Privacy Policy

This Application collects some Personal Data from its Users.

The Commpla platform, URL: commpla.com , (hereinafter referred to as “Site” or “Application”)

COMMpla, with registered offices in via Francesco Redi, 10, 56124 Pisa (IT) – VAT no. and Fiscal Code 01958380501, is committed to protecting the online privacy of the users of this website (“Website”).
As such, this Privacy Policy has been written in order to allow you to COMMpla policy regarding your privacy, as well as how your personal information will be handled when using the Website. This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.
In general, any information and data which you provide to COMMpla in the context of the use of Website’s services (“Contact us” and “Careers”) as better defined in Section 3 below, will be processed by COMMpla in a lawful, fair and transparent manner. To this end, and as further described below, COMMpla takes into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.

1. Data controller 

COMMpla, as identified at the top of this Privacy Policy, is the data controllers regarding all personal data processing carried out through the Website. You can contact COMMpla with any questions related to this Privacy Policy or the COMMpla personal data processing practices by sending a written communication to privacy[@]commpla.com, or via the contact forms available on the Website.

2. Personal Data processed 
When you use the Website, COMMpla will collect and process information regarding you (as an individual) which allows you to be identified either by itself, or together with other information which has been collected. COMMpla may also be able to collect and process information regarding other persons in this same manner, if you choose to provide it to COMMpla, also via the Website.
Data Subjects should refrain from providing the personal data of other data subjects and if they decide to provide such information, they are fully responsible for any claims or damages that may arise as a result of the provision of such information and they fully indemnify COMMpla against any liability.
This information may be classified as “Personal Data” and can be collected by COMMpla when you choose to provide it via the Website (e.g., when you request some Services provided by COMMpla over the Website).
Personal Data which can be processed by COMMpla through the Website are as follows:

a. Name, contact details and other Personal Data
In various areas of the Website you will be asked to submit information about yourself, such as your name and e-mail address. Mandatory fields will be marked as such in the contact forms – it is not possible to process your request if any of the mandatory fields are left incomplete.
In addition, whenever you communicate with COMMpla by submitting a general enquiry, your CV or a support ticket via the Website, COMMpla may collect additional information which you choose to provide. Where these fields are completely free, you may use them to disclose (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.
COMMpla asks that you do not disclose any sensitive Personal Data on the Website, unless you consider this to be strictly necessary.

b. Other persons’ Personal Data
As mentioned in the previous section, certain areas of the Website include free text fields where you can write messages to COMMpla, or otherwise allow you to post various types of content on the Website. These messages and content may (inadvertently or not) include Personal Data related to other persons.
In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify COMMpla against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website.
As COMMpla do not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to COMMpla; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give COMMpla this information.

c. Browsing data
The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. COMMpla do not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.
This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your device, the type of device, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.
These data are used to compile statistical information on the use of the Website, to ensure its correct operation, as well as restore backup from possible failures of the Website and identify any faults and/or abuse of the Website. Save for this last purpose, these data are not kept for more than 60 business days.

c. Cookies
– Definitions, characteristics, and application of standards

Cookies are small text files that may be sent to and registered on your computer by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.
Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.
When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., “ third-party cookies”).
There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.
According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used on a website. In particular, “ technical cookies” – i.e. cookies which are only used to send messages through an electronic communications network, or which are needed to provide services you request – typically do not require this consent. This includes browsing or session cookies (used to allow users to login) and function cookies (used to remember choices made by a user when accessing the website, such as language or products selected for purchase).

– Types of cookies used by the Website

The Website uses the following types of cookies:
Browsing or session cookies, which are strictly necessary for the Website’s operation, and/or to allow you to use the Website’s content and Services.
Analytics cookies , which allow COMMpla to understand how users make use of the Website, and to track traffic to and from the Website.
COMMpla also uses third-party cookies – i.e.cookies from websites / web servers other than the Website, owned by thirdparties. These third parties will either act as independent datacontrollers from COMMpla regarding their own cookies (using the datathey collect for their own purposes and under terms defined by them) or as data processors for COMMpla (processing personal data on COMMpla’s behalf).
For further information on how these third parties may use your information, please refer to their privacy policies:
Instagram
LinkedIn
Twitter
Youtube

The list of installed cookies is available in the Cookie Policy on the Website

– Cookie settings

Cookies are manually managed the first time you visit the website via a dedicated form. In any time, users can block or delete cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:
Chrome
Firefox
Internet Explorer
Safari
You may also provide set your preferences on third-party cookies by using online platforms such as AdChoice.

CAUTION If you block or delete technical and/or function cookies used by the Website, the Website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

3. Purposes of processing 
COMMpla intends to use your Personal Data, collected through the Website, for the following purposes:
To respond to your enquiries and requests for support, and to provide any other services which you may request (“Contact us” and “Work with us”);
For development and administration of the Website, in particular by use of anonymised data analytics regarding how users make use of the Website, to generate statistics and improve our offerings (“Analytics”) ) – Art. 6(1)(f) GDPR;
To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website, including by carrying out internal audits (“Misuse/Fraud”) ) – Art. 6(1)(f) GDPR.

4. Grounds for processing and mandatory / discretionary nature of processing 
COMMpla’s legal bases to process your Personal Data, according to the purposes identified in Section 3 , are as follows:
1. Service Provision (“Contact us” and “Work with us”): processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contact with you – Art. 6(1)(b) GDPR. It is not mandatory for you to give to COMMpla your Personal Data for these purposes; however, if you do not, COMMpla will not be able to provide any Services to you.
2. Compliance: processing for this purpose is necessary for COMMpla to comply with its legal obligations – Art. 6(1)(c) GDPR. When you provide any Personal Data to COMMpla, COMMpla must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
3. Analytics: Information collected for this purpose is used to allow COMMpla to understand how users interact with the Website and to improve the Website accordingly, with the aim to providing a better user experience – Art. 6(1)(f) GDPR. Data are collected in anonymous way and no Personal data is transferred to the service provider Google Analytics
4. Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes) – Art. 6(1)(f) GDPR.

5. Recipients of Personal Data – Data Processors 
Your Personal Data may be shared with the following list of entities (“ Data Processors”); the following entities are engaged in order to provide or support the Website and Services (e.g., hosting providers, e-mail platform providers, technical maintenance providers Website administrators and Website user administrators):

Trust-IT Services Srl located at via Francesco Redi 10, 56124 Pisa, Italy. VAT no. 01870130505
Google Ireland Limited; Gordon House Barrow Street, Dublin 4 DUBLIN, D04 E5W5 Ireland, managing the Google Analytics service for European based website

6. Other Recipients of Personal Data 

Your Personal Data may be shared with the following list of persons / entities (“Recipients”):
Persons, companies or professional firms providing COMMpla with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services and which act typically as data processors on behalf of COMMpla;
Persons authorised by COMMpla to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., members of the team operating the Website, and other functions with access to Personal Data processed via the Website);
Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities.
More information on these transfers is available upon written request to the Website Managing Team at the following address: privacy[@]commpla.com.

7. Retention of Personal Data 
Personal Data processed for Services will be kept by COMMpla for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, COMMpla may continue to store this Personal Data for a longer period, as may be necessary to COMMpla interests related to potential liability related to the provision of the Services.
Personal Data processed for Compliance will be kept by COMMpla for the period required by the specific legal obligation or by the applicable law.
Personal Data processed for preventing Misuse/Fraud will be kept by COMMpla for as long as deemed strictly necessary to fulfil the purposes for which it was collected.
More information on applicable retention periods is available upon written request to the Website Managing Team at the following address: privacy[@]trust-itservices.com.

8. Data subjects’ rights 
As a data subject, you are entitled to exercise the following rights before COMMpla, at any time:
1. Access your Personal Data being processed by COMMpla (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
2. Correct or update your Personal Data processed by COMMpla, where it may be inaccurate or incomplete;
3. Request erasure of your Personal Data being processed by COMMpla, where you feel that the processing is unnecessary or otherwise unlawful;
4. Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
5. Exercise your right to portability: the right to obtain a copy of your Personal Data provided to COMMpla, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
6. Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent COMMpla from processing your Personal Data.
Aside from the above means, you can always exercise your rights described above by sending a written request to the Website Managing Team at the following address: privacy[@]trust-itservices.com.
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful.

9. Amendments 
This Privacy Policy entered into force on 01/03/2024
COMMpla reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. The Website Managing Team will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. The Website Managing Team therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how COMMpla collects and uses Personal Data.