Data Controller

This page describes how Toky Digital SRL, as the data controller, processes users’ personal data. It also describes the types of data collected, the purposes of processing, and users’ rights regarding the ability to view, update, and delete their data.
Types of Personal Data

When browsing the Toky Digital SRL website, our systems automatically collect certain information, such as the user’s IP address at the time of browsing, the information and pages requested, the version of the program used to navigate the web (browser), and the user’s operating system.

This data is stored by our website management provider for IT security reasons, to verify that there is no unauthorized access, and to prevent suspicious activity or cyber attacks. User data will only be used in the event of potential problems or damage to the IT system.

We also collect information through cookies and web analytics.
Types of data provided in case of requests

When you contact Toky Digital SRL and/or Partners and/or Customers via email or by completing the online form, you consent to the processing of your personal data in accordance with the provisions of European Regulation 2016/679. Data sent via email and/or online form will be stored along with the message. Documents sent via email attachments will be retained in accordance with this privacy policy.

For telephone inquiries, Toky Digital SRL will save the information provided, but the call will not be recorded.

Data provided via post will be retained in accordance with privacy regulations.
User information obtained from third parties

We receive information about users’ browsing, through our suppliers, through cookie technology and web analytics services.

We do not typically receive user information from third parties, but it may be necessary to search for user data by consulting websites, publications, or social media when the information held by Toky Digital SRL is insufficient to contact the user or to verify the accuracy of the contact information.
Purpose of data processing

The personal data provided may be used to:

1. Operation of the site, such as identifying you when you log in;
2. Updating you about changes to the site and services or notifying you of security issues or updates;
3. Providing you with information or support you have requested;
4. Performing technical analysis on the site to improve its efficiency and quality of services;
5. Monitor activity on the site to identify potential fraudulent activity and ensure that actions are in accordance with the site’s terms of use;
6. Providing administrative services.

Parties to whom we disclose your data. Your personal data is not provided to third parties except to use services necessary or to support Toky Digital SRL’s business. These services include:

• Telephone operator
• Email services
• Mailing list services
• IT support
• Web development
• Hosting provision

Information will be shared only when strictly necessary. Toky Digital SRL may be required to share user information for legal reasons. This happens:

• If we suspect fraudulent use or a crime has been committed and we are forced to contact law enforcement;
• If we need to enforce our rights due to copyright infringement, non-payment, or breach of contractual obligations;
• To resolve disputes with users or third parties;
• To comply with legal obligations.

Data Retention Methods: Users’ personal data is stored securely on our servers or those of our service providers (hosting) and occasionally in backup copies kept in protected locations. Access to personal data is restricted to authorized personnel only and only for the purposes explained above. We adopt authenticated access measures and, where possible, use encrypted and traceable transmission technologies to protect user data. Paper documents containing user data are stored in restricted-access locations and are accessible only to authorized personnel for the purposes of providing the service.
Period of Processing: Toky Digital SRL will retain users’ personal data only for the time necessary to provide the services or to comply with legal obligations. In some cases, this period is clearly indicated:

• For mailing lists to which you have subscribed, we retain your information for as long as you remain subscribed or until we decide to suspend the service.
• For emails and correspondence, we retain your information for as long as necessary to respond and for the following 6 months, after which we will delete it.

Where it is not possible to indicate a clear date, we retain the information for as long as necessary, taking into account the following criteria:

• The purpose and use of the information now and in the future;
• Any obligations to retain records;
• Potential risks in retaining personal data;
• The difficulty of keeping data up to date;
• The legal basis for retaining the data (e.g., consent);
• The nature of the relationship and any other circumstances.

What are Cookies and Web Analytics? Cookies are small text files used by browsers to store information about users for various purposes. Toky Digital SRL uses them to improve the user’s browsing experience (for example, to store login passwords) or to perform usage analyses. Google Analytics is used on the site to obtain information about traffic and browsing from Google. Google collects some user data, including IP addresses and cookies, to provide its analytics service in an aggregated and anonymous form based on the service selected. Users can consult Google’s privacy policies regarding partners for more details, or they can also decide to disable Google Analytics by downloading the browser plugin.
Processing of sensitive data Toky Digital SRL only processes users’ personal data within the timeframes described. Sensitive data includes health, religious beliefs, ethnic origin, political opinions, trade union membership, biometric and genetic data. This data is not known to Toky Digital SRL and is not collected intentionally. Therefore, it is not necessary for users to send it to us. Should the user do so, intentionally or by mistake, Toky Digital SRL will assume the user’s consent to their processing for the sole purpose of deletion.
User rights: Taking into account the applicable limitations, the following is a list of the rights the user can exercise by sending an email to amministrazione@tokydigital.it:

• Request access to your information and information relating to the processing of your data;
• Request correction or deletion of your data;
• Request restriction of data use;
• Request to receive the data you provide in a format commonly used for machine-to-machine communication (for example, a CSV file);
• Refuse consent to data processing for certain purposes;
• Withdraw consent to the use of your data at any time, even if you previously provided consent, without affecting Toky Digital SRL’s prior authorization.

Information made public or provided to others by the user, Toky Digital SRL is not responsible if a user provides information to third parties, for example, by sharing a link via a social network or contacting another user. Before sharing information, it is advisable to review the third party’s privacy policy and how they handle data.
Updates to the Policy Toky Digital SRL’s privacy policy may be updated over time due to legal changes to which it must comply or to inform users of changes to the data processing methods implemented by Toky Digital SRL. Therefore, it is advisable for the user to review this updated document.
Contacts Users can contact Toky Digital SRL by sending an email to info@tokydigital.it or by post to Via Altmann 9 – 39100 Bolzano. Users who are dissatisfied with the response or encounter problems with the processing may contact the Italian Data Protection Authority.