Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data

SylloTips (nel seguito anche "Titolare" e/o “Responsabile”), (P.IVA  17232791008), con sede legale in Piazza Crati, 20, 00199 Roma, in qualità di titolare del trattamento e/o Responsabile del trattamento vi informa, ai sensi degli artt. 13 e 14 del Regolamento Europeo 679/2016 relativo alla protezione dei dati personali ("GDPR") di quanto segue.

Ove non specificamente definiti nel presente Accordo, i termini indicati nel prosieguo con lettera maiuscola devono intendersi con il significato ad essi attribuito nelle Condizioni Generali.
1. Stakeholders
a) Customer Data: personal data that we collect, process and manage on behalf of our business customers ("Customers"). They are processed by SylloTips through its Services, including the Platform, products, applications, application programming interface ("API"), tools and any ancillary or supplementary products and services of SylloTips including upgrades (as defined in the Terms of Use and General Terms and Conditions), offered online and via a mobile application (collectively, "Platform"). We process Customer Data on behalf of and at the instruction of the Customer as a "data controller" in accordance with the Agreement for the Processing of Personal Data ("ATDP").  Accordingly, this Privacy Policy - which describes SylloTips' data processing practices as a "data controller" - with respect to the Platform, Sites (as defined below), Mobile Apps and any other services provided to the SylloTips Customer ("Services"), and does not apply to the processing of Customer Data.

b) User Data: personal data relating to Customer's internal personnel who interact directly with SylloTips in using the Software and Mobile Apps and in relation to their account (e.g. billing contacts and authorised signatories), customer account administrators and authorised users of the platform (collectively, "Users");

c) Visitor Data: data relating to visitors to our websites to event participants and any other potential customers, users or partners (collectively, "Visitors") who visit or otherwise interact with our programmes, marketing and social activities and with our websites, advertisements and digital content, e-mails, integrations or communications under our control ("Sites").
1. Type of data processed
When we use the term "personal information" in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably associated with, or could reasonably be linked directly or indirectly to an individual. It does not include aggregated or anonymised information maintained in a form that is not reasonably capable of being associated or linked to an individual.

We collect or generate the following categories of personal data in connection with the Services:
a) Usage and device information of our Users and Visitors - Connectivity, technical and usage data, such as IP addresses and approximate general locations derived from such IP addresses, device and application data (such as type, operating system, mobile device id or app id, browser version, location and language settings used), activity logs, relevant cookies and pixels installed or used on your device, and recorded activity (sessions, clicks, feature usage, recorded activity and other interactions) of Visitors and Users in connection with our Services. We collect and generate this information automatically, including through the use of analytics tools (including cookies and pixels) - which collect data such as: how often Visitors visit or use the Sites, what pages they visit and when, what website, ad or email message took them there, and how Users interact with and use the Platform and its various features.

b) Metadata of Services - When an Authorized User interacts with the Services, metadata is generated providing additional context about how an Authorized User uses the Services. For example, SylloTips records the workspaces, channels, people, functions, content, and links the user views or interacts with, as well as the types of files shared and any third-party Services used.

c) Contact and Profile Information of Our Clients, Users, and Visitors - Name, email, phone number, location, workplace, profile picture, login credentials, contractual and billing details, and any other information provided by the Client.We collect this information directly from you or from other sources and third parties, such as our Client (your employer), Users, event organizers, or promotions in which both you and we participated, and through commonly used tools and channels for connecting businesses and professionals to explore potential business and job opportunities.

d) Communications with Our Clients, Users, Potential Customers, and Technology Partners - Personal data contained in all forms and requests you may send us, including assistance requests, interactions through social media channels and instant messaging apps, event registrations we host, organize, or sponsor, and participation in online and offline activities.Surveys, feedback, and testimonials received; expressed needs and preferences.In no case does SylloTips process User data and the data that Users enter into the Platform and in relation to the Sybil Chatbot except in the ways and for the purposes determined by the Client as the Data Controller and/or to eliminate bugs and service disruptions.

2. Purpose and Legal Basis of Processing
Data processing is carried out by SylloTips in the performance of its economic and commercial activities for purposes related to the establishment, management, and execution of commercial relationships, including the management of the pre-contractual relationship. In particular, the data provided by the data subjects will be processed, mainly by electronic means, for the following purposes:
a) The performance of obligations strictly connected to the management of the Contract, including administrative and accounting management of contracts, payment and invoice management, service provision, and customer support services management. Providing data for these activities is essential for the proper management of the Contract and does not require the consent of the data subject (Art. 6(1)(b) of the GDPR).
b) The performance of activities instrumental to the management of the Contract, including activity planning, protection, and management of any litigation and debt recovery, for which providing data, where necessary, is optional and the processing is based on SylloTips' legitimate interest.
c) Compliance with obligations arising from the law, regulations, or EU legislation (e.g., tax and accounting obligations), for which the provision of data is mandatory and the processing does not require the data subject's consent (Art. 6(1)(c) of the GDPR).

3. Processing Methods
Data will be processed by SylloTips using electronic and manual systems according to the principles of fairness, loyalty, and transparency provided by the applicable data protection legislation and protecting the data subject's confidentiality through technical and organizational security measures to ensure an adequate level of security.

4. Data Retention
SylloTips will retain the Client's data in accordance with the Client's instructions (e.g., to fulfill the terms applicable in the Contract with the Client and through the use of the Services' functionality by the Client) and as required by applicable law. The Client can customize its retention settings. Deletion of the Client's data and other uses of the Services by the Client may result in the deletion and/or anonymization of certain other associated information. SylloTips may retain other information relating to the User for the time necessary for the purposes described in this Privacy Policy (such as to provide the Services, including any optional features used, and to provide customer support). This may include retaining other information after deactivating the user's account for the time necessary for SylloTips to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce agreements.

5. Data Communication, Disclosure, and Transfer
This section describes how SylloTips may share and disclose information collected and received on the Platform. Clients determine their criteria and procedures for sharing and disclosing information to third parties. SylloTips does not control how a Client or any third party chooses to share or disclose information.
Client Instructions. SylloTips may share Information in accordance with the Client's instructions and with their consent, including the terms applicable in the Contract with the Client and through the use of the Services' functionality by the Client, and in accordance with applicable law and legal proceedings. Some sharing at the Client's request may incur additional costs.
Service Visualization. When an Authorized User submits information, it may be viewed or detected by other Authorized Users in the same workspaces or other connected workspaces or on specific discussions.
Collaboration with Others. The Services allow Authorized Users operating in independent workspaces to collaborate in various ways. Information, such as an Authorized User's profile and organization information, may be shared based on the criteria and procedures of the used workspaces. For example, depending on the workspace settings, to enable connections with other Authorized Users, the user profile may be shared, searchable, or detectable by Authorized Users or other users outside the belonging workspace.
Customer Access. Owners, administrators, Authorized Users, and other representatives and staff members of the Client may be able to access or restrict access to Information and modify it. This may include, for example, the employer using the Services' features to access or modify profile details or to export workspace activity logs.
Third-Party Partners and Service Providers. SylloTips may use third-party companies or individuals as service providers or business partners to process Information and support its business. These third parties may provide, for example, virtual processing and storage services, assist SylloTips in verifying owners and customers, or SylloTips may share business information to develop strategic collaborations with third-party service providers to support common customers. In this regard, based on the third-party service provided, SylloTips may share user information.
Third-Party Services. A Client may enable or allow Authorized Users to enable third-party Services. SylloTips asks each third-party service provider to disclose all permissions for information accessible through the Services but does not guarantee they will do so. When third-party Services are enabled by a Client or an Authorized User, SylloTips may share Information with the third-party Services. Third-party Services are not owned or controlled by SylloTips, and the third parties granted access to the Information may have different criteria and procedures for data collection, use, and sharing. Check permissions, privacy settings, and communications for third-party Services or contact the provider for any questions.
Discussions. Information that the User chooses to provide to the community in a specific Discussion, including personal data, will be publicly available.
Professional Advisors. SylloTips may share user information with professional advisors acting as service providers, data controllers, processors, or joint controllers, including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services, and to the extent that SylloTips has a legal obligation or legitimate interest to share information containing personal data.
During a Change in SylloTips' Business. If SylloTips is involved in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of its assets or shares, financing, public offering of securities, acquisition of all or part of the business, transaction, or similar proceeding or steps in contemplation of such activities, some or all of the Information described in the "Information Collected and Received by SylloTips" section may be shared or transferred, subject to standard confidentiality provisions.
Aggregated or Anonymized Data. SylloTips may disclose or use aggregated or anonymized Information for any purpose. For example, it may share aggregated or anonymized Information with potential customers or partners for business or research purposes.
Law Enforcement and Regulatory Bodies. If SylloTips receives a request for information, it may disclose Other Information if it reasonably believes that disclosure is compliant with the law or required under a law, regulation, or legal process.
To Enforce Our Rights, Prevent Fraud, and Ensure Safety. These are cases where SylloTips must protect and defend the rights, property, or safety of SylloTips, its users, or third parties, including the enforcement of its contracts or policies or in relation to the investigation and prevention of illegal activities, fraud, or security issues, including preventing death or imminent personal injury.
With Consent. SylloTips may share information with third parties when it has consent or as otherwise permitted in this Privacy Policy. For workspaces registered to corporate entities, SylloTips may share Information with the primary Workspace owner's consent, the authorized corporate officer, or their designated person. For workspaces created without formal affiliation, SylloTips may request user consent.
Any data transfers abroad will occur, if to countries that do not benefit from an adequacy decision by the European Commission and, therefore, do not offer an adequate level of personal data protection, only (i) after adopting appropriate safeguards such as, by way of example, the subscription of standard clauses approved by the European Commission, or (ii) if an exception to the prohibition of transfers outside the European Union applies, such as, by way of example, after obtaining the explicit and informed consent of the User, or only to the extent necessary for the execution of a contract concluded between the User and the Company, or between the Company and a third party for the benefit of the User, or for the execution of pre-contractual measures adopted at the request of the User.

6. Marketing and Profiling
With the data subject's consent or in other cases possibly permitted by data protection legislation, data may also be processed by SylloTips for the following purposes:
a) Sending offers and commercial initiatives via email, automatic messages, or telephone, related to SylloTips products or services, as well as conducting market research or other customer satisfaction initiatives promoted by SylloTips. If data provision is required for such purposes, it will be optional. Consent can be revoked at any time, freely in the manner indicated in the following point 7. Failure to provide or revocation of consent will not affect the execution of the Contract in any way.
b) Analyzing the usage habits of SylloTips products and services by the data subject based on what might be of interest to improve SylloTips products and services with features that may be of greater interest to customers and to offer the data subject products that may better meet their needs. If data provision is required for such purposes, it will be optional. The possible use of information related to the use of products or services attributable to the legal entity Customer may be carried out by SylloTips even without specific consent unless otherwise provided by law. Consent can be revoked at any time, freely in the manner indicated in the following point 7. Failure to provide or revocation of consent will not affect the execution of the Contract in any way.The Data Controller reserves the right to use the email address provided by the Client in the context of the stipulation and management of the Contract to send communications for direct marketing purposes of products or services similar to those covered by the Contract to which this notice refers, without prejudice to the data subject's right to object at any time to receiving such communications by ticking the appropriate checkbox or writing to the contacts provided below.Without prejudice to the exercise of the rights to delete Data and the rights of objection and limitation of processing described in point 7 of this notice, the data processed for the purposes referred to in this point will be retained and processed in compliance with the applicable data protection legislation for the entire period of time necessary to achieve the purposes mentioned above, up to a maximum of 24 months or the longer maximum period allowed by law for profiling as per letter a) of this point; otherwise, for the purposes referred to in letter b) of this point, processing will be carried out until the consent is revoked by the data subject.

7. Data Subject's Rights
The data subject may exercise the rights provided by the GDPR (Art. 15-21) regarding the described data processing, including:
- Receiving confirmation of the existence of the Data and accessing its content (right of access);
- Updating, modifying, and/or correcting the Data (right of rectification);
- Requesting deletion or limitation of the Data processed in violation of the law, including those that do not need to be retained for the purposes for which they were collected or otherwise processed (right to be forgotten and right to restriction);
- Objecting to the processing (right to object);Revoking consent, where given, without prejudice to the lawfulness of the processing based on the consent before its revocation;
- Lodging a complaint with the supervisory authority (Garante per la protezione dei dati personali in case of a violation of data protection regulations;
- Receiving an electronic copy of the Data concerning the data subject, when such Data have been provided within the context of the contract and requesting that such Data be transmitted to another data controller (right to data portability).To exercise these rights, the data subject may contact the Data Protection Officer by sending a request to the address , or by addressing the communication via post to:SylloTips S.r.l.
Piazza Crati, 20,
00199 Rome, Italy

When contacting us, the data subject should ensure to include their name, email/postal address, and/or phone number(s) to ensure their request can be handled properly.

8. Modifiche all’Informativa
SylloTips si riserva di modificare unilateralmente la presente informativa o semplicemente aggiornare il contenuto, in parte o completamente, anche a causa di variazioni della Normativa Applicabile. SylloTips informerà di tali variazioni non appena verranno introdotte e saranno vincolanti non appena pubblicate sul Sito. SylloTips invita quindi a visitare con regolarità questa sezione per prendere cognizione della più recente ed aggiornata.

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