Dear User, Wooflo Pro (hereinafter known as “Wooflo Pro”, “Provider,” us”, “we”, “the App”, “the Site”, or “Wooflo Ltd”) respects the privacy of its users and is committed to protecting their personal information. This privacy policy explains how we collect, use, disclose, and protect personal data, and outlines your rights as a data subject. Please take a moment to review this policy carefully.
The data that may be communicated through the Site will be treated with the utmost care and with all the tools necessary to ensure their security, in full compliance with current legislation placed to protect the confidentiality of data. We wish to inform you that the “European Regulation 2016/679 on the Protection of Individuals with regard to the Processing of Personal Data and on the free movement of such data” (henceforth “Regulation” or “GDPR”) provides for the protection of individuals with regard to the processing of data of a personal nature as a fundamental right. Therefore, pursuant to Article 13 of the GDPR, we would like to inform you of the following.
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Introduction
Wooflo Pro offers its users a software platform called Wooflo Pro, accessible through the website of the same name which, through a series of features and interactions with external providers, allows Customers to:
APPOINTMENT OF DATA CONTROLLER
The User (hereinafter “Owner” or “Customer” or “Data Controller”),
by express acceptance of the Terms and Conditions of Wooflo Pro (hereinafter “Provider” or the “Data Processor”), accepts this addendum on the processing of personal data, which constitutes an integral part of the relationship between the Parties. This Addendum is signed pursuant to Article 28 of Regulation 679/2016 and governs the manner in which the Data Processor will process personal data on behalf of the Data Controller. Data Controller and Data Processor, may also be referred to individually as the “Party” and jointly as the “Parties”.
WHEREAS.
the processing operations of personal data carried out by the Data Controller are listed in the register of processing operations kept by the Data Controller;
for some processing operations the Data Controller makes use of the cooperation of the Supplier;
the Supplier, as part of the services offered to the Data Controller, as better detailed in the specific contract in place, may carry out personal data processing on behalf of the Data Controller;
the Data Controller and the Provider have signed an agreement for the provision of an integrated web and tablet for creating, managing and sending review requests (“Service”), of which this document is an integral part;
with reference to the Service made available by the Provider, the latter may process data personal data owned by the Controller and, more specifically, common data (first name, last name, contact details) of the Holder’s end customers;
the purpose of the processing is to provide a technological solution that allows the Holder to be able to take advantage of the Service;
in accordance with Article 28.1 of Regulation (EU) 2016/679, General Data Protection Regulation (henceforth “GDPR”), “where a processing is to be carried out on behalf of the Controller of the Processing, the latter shall only use data controllers.”
the Data Controller has verified that Wooflo Pro, again pursuant to Article 28.1 of the GDPR, presents “sufficient guarantees to put in place appropriate technical and organizational measures so that the processing meets the requirements of the Regulation and ensures the protection of the rights of the data subject.”
The Data Controller appoints Wooflo Pro as the “PERSONAL DATA PROCESSING RESPONSIBLE” (henceforth also simply “Processor” or “Processor”), with respect to the personal data that Supplier may process in the performance of its activities and those that may be entrusted to Supplier in the future.
In accordance with the GDPR, the activity performed by the Processor will be governed as follows:
DURATION. This appointment shall be effective for the duration of Wooflo Pro’s relationship with the Controller and shall be deemed automatically revoked in the event of termination of the same.
PURPOSE OF THE PROCESSING. The data that are entrusted to Wooflo Pro, as part of the activities entrusted to it for the use of the Service, may be processed only for the purposes indicated in the mandate entrusted and/or in the contract entered into with the Owner. In particular, Wooflo Pro will process data for the purpose of guaranteeing the provision of the Service to the Owner who will remain responsible for communicating purposes to end customers and obtaining consent for processing, as well as communication of data to third parties.
METHODS OF PROCESSING. The data may be processed on paper or digital media, depending on the activities carried out, provided that the tools are properly identified and inventoried by Wooflo Pro and systematically communicated to the Owner for approval. In particular, data will be processed using Wooflo Pro software platform.
DUTIES AND TASKS OF THE RESPONSIBLE PERSON. Wooflo Pro undertakes to:
process entrusted personal data only on documented instruction from the Controller;
ensure confidentiality and appropriate training for authorized personnel;
implement technical and organizational measures to ensure data security;
inform the Data Controller if another Data Processor needs to be used;
assist the Controller in complying with legal obligations;
update, modify, rectify, delete or return personal data as required;
allow Data Controller to exercise control and verification rights;
comply with relevant data protection measures.
SUPERVISION. The Data Controller may supervise compliance with instructions given to Wooflo Pro and verify its experience, capacity, and reliability.
VIOLATION. If Wooflo Pro violates provisions by independently determining processing purposes or disregarding instructions from Data Controller, it will be considered Controller of such processing.
ASSISTANCE TO THE CONTROLLER IN CASE OF A BREACH. In case of a personal data breach, Wooflo Pro agrees to inform Data Controller without undue delay and assist in analyzing and documenting relevant information.
CONFIDENTIALITY. Wooflo Pro agrees to keep Confidential Information strictly confidential and use it only for contract-related obligations. It shall not disclose Confidential Information without written approval from Data Controller.
AMENDMENTS AND ADDITIONS. The Parties have right to make necessary amendments and adjustments to this Agreement at any time. Changes will be deemed accepted by Wooflo Pro after a 60-day period.
APPLICABLE LAWS. Any dispute regarding validity, interpretation, performance, and termination of this Addendum shall be resolved amicably among Parties or under exclusive jurisdiction of Judicial Authority of Court of Rome.
This appointment does not imply any specific compensation or indemnity beyond what is provided for in terms and conditions.