Privacy Policy

Data protection information for visiting the website and using the contact forms on the website

I. Definitions

Website

means the website www.punware.eu

Punware

refers to the company PUNWARE TECHNOLOGIES LTD, a single-member company, with registered office at 7 Florinis street, Greg Tower, 2nd floor, flat 201, 1065 Nicosia, Cyprus, tax and VAT number 10437296G, registered in the commercial register at the Chamber of Commerce of Cyprus under the number HE437296, e-mail: info@punware.eu (further data disclosed in the imprint)

Personal data

means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing

means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller

means Punware, i.e. the company that solely decides on the purposes and means of processing personal data on the website.

GDPR

means the European Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

User

refers to any natural or legal person who accesses the website via the internet.

DPO

means the Data Protection Officer, PUNWARE TECHNOLOGIES LTD can be contacted at the e-mail address privacy@punware.eu

II. Data protection notice on navigation and use of the website in accordance with Art. 13 GDPR - Cookie policy

1. Purposes and principles of data processing

In accordance with Articles 13 and 14 GDPR, this data protection notice informs the User which personal data Punware processes during the visit to the website.

The Italian data protection authority (Garante per la protezione dei dati personali) implemented the EU Directive 2009/136/EC with resolution dated 8 May 2014, which obliges website operators to publish a cookie policy on the website.

This policy may be updated at any time to comply with changes in current legislation or changes in the configuration and type of cookies used. Punware therefore recommends that the User checks this Cookie Policy regularly in order to be informed of any subsequent updates.

The Website may contain links to external websites. Users should consult the privacy policies of those websites for information about how their operators process personal data.

2. What are cookies?

A cookie is a small text file that is stored on your computer or mobile device (mobile phone, tablet, etc.) when you visit a website (internet presence), which allows the website to automatically recognise the user (or other users using the same device) after the first visit and thus improve their user experience.

The functionality of cookies depends entirely on the browser used by the user and can be activated or deactivated by the user. By default, almost all web browsers are set to accept cookies automatically.

3. Types of cookies

The following types of cookies exist:

First-party cookies, if they are managed directly by the website operator.
Third-party cookies, when the cookies are installed and managed by third parties that are not the website visited by the user. Third-party cookies are the direct and exclusive responsibility of the respective operator and, with regard to their installation, the operator of the first-party website merely assumes the role of technical intermediary.
Technically necessary cookies: These cookies ensure that the Website works and that the User sees the Website the same way on the next visit as the first time. Persistent cookies are stored on the User's computer and are not automatically deleted after the browser is closed; the session cookie, on the other hand, is deleted after the Website visit has ended. For the use of technical cookies, the law only requires the mere provision of information to the data subject, as is the case with this notice, even without the installation of specific banners on the Website.
Technically unnecessary cookies: These cookies are not (only) used for the functionality of a Website, but also collect personal data of the User. This includes tracking cookies (these collect information about the User across devices, e.g. their location, where on the website they have been for how long), targeting cookies (adapt advertisements for the User), analysis cookies (analyse User behaviour on the Website) and social media cookies (link a website with social media platforms such as Instagram or Facebook).

4. Which cookies are used on the website and for what purpose?

4.1 Technical cookies

The Website uses technical cookies which are necessary for a proper navigation on the Website.

4.2 Non-technical cookies - Google Analytics

The Website uses Google Analytics 4, a web analytics service provided by Google, to collect information about visits and interactions with the Website. The service uses the Google tag and cookies to generate usage statistics only after you accept analytics cookies. Until then, the Google Analytics tag is blocked. Google advertising features are disabled.

Information about this service, the data it processes and the privacy controls offered by Google is provided below. Users can also contact Punware at privacy@punware.eu with questions about the processing of their personal data.

4.2.1 Contents

Google Analytics enables website operators to measure traffic and engagement on their websites and mobile apps using customisable reports.

4.2.2 Processing company

Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.

4.2.3 Data protection officer of the processing company

Below you will find the e-mail address of the data protection officer of the processing company: E-Mail-Adresse

4.2.4 Purpose of the data

The purposes of data collection and processing are as follows: Marketing and analysis.

4.2.5 Technologies used

The following technologies are used to collect data: Tracking code and cookies.

4.2.6 Collected data

This list contains all personal data collected from or through the use of this service: Device information, Geographic location, Browser information, Device operating system, Screen resolution, Referrer URL, Interaction data, Date and time of visit, User behaviour, Pages visited, Online identifiers, Shortened IP address, User ID, Advertising identifier.

4.2.7 Place of processing

The data is processed exclusively in the European Union.

4.2.8 Storage period

The data will be deleted as soon as it is no longer required for the specified processing purposes. The maximum retention period is 14 months.

4.2.9 Transfer to third countries

When using Google Analytics, the collected data may be forwarded to another country: United States of America, Singapore, Taiwan, Chile.

4.2.10 Data recipient

The recipients of the data collected are listed below: Alphabet Inc, Google LLC, Google Ireland Limited. The privacy policy can be found here:

4.2.11 Memory information

The cookies are stored for a maximum of two 2 years.

4.3 Non-technical cookies - Social media

On the website, the user can directly access Punware's social media channels (Facebook, Linkedin, Instagram, X, YouTube).

However, access does not take place via social plugins, which automatically transfer an interaction action of the User directly on the website to the corresponding social network, but via a simple link, in which, on a technical basis, no (personal) data is collected or transferred. Data processing may only take place when the User clicks on a link and is redirected to the external page, i.e. the social media profile. Punware is not responsible for this processing.

The management of information and the methods for deleting such social media cookies are therefore governed by the respective social media websites: Users are invited to consult the relevant privacy policies of each website at the following links:

The use of such cookies is purely anonymous, no personal information is collected unless the user expressly wishes to provide it by sending contact forms and/or requests for information.

5. Change and delete cookies

Use the Privacy Settings banner to accept or deny analytics cookies. You can reopen the settings at any time using the “Preferences cookies” link in the footer and select or deselect Analytics. Necessary storage cannot be disabled in this panel. Your choice is stored locally in your browser for up to 180 days. Withdrawing consent stops further Analytics collection and removes accessible Google Analytics cookies from this website; it does not erase data already collected by Google. You may contact privacy@punware.eu to exercise your rights regarding that data.

By default, browsers generally accept the use of cookies both from this Website and from third-party websites. In order to enable the Website to function properly, to fully utilise its functions and to use them to their full extent, we recommend accepting the use of technically necessary cookies.

However, the User is authorised to change the default settings at any time. To manage the functioning of cookies and to set options to restrict or block cookies, the User only needs to change the settings of its internet browser via the corresponding toolbar. It is possible to choose between the unconditional acceptance of all cookies, the definitive general rejection of all cookies or the display of a pop-up window (warning) for each proposed cookie to decide whether or not to accept it, through an explicit action by the user.

6. Rights of the user under the GDPR

PUNWARE TECHNOLOGIES LTD is responsible for data processing.

7. Rights of the user under the GDPR

The rights of the User in accordance with the GDPR are set forth in Section 14.

III. Data protection notice on the use of contact forms on the Website

There are contact forms on the Website which the User can use to request information and offers on the products and services offerd by Punware.

8. Purposes of processing and legal basis

The data received from the User will be processed for the correct recording and processing of the enquiry, for forwarding to the persons responsible within Punware and for sending an offer or for further contact details.

However, since the provision of this information is not necessary for navigating on the Website, the User must give its consent to the processing of personal data before sending the request (Art. 6 para. 1 sentence 1, lit. a GDPR). Consent is given via the opt-in option by clicking on the corresponding field in the contact form.

9. What data is collected via the contact form?

The following data is collected via the contact form:

Salutation - For the correct form of address when submitting an offer or making further contact
First name and surname - To record the person to whom the offer is to be sent or with whom contact can be made.
E-mail address - For sending the offer or for contacting the person that submitted a request
Name of the company - For the registration of the company to which the offer is to be addressed.
Seat of the company - For forwarding the offer to the proper person internally in Punware

10. Data transfer

Without prejudice to disclosure to third parties due to legal obligations or regulations or a request from courts or other third parties who are authorised to do so in accordance with the aforementioned provisions, the data will only be processed internally by Punware for the purposes of submitting a offer or establishing further contact.

11. Data transmission to third countries

In cases where the services offered may require this, the Controller may use cloud services from "Microsoft Azure", which would result in the transfer of data abroad.

In relation to such transmission(s), the Controller informs that:
The cloud solution "Microsoft Azure" has received an adequacy decision from the organisation "Article 29 Working Party" regarding conformity with the security standards approved by the EU Commission.

12. Retention period of the data

As a rule, the data will be stored for as long as is necessary to fulfil the offer submission and, if applicable, the exchange of information. If offers are sent, the personal data contained in the offer will be stored for 10 years from the date of transmission, as provided for by the Italian Civil Code for the purpose of storing business correspondence. In the event of disputes with the User, the data will be processed for the time strictly necessary to safeguard Punware's rights.

13. Responsible for data processing

The Controller for the processing of your personal data is PUNWARE TECHNOLOGIES LTD.

14. Rights

In connection with the processing of personal data, the User has the following rights, which he can exercise without special formalities by contacting Punware at the above e-mail address.

14.1 The User can request confirmation from Punware as to whether personal data concerning the User is being processed. In this case, the User will receive access to the personal data and the following information:

the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right of the data subject to request from our company rectification or erasure of personal data or restriction of processing of personal data concerning him or her or to object to such processing;
the right to lodge a complaint with a supervisory authority; if the personal data are not collected from the data subject, all available information about their origin;
the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

14.2 If personal data is transferred to a third country or an international organisation, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.

14.3 The User may request Punware to rectify incorrect data without delay; taking into account the purposes of the processing, the user may request the completion of incomplete personal data, including by means of a supplementary declaration.

14.4 The User can request the deletion of the data if:

the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
the data subject withdraws consent on which the processing is based and where there is no other legal ground for the processing;
the data subject objects to the processing and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing for direct marketing purposes (including profiling for such direct marketing);
the personal data has been processed unlawfully;
the deletion of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which our company is subject;
the personal data was collected in connection with the provision of information society services;

14.5 The User may request the restriction of the processing of their personal data if one of the following conditions is met:

the accuracy of the personal data is contested by the data subject, in which case the processing may be restricted (i.e. suspended) for the period necessary for Punware to verify the accuracy of the personal data;
the processing is unlawful (e.g. because the data subject has not been provided with information required by law) and the data subject objects to the erasure of the personal data (i.e. the data subject wants it to be kept in Punware's paper and/or electronic archives instead) and the use is restricted instead;
Although Punware no longer needs the personal data for the purposes of the processing, the personal data are required by the data subject for the establishment, exercise or defence of legal claims;
the data subject has objected to processing for direct marketing purposes pending the verification whether the legitimate grounds of our company override those of the data subject;

14.6 Upon request, the User will receive information about the third parties to whom personal data has been transmitted.

14.7 The user may at any time withdraw the consent to processing previously given for one or more specific purposes, without prejudice to the lawfulness of the processing carried out on the basis of the previous consent.

14.8 The user has the right to receive his personal data, which he has provided to Punware, in a structured, commonly used and machine-readable format; he may request that his data be transmitted to another controller without hindrance from Punware, provided that the following conditions are met (cumulative condition):

the processing is based on the data subject's consent for one or more specific purposes or on a contract to which the data subject is party and the processing is necessary for the performance of that contract; and
the processing is carried out by automated means (software) (overall right to so-called "data portability"). The exercise of the so-called right to data portability does not affect the right to erasure described above;
not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the user or similarly significantly affects you.

14.9 The User has the right to lodge a complaint with the competent supervisory authority (Garante per la protezione dei dati personali) in accordance with the GDPR or with an ordinary court.