with a legal obligation to which the Controller is subject;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party.

In any case, it is always possible to request the Data Controller to clarify the specific legal basis that applies to each processing, and in particular, whether the processing is based on law, required by a contract, or necessary to enter into a contract.

Further information on data retention period

Unless otherwise stated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be retained for a longer period due to legal obligations or with the User's consent. Therefore:

Personal Data collected for purposes related to the performance of a contract between the Controller and the User will be retained until the execution of that contract is completed.
Personal Data collected for purposes related to the legitimate interest of the Controller will be retained until such interest is satisfied. Users may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When processing is based on the User’s consent, the Controller may retain the Personal Data for a longer period until such consent is withdrawn. Additionally, the Controller may be obliged to retain the Personal Data for a longer period to comply with a legal obligation or by order of an authority. At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiration of this period, the rights of access, erasure, rectification, and data portability can no longer be exercised.

User rights under the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Controller. In particular, to the extent permitted by law, Users have the right to:

withdraw consent at any time. Users can withdraw previously given consent to the processing of their Personal Data.
Object to processing of their Data. Users can object to the processing of their Data if it is carried out on a legal basis other than consent.
Access their Data. Users have the right to obtain information about the Data being processed by the Controller and to receive a copy of such Data.
Verify and request rectification. Users can verify the accuracy of their Data and request it be updated or corrected.
Obtain restriction of processing. Users can request the restriction of the processing of their Data. In this case, the Controller will not process the Data for any purpose other than storage.
Obtain the erasure or removal of their Personal Data. Users can request the deletion of their Data by the Controller.
Receive their Data or have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without hindrance.
Lodge a complaint. Users can lodge a complaint with the competent data protection authority or take legal action.

Users have the right to receive information regarding the legal basis for Data transfers to countries outside the EU or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Controller to safeguard their Data.

Details about the right to object

Where Personal Data is processed in the public interest, in the exercise of official authority vested in the Controller, or for the purposes of the legitimate interests pursued by the Controller, Users may object to such processing for reasons related to their particular situation. Users are reminded that if their Personal Data is processed for direct marketing purposes, they may object to that processing at any time free of charge and without providing any justification. If Users object to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To find out whether the Controller is processing Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Controller through the contact details provided in this document. Such requests are free of charge and will be handled by the Controller as soon as possible and always within one month. Any rectification, erasure, or restriction of processing will be communicated by the Controller to each recipient, if any, to whom the Personal Data has been disclosed, unless this proves impossible or involves a disproportionate effort. The Controller will inform the User about such recipients if requested.

Additional information about data processing

Legal Defense

The User's Personal Data may be used by the Controller in legal proceedings or in the preparatory stages of such proceedings to defend against misuse of this Website or related Services. The User declares to be aware that the Controller may be required to disclose the Data by order of public authorities.

Specific information

Upon User request, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning specific Services or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect system logs, i.e., files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Further information concerning the processing of Personal Data may be requested from the Controller at any time using the contact details provided.

Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, where technically and legally feasible, by sending a notice to Users via any contact information available. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing based on the User’s consent, the Controller shall collect new consent from the User, where required.