Creative Jam S.r.l. is committed to protecting and safeguarding the privacy of users of its site https://treasurehuntinitaly.com; in fact, our technology is constantly evolving to ensure adequate levels of privacy, security and transparency.

This information explains how our company, in synergy with its Partners, is committed to protecting the information collected for the use of our products and services: this information confirms Creative Jam S.r.l. commitment to be transparent towards the User about the data you collect, how you use them and how you share them.

The purpose of this document is to provide the interested party with the necessary information so that he can express, if he deems it appropriate, explicit and informed consent to the treatments carried out. We hope to explain it in a clear and understandable way, but we will provide the contact details below to contact us in case of questions.

In general, any information or personal data that will be provided to Creative Jam S.r.l. through the Site, or that is collected in another way in the use of the services offered by Creative Jam S.r.l., as better defined below, will be processed in accordance with internationally recognized principles of lawfulness, correctness, transparency, purpose limitation and retention, data minimization, accuracy, integrity and confidentiality.
This information was drafted on 22 May 2024; occasionally we may need to change it, also due to changes in the applicable legislation. To stay updated, we invite the interested party to regularly visit this section to gain knowledge of the most recent and updated version of the Information, in any case every registered user will be regularly informed of the changes made.
By using our services, you consent to the use of your data by us pursuant to this Privacy Policy.

A necessary note: if the interested party does not agree with this Privacy Policy, it is necessary to stop using our services.

1.  Data Controller and Data Protection Officer

2.  The data being processed

2. a.  Name, contacts and other personal data

2. b. Data provided voluntarily by the interested party

2. c.  Third-party data provided by the interested party

2. d.  Navigation data

2. e.  Cookie

3.  Legal basis and mandatory or optional nature of the processing

4.  Purpose of treatment

5.  Recipients of personal data

6.  Transfers of personal data

7.  Treatment modalities

8.  Retention of personal data

9.  Social Media

10.  Diritti dell’Interessato

11.  Modifiche

12.  Definizioni

The data controller in relation to all personal data that is processed through the Site is Creative Jam S.r.l., via Tuscolana 942, 00147 Roma, Italy, which can be contacted at the following address: info@treasurehuntinitaly.com. The Data Protection Officer (DPO) can be contacted at the following address: dpo@treasurehuntinitaly.com.

The personal data processed through the Site are the following:

  a.  Name, contact details and other personal data

In the sections of the Site "Contact Us" or "Request Information", you will be asked to enter information such as the name of the contact person, the company name, telephone number, address and e-mail address. Furthermore, whenever the interested party participates in events whose registration takes place via the Site or communicates with Creative Jam S.r.l. through the contacts found on the Site, Creative Jam S.r.l. may collect the additional information that the Data Subject decides to provide.

  b.  Candidatures

Only in the condition it is active and present in the main menu, by registering in the section of the Website relating to the Creative Jam S.r.l. candidatures, you will be asked to provide your personal data (such as Name, Surname, Date of Birth, Address, telephone), and some professional details or working conditions (training, educational qualifications, professional qualifications and desired workplace). The personal data provided for this purpose will be processed by Creative Jam S.r.l. as described in the specific information provided there.

  c.  Third-party data provided by the interested party

As already mentioned above, in some parts of the Site, it is allowed to insert text messages, visible to Creative Jam S.r.l., which could contain (voluntarily or not) personal data of other people.

With respect to these hypotheses, the interested party must consider himself/herself as the data controller, assuming all the legal obligations and responsibilities towards the "interested third parties".

  d.  Navigation data

The computer systems and software procedures used to operate the Site acquire, by default, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category includes IP addresses, domain names of computers used by users who connect to the Site, addresses in URI (Uniform Resource Identifier) ​​notation, time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the IT environment of the interested party. This data is used only to obtain anonymous statistical information on the use of the Site, to check its correct functioning, to provide the User with targeted advertising (for a complete explanation of these forms of use, see the cookie policy), and to identify anomalies and/or abuses. To collect information, in aggregate form, on the number of users and on how they visit the site, Treasure Hunt in Italy uses, among others, the Google Analytics service, whose cookie policy can be viewed at the address

https://support.google.com/analytics/answer/6004245

and Google AdWords, whose Privacy policy is available at the following address:

https://policies.google.com/technologies/ads?hl=en&gl=en

  e. Cookies

Information on the use of cookies is available in the Information:

https://treasurehuntinitaly.com/cookie-policy

The legal bases used by Creative Jam S.r.l. to process personal data, according to the purposes indicated in Article 4 below, are the following:

• Service provision/fulfillment of contractual obligations: processing for this purpose is necessary for the execution of the contract signed between Treasure Hunt in Italy and the interested party and, therefore, to be able to provide the contractually agreed services. The provision of personal data for this purpose is not mandatory, but in the absence of this it will not be possible to provide any Service.
• Legitimate main interest of the owner: the treatment is necessary to make checks and assessments on the results and on the progress of the contractual relationship, as well as on the risks connected to it (such as: truthfulness of the data provided, solvency even in the course of reporting and correct use of product and services).
• Legal obligations: processing for this purpose is necessary for Creative Jam S.r.l. to fulfill any legal obligations. The personal data provided to Creative Jam S.r.l., will be processed according to the applicable legislation, which could lead to their storage and communication to the competent Authorities.
• Promotional communications to its customers: the processing for this purpose is based on the legitimate interest of Creative Jam S.r.l. to transmit marketing communications regarding the integration of products and services already purchased by our customers or the promotion of similar products and services. The interested party may, at any time and free of charge, stop receiving these communications by writing to dpo@treasurehuntinitaly.com and without prejudice to the lawfulness of the processing in the period of validity of the same consent.
• Legitimate main interest of the owner: the processing of our customers' data, in this case, is necessary to improve the efficiency of products and services offered by Creative Jam S.r.l.. To this end Creative Jam S.r.l. will be able to transmit questionnaires concerning the level of satisfaction and market surveys, make telephone calls or chat sessions; these questionnaires/market surveys in general will be designed to minimize the use of personal data.
• Marketing: processing for this purpose is based solely on the consent of the interested party, which can be revoked at any time; the interested party may, at any time and free of charge, stop receiving these communications by writing to dpo@treasurehuntinitaly.com and without prejudice to the lawfulness of the processing in the period of validity of the same consent. In case of revocation Creative Jam S.r.l. will not proceed to make any further communication.

Creative Jam S.r.l. will process the personal data provided by the Users only in the ways established in this Privacy Statement and in compliance with the laws in force. Personal data collected through the Site will be used for the following purposes:

Service provision/fulfillment of contractual obligations: for purposes relating to the execution of the obligations envisaged by the General Contract Conditions.

1. Legitimate main interest of the owner: for verifications and assessments on the results and on the progress of the relationship, as well as on the risks connected to it (such as: truthfulness of the data provided, solvency even during the relationship), to draw up statistics, in anonymous form, on services rendered and about access to sites and commercial information and participation in fairs, events, seminars and any other initiative aimed at promoting Creative Jam S.r.l. products and services; to prevent or detect any abuse in the use of the Site or any fraudulent activity; to improve the quality of the services rendered, by sending questionnaires, feedback on participation in events, recording of calls and chats.
2. Legal obligations to which the data controller is subject: for the fulfillment of the law and/or provisions of public bodies, which require Creative Jam S.r.l. to collect and/or further process certain types of personal data.
3. Sending promotional offers to its customers: to send, via e-mail, SMS, by phone, via banner, instant messaging, through an operator, via paper mail and through the official social pages of Creative Jam S.r.l. (RSS, X, Facebook, LinkedIn, Instagram), marketing communications, promotions and personalized content, providing targeted advertising, concerning products and services similar to those that the Customer has already purchased.
4. Marketing: to send marketing communications, promotions and advertising to anyone who has previously expressed their consent, via e-mail, SMS, telephone, banner, instant messaging, through an operator, via paper mail and through social pages official Creative Jam S.r.l. (RSS, X, Facebook, LinkedIn, Instagram), relating to the products and services of Systems and third parties.

In the cases referred to in points a), b), c), d) of this article, Creative Jam S.r.l. is authorized to process personal data pursuant to the applicable data protection rules, without the need to collect a specific consent from the 'Interested. The processing for the purposes referred to in points a), b) and c) is necessary in order to provide the services and, therefore, for the execution of the contract itself. The provision of Data to Creative Jam S.r.l. for this purpose is not mandatory, but otherwise it will not be possible to provide any service.

In relation to the purposes referred to in point d) the interested party may object to their processing at any time and free of charge: in the event of revocation, the interested party may not use the services specified above.

In the cases referred to in the previous point e) of this article, Creative Jam S.r.l. will process the data only after obtaining the consent from the interested party. The granting of consent, as better specified in the previous art. 3 "Legal basis and mandatory or optional nature of processing", is not mandatory, and where provided, the interested party is free to revoke it at any time without any consequence (except that of not being able to receive marketing communications). More information on the withdrawal of consent previously given is provided in Article 10 of this Notice.

The personal data of the interested party may be destined to the subjects indicated below ("Recipients"):

• Subjects that act as Partners: we work with our Partners throughout the Italian territory, who distribute or promote our products and services. This means that, according to defined criteria, these Partners have been enabled to view some lists of personal data necessary to render the service or to inform the Interested Party about Creative Jam S.r.l. initiatives; the names and contacts of these subjects are available by sending a specific request to the e-mail address: dpo@treasurehuntinitaly.com;
• Subjects that typically act as data controllers, that is: individuals, companies or professional offices that provide assistance and consultancy services to Creative Jam S.r.l. in accounting, administrative, legal, tax, financial, debt collection related to the provision of Services, mailing of advertising material or contractual communications, companies organizing training events, subjects providing services for web meetings and training web seminars; a complete list of all those responsible can be requested by contacting the e-mail address: dpo@treasurehuntinitaly.com;
• Subjects providing e-mail services (platforms for sending e-mails), delegated to also manage cancellation requests sent by users for processing purposes referred to in point 3, letters (d, (e;
• Subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks);
• Persons authorized by Creative Jam S.r.l. to process personal data necessary to carry out activities strictly related to the supply of products/services; a legal obligation of confidentiality applies to these persons;
• Associated companies of the Group for administrative purposes;
• Factoring companies, credit institutions, debt collection companies, credit insurance companies;
• Professional orders or Training Institutions accredited with these Orders;
• Competent subjects, bodies or Authorities to which it is mandatory to communicate personal data to fulfill legal obligations, to prevent abuse or fraud.

For purposes related to the execution of the contract, some data may be disclosed to recipients located outside the EU Economic Area.

Systems ensures that the processing of personal data by these recipients takes place in compliance with the applicable legislation. Indeed, transfers are made through adequate guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate. More information is available from Creative Jam S.r.l. by writing to the following address:

dpo@treasurehuntinitaly.com

The subjects to whom the data will be communicated will be appointed as Data Processors. A complete list of managers can be requested by contacting the e-mail address:

dpo@treasurehuntinitaly.com

The processing of personal data is carried out by means of the following operations: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.

Personal data is processed both on paper and electronic and/or automated, using a cloud-hosted website managed by our company and located in Germany.

The data will be processed in such a way as to guarantee continuous security and confidentiality.

In accordance with European regulations and national data protection laws, Creative Jam S.r.l. has put in place specific procedures to prevent unauthorized access to data, their improper or illegal use, as well as to prevent destruction or even accidental loss of the data itself.

Only duly authorized personnel can access the data while carrying out their work.

The personal data processed for the purpose of "Service Delivery/Contractual Fulfillment" will be kept for the time strictly necessary to achieve the aforementioned purpose. In any case, since these personal data are processed to provide the products/services, Creative Jam S.r.l. may keep them for a longer period, in particular as may be necessary in order to protect the interests of Creative Jam S.r.l. from possible responsibilities related to the supply.

Personal data processed for Marketing purposes will be stored by Creative Jam S.r.l. until the consent given by the interested party is revoked. Once the consent has been revoked, the use of the data for these purposes will cease, but may preserve them in order to protect the interests of Creative Jam S.r.l. from the possible responsibilities based on such treatments.

Personal data processed for the purpose of sending promotional offers to customers will be stored by Creative Jam S.r.l. until the interested party does not object to the treatment by writing to dpo@treasurehuntinitaly.com.

The personal data processed for the purpose of fulfilling legal obligations will be kept by Creative Jam S.r.l. for the period provided for by specific legal obligations or by the applicable legislation.

Personal data processed to prevent Abuse/Fraud will be stored by Creative Jam S.r.l. for the time strictly necessary for the aforementioned purpose.

Treasure Hunt in Italy uses social media for the purpose of communicating content relating to its products and services.

https://twitter.com/thi

https://www.facebook.com/thi

The sites of third parties which can be accessed through this website are not covered by this information. To consult the privacy policies of these social media, please visit the pages:

TWITTER: https://twitter.com/en/privacy

FACEBOOK: https://en-en.facebook.com/policy.php

The interested party has the right to ask Creative Jam S.r.l., at any time:

• Access to their personal data, (and/or a copy of such personal data), as well as additional information on the treatments in progress on them;
• The correction or updating of your personal data;
• The cancellation of personal data from the Creative Jam S.r.l. databases;
• The limitation of the processing of personal data by Creative Jam S.r.l.;
• Data portability, that is to obtain in a structured format, commonly used and readable by an automatic device, a copy of your personal data provided to Creative Jam S.r.l., or to request its transmission to another Data Controller;
• The opposition to the processing of personal data;
• Revocation of your consent for the intended purposes.

Creative Jam S.r.l. will provide the interested party with information relating to one or more of the actions taken as per the previous list without unjustified delay and, in any case, at the latest within one month of the request itself. This deadline can be extended by two months, taking into account the complexity and the number of requests, with consequent information to the interested party of this extension and the reasons for the delay, to be provided within one month of receipt of the request.

The interested party also has the right to lodge a complaint with the competent Control Authority (for Italy, the Privacy Guarantor, http://www.garanteprivacy.it), if it considers that the processing of your personal data is contrary to the legislation in force.

The exercise of the rights referred to in this article may be exercised by the interested party at the following email address: dpo@treasurehuntinitaly.com.

This Notice is effective as of May 10, 2024 Creative Jam S.r.l. reserves its modification or updating also due to possible regulatory changes or practices coming from the National Control Authority or from the European Committee for data protection.

1) personal data: any information concerning an identified or identifiable natural person (Interested); the identifiable natural person who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychic, economic, cultural or social;

2) treatment: any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as the collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of provision, comparison or interconnection, limitation, cancellation or destruction;

3) data controller: the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data; where the purposes and means of such processing are determined by the law of the Union or of the Member States, the controller or the specific criteria applicable to his designation may be established by Union or Member State law;

4) data processor: the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller;

5) recipient: the natural or legal person, the public authority, the service or another body that receives communication of personal data, whether or not they are third parties. However, public authorities that can receive communication of personal data in the context of a specific investigation in accordance with Union or Member State law are not considered recipients; the processing of such data by said public authorities is in compliance with the applicable data protection laws according to the purposes of the processing;

6) third: the natural or legal person, the public authority, the service or other body that is not the interested party, the data controller, the data processor and the persons authorized to process personal data under the direct authority of the data controller or Responsible;

7) consent of the interested party: any manifestation of free, specific, informed and unequivocal will of the Interested party, with which he expresses his assent, through unequivocal positive declaration or action, that the personal data concerning him are being processed;

8) personal data breach: the security breach that accidentally or illegitimately involves the destruction, loss, modification, unauthorized disclosure or access to personal data transmitted, stored or otherwise processed;

9) binding corporate rules: the policies regarding the protection of personal data applied by a data controller or Data Processor established in the territory of a Member State to the transfer or transfer of personal data to a controller or data processor in one or more countries third parties, in the context of an entrepreneurial group or group of companies which carries out a common economic activity;

10) supervisory authority: the independent public authority set up by a Member State pursuant to Article 51;

11) relevant supervisory authority: a control authority involved in the processing of personal data as:

• the data controller or data processor is established in the territory of the Member State of this supervisory authority;
• the data subjects who reside in the Member State of the supervisory authority are or are likely to be substantially affected by the processing; or
• a complaint has been proposed to this supervisory authority.

12) cross-border treatment: a) processing of personal data that takes place in the context of the activities of establishments in more than one Member State of a data controller or Data Processor in the Union where the data controller or data processor is established in more than one Member State ; or

b) processing of personal data that takes place in the context of the activities of a single establishment of a data controller or Data Processor in the Union, but which affects or probably substantially affects interested parties in more than one Member State.

13) Partner: the subject to which Creative Jam S.r.l., on the basis of a signed contract, confers the quality and assignment of Creative Jam S.r.l. dealer, and as such is authorized for the distribution, installation and assistance of Creative Jam S.r.l. products.