This Privacy Policy has been specifically drafted by Whitelibra S.r.l. to inform you about the processing of your personal data, collected at the time of your registration to our Platform. Data processing means “any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, restriction, erasure or destruction”. We inform you that the processing of your personal data will be carried out in full compliance with Regulation (EU) 2016/679 (hereinafter: GDPR), will be based on the principles of lawfulness, correctness and transparency and will be carried out only after the release and acquisition of your consent by Whitelibra S.r.l. We also inform you that your personal data will be processed exclusively for the purposes set out below, to the extent necessary for Whitelibra S.r.l. to provide the services offered and requested by you. The Data Controller – as defined under article 4 of the GDPR – is the company Whitelibra S.r.l., with registered office in Milan, Via Galleria Passarella n.1, 20122 (MI), VAT and Tax Code: 10789710968, (hereinafter “Whitelibra”).  


When you register with the Platform, you will be asked to provide certain personal data such as, but not limited to, your name, surname, contact details, address, job title, position held in the company, curriculum vitae, so that Whitelibra can get in touch with you, evaluate your application for the use of the services provided by the Platform, or certain payment data. In case of refusal to provide the data or even in the case of untrue data provided, the consequence will be the impossibility for Whitelibra to provide the requested services (e.g. registration). For further purposes or different treatments, your specific and optional informed consent is required: in the absence of your consent for such purposes or further treatments, they cannot be carried out. Some of the personal data processed by Whitelibra are essential, therefore the provision of such data is necessary for the sole purpose of performing the service requested and fulfilling the related obligations. Such data will be specifically indicated as compulsory at the time of their collection. We inform you that failure to provide this information, as well as the lack of your consent for the processing of the data necessary to obtain the requested service will make it impossible for Whitelibra to provide the relative service. Otherwise, for further purposes or different processing operations, your separate specific and optional informed consent is required: in the absence of your consent for such further purposes or processing operations, they cannot be carried out.


We would like to inform you that your data is used by Whitelibra in order to allow you access to the Platform, to provide you with the services you have requested and therefore for the purposes of the execution of the contractual relationship established between the parties. This data is also used for the purpose of invoicing the services, to fulfil legal and regulatory obligations, to communicate with you regarding the services, where necessary. We would also like to inform you that Whitelibra uses your data to inform you about relevant changes or developments in the Platform or services offered. Your data will be stored by Whitelibra for the period of time strictly necessary to achieve the purposes for which it was collected and for the period of time required by law. If you do not wish the data to be used by Whitelibra as described above, please notify Whitelibra at whitelibra@pec.it


We inform you that the data provided by you are transferred to AWS servers and stored there in accordance with the procedures and security measures provided for in Article 32 of the GDPR. For the proper performance of the above purposes, Whitelibra’s administrative and appropriately authorized Whitelibra personnel, persons who carry out commercial activities, as well as personnel responsible for the management of computer systems, maintenance of the Platform and assistance to users, and personnel of third party companies that provide services to Whitelibra (for example, providers of computer services for hosting and maintenance of the Platform) may have access to your data. Some third parties are responsible for processing part of the data, such as those related to credit card payments, and provide Whitelibra with support services in relation to payments made to the latter. In the event that Whitelibra enters into cooperation agreements (joint venture), or purchases, or is sold, or is merged with another company(ies), your data may possibly be communicated or transferred to the new business partner, the new owner, the target company or their respective consultants. We inform you that Whitelibra has the right to communicate or share your data with third parties in the event that it is required to do so in order to comply with a legal obligation, to implement the General Conditions of Use of the Platform or other contract and/or to protect the rights of Whitelibra and/or other parties. The above clause extends to the exchange of data with other companies or entities for purposes related to the prevention of fraudulent activities and the protection from them. We also inform you that, where necessary, your data may be transferred by Whitelibra to third countries both within and outside the European Union. In the latter case the transfer of data will take place in accordance with the regulatory provisions by entering into agreements with the data importer and/or by adopting the standard contractual clauses provided by the European Commission, which ensure an adequate level of protection, and if necessary other additional measures.


Your personal data are processed, in accordance with the provisions of Article 32 of the GDPR, also with automated and electronic tools. Specific security measures are observed by Whitelibra to prevent the loss of data, illicit or incorrect use and unauthorized access, including the https secure protocol for certain confidential parts of this Platform.


By submitting your request directly to the registered office of Whitelibra by registered letter with acknowledgement of receipt or by using the following e-mail address: whitelibra@pec.it, you may exercise, at any time, in accordance with Articles 15 to 22 of the GDPR, the right of:
  1. asking for confirmation whether personal data concerning you is being processed;
  2. obtaining information about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom your personal data have been or will be communicated and, when possible, the period of storage;
  3. obtaining the correction and deletion of your personal data;
  4. obtaining the limitation of the treatment of your data;
  5. obtaining the portability of the data, i.e. receive them from Whitelibra S.r.l. in a structured format, in common use and readable by automatic device, and transmit them to another data controller without hindrance;
  6. opposing the processing at any time and also in the case of processing for direct marketing purposes;
  7. opposing an automated decision-making process relating to natural persons, including profiling;
  8. revoking the consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation;
  9. making a complaint to a supervisory authority.


We also inform you that by using the same contacts listed in paragraph 5 above of this Privacy Policy, you will be entitled to make any changes to the consent given by you regarding certain services requested.


CREDIT CARDS Payment by credit card does not involve additional costs and the transaction is secure and certified, thanks to the use of advanced technologies that allow our payment gateway to manage your sensitive data in an anonymous and certified way. You can pay with the main credit cards on the market (Visa, Mastercard, American Express). To proceed with the purchase with your credit card, simply enter the following information in the payment screen:
  1. Name and surname of the card holder
  2. The card number and the protection code (the 3-digit code on the back of the credit card)
  3. The expiry date of the card
PAYPAL PayPal is the fast and secure way to make your payments online. It is completely free and allows you, once registered, to pay with your credit or prepaid card, or through your PayPal account, which you can top up by bank transfer or credit or prepaid card. If you choose this payment method, you just need to enter your login credentials so you can make the payment in a few seconds through your Paypal account. Of course, all the information will be entirely managed by Paypal, ensuring the protection of your purchases and your data. For the protection of your security Whitelibra does not process and does not store any data concerning payment instruments (e.g. credit card numbers), which are processed by the relevant payment service providers. The actual payment is made after the User has been transferred to a secure and encrypted page of the banking service (PayPal Pro). Only after the transaction has taken place, the banking service provider informs Whitelibra of the outcome of the payment, without providing any information regarding the credit card used. For this reason, Whitelibra has no power over the possible refusal of the credit card used for the payment. Whitelibra cannot therefore be held responsible in any way for direct or indirect consequences deriving from the use of the credit card by the user to make payment for the products and/or services purchased. If you have any other questions or need assistance write us at info@whitelibra.com. BANK TRANSFER

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