Privacy Policy

1. Introduction

This Privacy Policy describes how Joost Nico Anton Groenewegen processes the personal data of users who visit the jti-advice.com website and use the services offered by JTI Advice.

Personal data is processed in compliance with Regulation (EU) 2016/679 (“GDPR”) and with the applicable legislation on the protection of personal data.

The Jti Advice services are intended exclusively for users of legal age. We do not knowingly collect personal data relating to persons under 18 years of age.

2. Data controller

The data controller is:
Joost Nico Anton Groenewegen
VAT no. 13425580969
Email: Joost.groenewegen@jti-advise.com
Phone: +39 346 0788845

3. What personal data we collect

Browsing data

During normal browsing on the website, the IT systems and software procedures used to operate the website may acquire certain technical data.

Such data may include, by way of example, the IP address, the type of browser used, information about the device and data relating to access to the website.

This data is processed to ensure the correct operation and security of the website and of the JTI Advice services.

Data provided voluntarily by the user

When the user uses the “Request Info” form or contacts Jti Advice, we may collect the data provided voluntarily, including:

• first and last name;
• email address;
• website;
• name of the property;
• information entered in the free-text field;
• any further information communicated voluntarily by the user.

The data is used exclusively to respond to the user’s request, to provide information about the Jti Advice services and, where requested, to allow access to the software trial or to start a commercial negotiation.

4. Purposes and legal bases of the processing

Personal data may be processed for the following purposes:

Handling information requests and software trial requests

The processing is necessary to respond to the user’s requests and to carry out pre-contractual measures adopted at the request of the data subject, pursuant to Art. 6(1)(b) of the GDPR.

Provision of the Jti Advice services

When the user uses the Jti Advice services, the data is processed to the extent necessary for the performance of the contract and the provision of the requested services.

Security of systems and services

Certain data may be processed to ensure security, prevent misuse and protect Jti Advice’s IT systems. This processing is based on the legitimate interest of the data controller, pursuant to Art. 6(1)(f) of the GDPR.

Compliance with legal obligations

Data may be processed where necessary to comply with legal, tax and administrative obligations or requests from the competent authorities.

Where specific processing activities require the user’s consent, such consent will be requested separately and may be withdrawn at any time.

5. Place of processing and data transfers

The processing connected with the Jti Advice services is carried out through IT infrastructures and technical service providers used by Jti Advice S.r.l.

Jti Advice uses, among others, Aruba Data Centers located in Italy and Hetzner Data Centers located in Germany and Finland.

The data is processed mainly within the European Economic Area (“EEA”).

Should the use of specific providers or technological services involve the transfer of personal data to countries located outside the EEA, the transfer will take place in compliance with Art. 44 et seq. of the GDPR and on the basis of the safeguards provided for by the applicable legislation, such as adequacy decisions of the European Commission or standard contractual clauses.

6. To whom the data may be disclosed

Jti Advice does not sell users’ personal data to third parties.

Personal data may be processed or disclosed to service providers strictly necessary for the operation and provision of the Jti Advice services, including:

• hosting and Data Center providers;
• cloud infrastructure providers;
• email service providers;
• technology and software service providers;
• consultants and professionals, where necessary;
• other parties involved in the provision of the services requested by the user.

These parties process the data in compliance with the applicable legislation and, where required, are appointed as data processors pursuant to Art. 28 of the GDPR.

Data may also be disclosed to the competent authorities or to other parties where required by law or in the presence of a legitimate request from the authorities.

7. Cookies and tracking tools

The Jti Advice website may use cookies and other technical tools necessary for the correct operation of the website.

For more information about the cookies used, their purposes and how to manage your preferences, please refer to our dedicated Cookie Policy.

8. How long we keep personal data

Personal data is kept for the time strictly necessary to achieve the purposes for which it was collected, in compliance with the principles of data minimisation and storage limitation provided for by the GDPR.

Data collected through the “Request Info” form is kept for a maximum period of 3 months from the request, unless a pre-contractual or contractual relationship is started that justifies its further retention.

Data relating to customers and to the use of the Jti Advice services is kept for the duration of the contractual relationship and, subsequently, for the period necessary to comply with legal obligations and to protect the rights of Jti Advice S.r.l.

For data processed as part of the “Umano” service, the specific retention arrangements set out in the dedicated section also apply.

9. How we protect personal data

Jti Advice S.r.l. adopts technical and organisational measures appropriate to the risk in order to protect personal data against unauthorised access, loss, alteration, destruction or disclosure.

Communications between the user’s browser and the Jti Advice services are protected by means of HTTPS/TLS protocols.

Jti Advice also adopts authentication systems, access control and restriction of data access to only those systems and persons authorised and necessary for the provision of the services.

Despite the adoption of adequate security measures, no IT system or transmission system over the Internet can guarantee absolute security.

The Jti Advice website may contain links to sites or services operated by third parties. Jti Advice S.r.l. is not responsible for the personal data processing practices adopted by such parties. We invite users to consult the relevant privacy policies before providing personal data.

10. Rights of data subjects

In accordance with the GDPR, the data subject may exercise, where applicable, the following rights:

• obtain confirmation as to whether or not personal data concerning them exists and request access to it;
• request the rectification or updating of the personal data;
• request the erasure of the personal data;
• request the restriction of the processing;
• object to the processing of the personal data;
• receive the personal data in a structured, commonly used and machine-readable format and request its portability, where applicable;
• withdraw consent at any time, where the processing is based on consent, without affecting the lawfulness of the processing carried out before the withdrawal;
• lodge a complaint with the competent supervisory authority.

The exercise of these rights is free of charge within the limits and in accordance with the arrangements provided for by the applicable legislation.

11. How to contact us

For any request relating to the processing of personal data or to exercise your rights, you can contact Jti Advice

The data subject also has the right to lodge a complaint with the:

12. Changes to this policy

Jti Advice may amend or update this Privacy Policy to adapt it to regulatory changes, developments in the services offered or changes in the way personal data is processed.

The most up-to-date version of the Privacy Policy will always be available on the Jti Advice website.

The date of the last update is indicated at the beginning of this document.