Information pursuant to Article 13 of EU Reg. 2016/679 - Clappit

Information on the processing of personal data pursuant to Art. 13 of EU Regulation 2016/679, General Data Protection Regulation and Legislative Decree no. 196/2003, Code regarding the protection of personal data

1 - HOLDERS OF THE TREATMENT
This privacy statement refers to the website www.clappit.com and the private labels connected to it (with domain www.clappit.com/evento), managed and owned by Bemils Srl, with registered office in Via Ferri, 3 20092 Cinisello Balsamo (MI), CF/VAT number 05589050961, e-mail address privacy@bemils.com, Data Controller.

Further Data Controller could be the Organizer of the event, in case of data processing for promotion or marketing purposes, subject to acceptance of further specific Terms & Conditions and Privacy.

The changes and updates will be binding as soon as they are published on the Portal.
In case of non-acceptance of the changes made to the Privacy Policy, the interested party is required to cease using this Portal and may request the Data Controller to delete their Personal Data.

2- LEGAL BASIS AND PURPOSE OF THE TREATMENT
The processing of personal data (including their registration in the Company master data) is based on the existence of a contractual or legal obligation or, depending on the case and as better specified below, on the existence of a legitimate interest of Bemils or on your consent, optional and revocable at any time. It is aimed exclusively at achieving the following purposes:

Provision of the requested services: registration on the Clappit Portal or one of the private labels connected to it is necessary in order to use the service. The administrative and accounting purposes connected to and deriving from the Contract concluded with the interested party are included, also with regard to the possible transmission of commercial invoices by e-mail by Bemils (also including the procedure for reimbursement of the price paid, and consequent issue of a credit note following the cancellation of a purchased event). This context also includes the service provided by Customer Care ("Contact Us" and "Chat" services) and, consequently, the processing of the user's personal data for the management and sending of responses to requests for assistance in relation to one or more of the services available on the Portal.

In fulfillment of legal obligations: for the fulfillment of obligations deriving from the law or from national and/or community regulations in force, in particular, in the tax, public safety, and "secondary ticketing" matters, as well as from instructions given by competent authorities and bodies.

By virtue of a legitimate interest of Bemils: in the legal defense of a right or interest before any competent authority or body, including for the purposes of credit recovery, for the organizational management of the purchased event and/or services accompanying the latter, for example, information about any cancellations or changes of date or place of the event purchased, inform on how to reach and access the event, how to request a refund in case of cancellation of the event.
Administrative and accounting purposes: for sending invoices relating to service fees, other expenses (e.g. shipping by courier, insurance, etc.), or the price of non-fiscal tickets.

Promotional and marketing purposes: subscription to the newsletter, which involves sending information and promotional material relating to the events on sale on the Clappit platform or on one of the private labels connected to it. The relative processing of this data is based on consent, which is optional and revocable at any time. Failure to provide data will not have any consequence on the possibility of registering on the Site and using the services provided, including the possibility of making purchases on the same, and will only imply the non-receipt of promotional and informational material on the events for sale on the Portal. The interested party can modify the consent within his reserved area on the Clappit website and on the private labels connected to it.

Geolocation information: in the event that the interested party places an order, some data will be recorded, such as for example the IP address from which the transaction originated, the time of the request, the type of browser used, etc. This data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site and/or third parties, at the instigation of the competent investigating authorities in accordance with the law.

Cookies: navigation on www.clappit.com and the private labels connected to it takes place through the use of cookies. For specifics on cookies, please read the Cookies Policy.

With reference to the purposes of the processing indicated in the first three points (Provision of the requested services, In fulfillment of legal obligations and By virtue of a legitimate interest of Bemils) we inform you that the provision of data is purely optional. However, since this treatment is necessary to allow registration on the Site and the provision of services offered through it, it should be noted that failure to provide, partial or incorrect provision of the data in question will make it impossible, depending on the case, to register on the Site and to use the services provided and, in general, to initiate the contractual relationship by establishing or established and/or to fulfill the obligations as required by the contract or by the applicable law or, again, to fulfill the specific requests.

The organizer will process the personal data of the interested party for the organizational and security obligations related to the event for which the admission tickets are purchased. Any marketing purposes (subscription to the newsletter) attributable to the organizer will be explained during registration and/or purchase and will always be optional.

The Company does not collect or process personal data attributable to the Customer that the GDPR qualifies as "special categories" (such as, by way of example, data suitable for revealing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of associations or organizations of a religious, philosophical or trade union nature, as well as personal data suitable for revealing the state of health) or data relating to criminal convictions and offences.

3 - METHOD OF TREATMENT
Bemils maintains corporate and IT security measures to prevent unauthorized access, disclosure, modification or destruction of personal data. The processing takes place through IT and/or telematic tools and operations related to the purposes indicated.
The data will be processed mainly with electronic tools, in the ways and within the limits necessary to pursue the aforementioned purposes, in compliance with the principles set out in Art. 5 of EU Regulation 2016/679.

4- DATA COMMUNICATION
Personal data could be communicated by Bemils to the Organizer of the event for which the admission tickets are purchased, for the purposes indicated in point 2.
The data may also be processed by the following categories of subjects:

Persons in charge of the treatment connected to Bemils, or by professionals who need to treat them for organizational and functional needs, as shippers agreed for the home delivery of purchased admission tickets,
To all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative provisions,
To banks and companies that manage the payment circuits through which online payments are made for products purchased through the Site,
To subjects, public and/or private, natural and/or legal persons (Judicial Offices, Chambers of Commerce, Chambers and Labor Offices, etc.), if the communication is necessary or functional for the correct fulfillment of the contractual obligations assumed, or of the obligations deriving from the law.
To Managers, educated in matters of security and protection of personal data, who are prohibited from disclosing or communicating personal data to other third parties.
The data may be communicated to the Judicial Authorities, where required, for organizational and security purposes related to the event and controls envisaged by current legislation.

5 - DATA STORAGE
The data will be stored in electronic archives with full assurance of the adequate security measures, required by the New European Regulation 2016/679.
Bemils will keep the data for the time necessary to fulfill the administrative, accounting, and fiscal purposes relating to the relationship established and deriving from the obligations established by law, in any case within the prescription terms set for the rights and obligations underlying the processing. The data collected for marketing/promotional purposes will be kept in the databases until the interested party exercises the right of cancellation through the methods available on the portal.

The personal data of the interested party will be kept for 24 months in the case of a subscription to the newsletter for the sending of promotional material on events and services for sale on the Portal

6 - MINORS THAN 16 YEARS OLD
Bemils invites all users under the age of 16, not to communicate their personal data under any circumstances without the prior authorization of a parent or whoever exercises parental authority. If Bemils becomes aware of the fact that the personal data have been provided by a minor under the age of 16, it will immediately destroy them, reserving the right to prevent access to the services available on the Portal. 

8 - RIGHTS OF THE INTERESTED PARTY
The rights of the interested party are indicated below:

Right of access: obtain confirmation that personal data concerning him is being processed, and if so, know the content and origin of the data, the purposes, and methods of processing.
Right of rectification: verify the accuracy, request updating and/or rectification of data. If you have a personal account, you can update the information yourself after logging in.
Right to Erasure: Request erasure or prevent further use of your personal data. This right does not apply if the data processing is necessary, inter alia, for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
Right to limitation: the interested party has the right to obtain the limitation of the processing in the event of: a) the accuracy of the personal data concerning him is contested within the period necessary for the owner (Company) to verify the accuracy of these data; b) unlawful processing and request by the interested party to limit use instead of the relative cancellation; c) necessity of the data for the assessment, exercise or defense of a right in court; d) opposition by the interested party to the processing, as indicated below, pending verification of the prevalence of legitimate reasons by the owner.
Right to object: the data subject has the right to object to the processing based on a legitimate interest of the data controller, subject to the demonstration by the latter of legitimate reasons for proceeding which prevail over the interests, rights and fundamental freedoms of the data subject, or for the assessment, exercise or defense of a right in court.
Right to portability: the interested party has the right to receive personal data concerning him and to transmit them to another data controller in relation to the hypotheses in which the processing of his data is based on consent or concerns particular categories of personal data processed on the basis of your consent, or the treatment is based on the execution of a contract and this treatment is carried out by automated means. You also have the right to obtain direct transmission of data from one owner to another, where technically feasible.
To exercise the above rights, the interested party must send a written request to privacy@bemils.com. The interested party also has the right to lodge a complaint with the Supervisory Authority (the Privacy Guarantor)

Last modified February 7, 2022