Personal data treatment statement
Motaira cares about your personal data by providing lawful, fair and transparent processing against European Regulation 2016/679 (General Data Protection Regulation) requirements.
Motaira implements countermeasures to protect your personal data collected for the performance of the contract to which you are a party or in order to take steps, at your request, prior to entering into a contract related to Motaira services.
⚠️ The provision of your personal data is mandatory by law, or to enter into or fulfil a contract with our company. If you choose not to give us this information, it may delay or prevent us from fulfilling our contract or doing what we must do by law.
I. Collection of personal data
The personal data are collected when you register to www.Motaira.com or through the mobile library or application installed by your end users.
✓ You and your end users are entitled to request to Motaira S.r.l. the cancellation of the data at any time.
II. Purpose of data treatment and processing
The personal data collected, together with other data related to the electronic communications you will be able to carry out using our services, will be processed by Motaira S.r.l. for the following purposes:
1. Provision of the communication services offered by Motaira S.r.l.
To allow you to use of Motaira and its services (like for example, sending push notifications and messages, to manage your account and join the Forum, Chat, Blog, etc.), it is necessary that Motaira S.r.l have some of your personal data (name, last name, company name, e-mail address, username and password, mobile number) and data related to electronic communication carried out by you and collected during the provision of Motaira service.
Moreover, your end users' mobile number will be used to allow you to if your end users are registered to the services through Motaira mobile library or application.
The data will be used for time required to fulfill these purposes, through the adoption of suitable measures to guarantee the respect of your end users confidentiality and, where possible, in anonymous form.
ℹ️ The unencrypted text of the push notifications and messages sent by you or received by your end users as well as the password for the access (login) to the website and back end system that offer information services and applications concerning the management of your account on www.Motaira.com, will not be read or known by the staff of Motaira S.r.l. or by companies which could take advantage from the provision of the same services.
2. Delivery of commercial and advertising data
Your personal data could be used to send your information messages regarding the opportunities and the promotions of which you may benefit as our user. In particular, your data could be used for:
- Delivery of promotional information, advertising and premium contest
- Commercialization of products and services, delivery of advertising/informative/promotional material
- Market researches and surveys also by means of telephone interviews and delivery of questionnaires
- Economic analyses and statistics
- Participation to marketing initiatives and offer devoted to reward the customers
- Promotion of telephones and data transmission services, as well as capable added value electronic communication services
- Interactive commercials and joining to premium contest
- Customers' satisfaction surveys referring to the quality of the provided services
The advertising messages delivered by MMS, SMS, WAP and e-mail could be sent both after your specific request (pull messages) or through an automated system of delivery (push messages).
The treatment for advertising purposes could be concerning products and services offered by Motaira S.r.l., as well as products and services offered by third parties. In the latter case, your data will not be subject of communication to these third parties.
⚠️ Consent Management: The consent to the data processing given for advertising purposes could be revoked by you in any moment, contacting Motaira S.r.l. at the following e-mail address: privacy@motaira.com
The eventual refusal to the treatment and processing of your personal data for advertising purposes will not influence on the provision of push notifications and messages services, but it will determine the impossibility of keeping you updated on offer and promotional deals dedicated to Motaira users signed up on www.Motaira.com.
The personal data used for the above-mentioned advertising purpose will be kept for the strictly necessary time, and however, for a time up to 24 months.
3. Further purposes
Your personal data, included the data related to the electronic transmission traffic, could be used also for further purposes whose: billing, control and management of the correct operation of the services offered by Motaira S.r.l., management of eventual claims and litigations, implementation of the obligation scheduled by national of EU laws, related regulations and provisions, in particular, to the protection of the public order and to the assessment and repression of the crimes.
III. Data management and safety measures
Motaira S.r.l. applies countermeasures to protect your personal data in order to:
- Disclose your data only to processors which are strictly relevant to contractual obligations
- Store your data in our access-controlled enterprise systems, physically controlled hard copy archives, with permissions granted for the following reasons:
- Data rectification or erasure according your request
- Bookkeeping accounts
- Accounts receivable and payable
- Compliance with civil and fiscal law, regulatory requirements and EU regulations
The data will be managed as described previously using paper or electronic methods, and logical processes strictly related to the same purpose, and will adopt measures which guarantee security and privacy, identified through a privacy impact assessment.
Your data will be stored on the server of Motaira S.r.l., located in appropriate spaces provided by the company Amazon Web Services at their data centre in Dublin - Ireland.
Such company will be in charge of the Processing of your personal data, according to the instructions provided to them by Motaira S.r.l.
In any case, the personal data will be processed and stored for the time established from the law and/or the provisions adopted from the Guarantor for the protection of the personal data, and, once ended, will be cancelled or made anonymous.
IV. Customer and User rights
You might apply at any time for execution of your right according to the following GDPR articles:
- 15 - Right of access
- 16 - Right to rectification
- 17 - Right to erasure
- 18 - Right to restriction of processing
- 19 - Notification obligation regarding rectification or erasure of personal data or restriction of processing
- 20 - Right to data portability
- 21 - Right to object
- 34 - Communication of a personal data breach
By addressing your requests at our company email privacy@motaira.com which we will comply with through specific procedures in order to make you aware about:
- The processing of your data
- The storage and protection of your personal data
- The recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations, to meet the binding contractual obligations
- Actions taken for rectification and erasure of your personal data
- The way you might receive your personal data in a structured, commonly used and machine-readable format
- Actions taken to apply the right to object
- Be informed, without delay, about a data breach which might compromise your personal data
We will inform you as soon as possible about the action taken upon your requests, at the latest within one month from the receiving of your communication.
Moreover, you will be informed, when personal data are transferred to a third country or to an international organization, about the appropriate safeguards pursuant GDPR requirements relating to the transfer, after our vetting of the third country accreditation by the Italian Supervising Authority and/or the Commission.
Your digital requests will be replied with the same media, unless otherwise instructed.
V. Holder, responsible and people in charge of data treatment and processing
Data Controller
The Holder of your data treatment and processing is Motaira S.r.l., with operation Office in Via Cosimo Del Fante, 10 - 20122 Milan (MI) - Italy.
The Data Protection Officer can be contacted at Motaira S.r.l., Email DPO@motaira.com
Inside Motaira S.r.l. your personal data will be processed by Motaira employee or contractors specifically appointed to carry out their duties in accordance with the list of processes and the procedures of Motaira System for Personal Data Protection.
Your data will be handled also from the company Amazon AWS where the server used by Motaira are located, as well as by the third party in charge for technical management of the server and the license to the distribution of the services.
Moreover, part of your personal data processing could be performed also by other third parties. Particularly, the data could be communicated to:
- Entities that provide assistance and support to Motaira S.r.l.
- Entities that perform activity of promotion and sale of services offered by Motaira S.r.l.
- Subjects that lend services of credit risk management and prevention and fraud control
- Other TLC operators used by Motaira S.r.l. for services provision
✓ In any case, such subjects will be appointed as Data Processor. The managers or the people in charge designated will receive suitable operating instructions, also with reference for the adoption of the minimum countermeasures.