Version: August 12, 2019
1. Data controller
Personal Data processed
When you use the Website, Curvature 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. Curvature may also be able to collect and process information regarding other persons in this same manner, if you choose to provide it to Curvature.
This information may be classified as “Personal Data” and can be collected by Curvature both when you choose to provide it (e.g., when you sign up for an account, in order to receive Curvature’s Services) or simply by analysing your behaviour on the Website.
Personal Data which can be processed by Curvature through the Website are as follows:
a. Name, contact details and other Personal Data
In various sections of the Website – e.g. if you decide to request a quote on the Website, or to subscribe to the Website’s Blog – you will be asked to submit information such as your name, phone / mobile numbers and e-mail address, as well as information related to the company you currently work for and your position in that company.
In addition, whenever you participate in surveys and other promotions which may be available on the Website, as well as whenever you communicate with Curvature through the contact details provided in the Website, Curvature may collect additional information which you choose to provide. This is also the case regarding any information you choose to disclose in certain sections of the Website which allow you to participate in a public forum or to contact Curvature directly.
b. Special categories of Personal Data
Certain areas of the Website include free text fields where you can write messages to Curvature (e.g., the Live Chat), or otherwise allow you to post various types of content on the Website, which may contain Personal Data.
Where these fields are completely free, you may use them to disclose, or may post content which discloses (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.
Curvature asks that you do not disclose any sensitive Personal Data on the Website, unless you consider this to be strictly necessary. If you do, then this Personal Data may be processed by the Company based on your explicit consent.
c. 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 Curvature, 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 on the Website, 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 Curvature 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 Curvature does 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 Curvature; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give Curvature this information.
d. 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. While Curvature does 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 computer, 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, as well as to ensure its correct operation and identify any faults and/or abuse of the Website.
– What are cookies?
Cookies are small text files that are sent and registered on your computer by the websites that you visit. These files are then re-sent by your computer to the same sites, when you visit them again.
Cookies allow websites to “remember” your actions and preferences (such as login data, language, font size, browsing activities and more). The information collected by cookies can be used for a wide variety of purposes, including to ensure that you don’t need to reconfigure settings when you visit a website again (or when you change pages within the same site), to keep you logged in to your account, to gather information about how you use a website, and to display advertisements on a website which may interest you.
There are different types of cookies that you may receive when browsing a website, which can be classified based on their purpose. These include technical cookies, browsing / session cookies, and function cookies (all of which usually don’t require your consent), analytics cookies and profiling cookies (which usually require your consent).
Cookies can also be divided into first-party cookies and third-party cookies, depending on whether they are sent to your computer and managed by the owner of the website, or by someone else.
– What cookies do we use?
Our Website uses the following types of cookies:
Here is information on the first-party cookies we use
|Technical name||Cookie type, function and purpose||Duration|
Determines if the user has previously viewed interstitial / pop-up content on the current page.
|Google (Google Analytics, DoubleClick)||https://policies.google.com/technologies/ads
Our site uses Google Analytics. Analytics is a tool developed by Google that collects information allowing for your use of the site to be evaluated, analysed and is meant to improve your browsing experience. You can read more about how to opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
– How can I change my cookie settings?
You can block or delete the cookies used on our site via your browser options. Your cookie preferences will be reset if use change the browser you use to access the site. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:
ATTENTION! If you block or delete the technical and/or function cookies used on our site, it may not be possible to browse the site and/or some of the functions of the site may not be available. In this case, you may need to manually enter your information and preferences each time you visit the site.
6. Retention of Personal Data
Personal Data processed for Service Provision will be kept by Curvature 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, Curvature may continue to store this Personal Data for a longer period, as may be necessary to protect Curvature’s interests related to potential liability related to the provision of the Services.
Personal Data processed for Marketing will be kept by Curvature until you opt-out or unsubscribe. Once this is done, Personal Data will no longer be used for these purposes, although it may still be kept by Curvature, in particular as may be necessary to protect Curvature’s interests related to potential liability related to this processing.
Personal Data processed for Profiling will be kept by Curvature from the moment you give consent until the moment you withdraw the consent given. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by Curvature, in particular as may be necessary to protect Curvature’s interests related to potential liability related to this processing.
Personal Data processed for Compliance will be kept by Curvature for the period required by the specific legal obligation or by the applicable law.
Personal Data processed for Analytics and Misuse/Fraud will be kept by Curvature for as long as deemed strictly necessary to fulfil the purposes for which it was collected, unless you validly object to the processing of your Personal Data for these purposes (please see Section 8 for further information).
7. Data subjects’ rights
As a data subject, are entitled to exercise the following rights before Curvature, at any time:
- Access your Personal Data being processed by Curvature (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
- Correct or update your Personal Data processed by Curvature, where it may be inaccurate or incomplete;
- Request erasure of your Personal Data being processed by Curvature, where you feel that the processing is unnecessary or otherwise unlawful;
- 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;
- Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Curvature, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
- Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Curvature from processing your Personal Data; or
- Withdraw your consent to processing (for Profiling).
Please note that most of the personal information you provide to Curvature can be changed at any time, including your e-mail preferences, by accessing the user profile you can create on the Website.
You can object to the processing of your Personal Data for Marketing also by selecting the appropriate link included at the bottom of every marketing e-mail message received.
Aside from the above means, you can also exercise your rights described above by sending a written request to Curvature at the following address: [email protected]
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.