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Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016
“GENERAL REGULATIONS ON DATA PROTECTION”

Legislative Decree 30 June 2003, n. 196
“CODE ON THE PROTECTION OF PERSONAL DATA”

Privacy Policy
Digital Atom SRL respects the privacy of visitors and online users of its products and services. Digital Atom SRL recognizes the importance of protecting user information and has adopted this privacy policy to inform users about how Digital Atom SRL collects, stores and uses user’s information resulting from the use of products, services and online website of Digital Atom SRL from users. We process personal data in accordance with the general data protection regulation (GDPR, General Data Protection Regulation).
This information is updated to the latest revision date. However, this information can be changed on a regular basis to reflect any changes and additions to it. Before complying with the provisions of the privacy policy, we recommend that you verify that this is the latest version available.

Data holder
Digital Atom SRL is responsible for the processing of personal data that we collect when you use the www.eyecadvr.com website, download a trial version of software and/or related services, purchase a license and/or related services, create an account “My eyecad VR”, you sign up for our newsletter.

For questions or requests, you can use the following contacts:
Digital Atom SRL, via Ceccano, 8, 96016 Lentini, Syracuse IT
Email address: info@eyecadvr.com
Telephone number: +39 0931 1756027 (available in English and Italian)

Personal information: definition, collection and use
Personal information are all information that can be traced directly or indirectly to a single identifiable person. Digital Atom SRL collects personal information about you in these different situations:

● When you visit our website, we store and process information about the use of the website. The aim is to improve the user experience.

● When you download a trial version of software and/or related services or when you purchase a software license and/or related services, we store and process your IP address, name, surname, state, street, house number, post code, city, province, telephone number, e-mail address, VAT number and additional information (optional) that you can choose to provide us, such as: company name, your recipient code, your pec address and the reference code. When you download a trial version of software and/or related services or when you purchase a software license and/or related services, you are automatically added to our newsletter. The aim is to improve customer relations and the services we offer to improve the user’s overall experience, you can still unsubscribe from the newsletter at any time.

● When you sign up for our newsletter, we only store your e-mail address, we also store information on how you use the newsletter, for example if you read it or not. The purpose is to adapt and improve the way we treat our customers and our service.

● When you join the forum we only store your username and your e-mail address, we also store information on how you use the forum, for example if you frequent it or not. The purpose is to adapt and improve the way we treat our customers and our service.

Digital Atom SRL processes anonymous data in aggregate or non-aggregated form to analyze and produce statistics on user habits, methods and demographic information both as a group and as individuals. Such anonymous data does not allow identification of the users to whom they refer. Digital Atom SRL has the right to disclose anonymous data to third parties, both aggregated and non-aggregated.

Identifiable and browsing personal data
These are the data that uniquely identify a user, such as the name, e-mail address. For EU users, the term “personally identifiable data” is used with the meaning of “personal data” referred to in Article 2a of Directive 95/46 of 24 October 1995. Users may be required to provide personal data identifiable during the login process and in relation to the use of Digital Atom SRL products, services and online website. While Digital Atom SRL collects personally identifiable information on a voluntary basis, for some products and services the collection of personal data identifiable by Digital Atom SRL may be a requirement to access the product or service or to process a user’s order .

How we use your personal information
The personal information we collect is used to:

● Create and manage your Eyecad VR account.

● Send you important notices, such as notices regarding purchases and changes to terms, conditions and policies. Send you newsletters, offers and other news about the outgoing Eyecad VR products, firmware and software updates and upcoming events. If you don’t want to be on our mailing list, you can simply unsubscribe by clicking on the unsubscribe link at the bottom of the newsletter.

● Develop, provide and improve our products, services, content, advertising and communications to customers through internal audits, data analysis and search for personal data and preferences you have provided in relation to registration, purchase, lotteries , in contests or other promotional programs, if you participate in such events.

● Customize offers and marketing for you as a member, subscriber and customer through the analysis of characteristics, habits and behaviors based on the number of purchases, categories of purchases, interests, behavior on the website and in relation to the receipt of our digital marketing material.

● Comply with legal obligations, such as tax and accounting regulations.

Our processing is necessary for the fulfillment of our contractual obligations towards you as a customer and a member of Eyecad VR and to allow you to obtain the benefits indicated in our terms and conditions. If you do not wish to provide Digital Atom SRL with the information required to fulfill our contractual obligations to you as a customer, we will not be able to provide you with subscriptions, signing up, products and/or services. In some cases, Digital Atom SRL has the legal obligation to process your personal data, for example for accounting purposes. We treat your personal data pursuant to this legal obligation.

Digital Atom SRL uses identifiable personal data to develop, present and improve its products, content and services to which users have subscribed and to respond to user requests. Digital Atom SRL may use the personally identifiable information provided by users to send them information about Digital Atom SRL, including communications relating to product updates, events and other promotional material, but only if users agree to receive such information. Digital Atom SRL undertakes not to disclose any personally identifiable information to third parties for marketing purposes without the user’s consent.

Disclosure to third parties
Digital Atom SRL may disclose and share certain personal informations to strategic partners
who work with Digital Atom SRL to provide or improve Digital Atom SRL services and products, or that they help Digital Atom SRL to sell its services and products to customers.

During the registration on the website, to download a trial version of our products or to buy a software license and/or related services, a reference code may be required. The code of reference identifies one of our partners with whom we share your data in order to receive assistance from best sales and/or advantageous economic offers. If you don’t want your data to be shared with a external partner, then, do not enter any reference code, even if you received it from us (ad example in a newsletter). If you do not enter any reference code, your information will not be shared with external partner to the detriment of receiving advantageous economic offers (for example a retailer that applies a discount higher than our product price) or at the expense of a purchase and assistance experience different from expectations (for example due to language problems and linguistic interpretations).

Digital Atom SRL may disclose and share personal information with digital service providers, which is providing services such as information processing, tax evasion, customer orders, product delivery, management and enhancement of customer data, customer service, the evaluation of interest in products and services, accounting and performance of customer research or customer satisfaction surveys.
These companies are obliged to protect your personal information based on data processing agreements.
Digital Atom SRL could, by law, legal process or in case of dispute and / or requests by
public or governmental authorities within or outside your country of residence, having to disclose yours personal informations. We may also disclose informations about you for security reasons national law, law enforcement or other issues of public importance.
Finally, in case of reorganization, merger or sale, we may transfer all personal informations we collect to third parties will be used for the same purposes and according to the same terms and conditions outlined herein Privacy Policy.

Protection of personal information
Digital Atom SRL takes precautions, including administrative, technical and physical measures, to protect yours personal information from loss, theft and misuse, as well as against unauthorized access, disclosure, alteration and destruction.
When you use one or some of the products, services or applications of Digital Atom SRL or if you publish a post in the Eyecad VR forum, in a chat or in a social network, the personal information you share is visible to other users and can be read, collected or used by them. You are responsible for the information which you choose to insert in these cases. For example, if you put your name and e-mail address in a forum by discussion, this information will become public. Take all this into consideration before using these features and provide information about you.

Your rights
Digital Atom SRL allows you to have personal information always accurate, complete and updated, with simplicity. Upon request, Digital Atom SRL can correct your data. If certain events occur conditions, Digital Atom SRL will delete your data or limit its processing, upon request. Previa request, Digital Atom SRL also has the obligation to confirm if the personal data concerning you are subject to processing or not, as well as granting you access to processing information.
You are also entitled to receive the personal data you provide to Digital Atom SRL in a format that can be read by a computer device, of common and structured use, for example that allows to transfer such data to another data controller. We are required to accept your request regarding the aforementioned rights within one month. In some cases, this period can be extended by two months. All requests can be forwarded via e-mail to info@eyecadvr.com.
We will retain your personal information for five (5) years from the last contact. If you bought one of our products, we keep the personal data necessary during the useful life of the product and the period of warranty.
If you find a violation of your rights under the GDPR, you have the right to file a complaint
through the supervisory authority of your country of residence.

Websites and third-party services
The Digital Atom SRL websites, products, applications and services may contain links to websites, third-party products and services. Digital Atom SRL cannot be held responsible for the contents of said third-party websites and invites you to obtain information regarding the privacy policies of these last.

Transfer to third countries
Personal data may be transferred or viewed by entities within Digital Atom SRL or other companies in other countries for the purposes and as described in this Privacy Policy. Digital Atom SRL has affiliates in the following countries outside the EU / EEA: United States, Canada and Japan. Transfers to third countries are carried out in accordance with the provisions of Chapter V of the GDPR. Where necessary, Digital Atom SRL uses the standard data protection clauses adopted by the European Commission in order to ensure safe transfers to third countries.

Information on cookies
Digital Atom SRL uses cookies on its websites to improve the usability and experience of the user. Through the continued use of this site, the user provides Digital Atom SRL with the consent to store and use cookies. If you do not consent, you must access the settings of your browser to manage cookies or stop using this website.
A cookie is a small file that websites store on the user’s device to recognize the latter the next time they visit the site. The cookie file is passive and, therefore, it cannot spread viruses or harmful codes.
Digital Atom SRL uses the following cookies:
– KeepLoggedOnUser: cookie that detects if the user has selected “Remember me”, used to stay connected.

The products, services and websites of Digital Atom SRL may use cookies and other technologies such as “web beacons” and “pixel tags”. The use of cookies is usually linked to websites. For example, when the user accesses to Eyecad VR products and/or services, Digital Atom SRL stores the user ID and the link between the user’s IP address and the access time as a cookie on the user’s computer. This cookie allows the user to move from one page to another without having to login each time. Likewise, if the user provides informations during the session, for example data to verify age, they will be stored as cookies and the user will not have to provide them again during the session. Furthermore, Digital Atom SRL may use third-party analytical tools for the web that use cookies to collect certain not identifiable personal information regarding the use of websites, such as the addresses of the reference websites, the number of page views and the types of browsers.
However, users can disable cookies by changing their browser settings. Digital Atom SRL also stores a unique authorization code on the user’s computer or that is entered by the user or automatically downloaded during product registration and activation. The authorization code is used to identify an authorized user and allow access to Digital Atom SRL products and services, as well as software. The code is necessary to allow Digital Atom SRL to supply the products and services for which users have requested.

Information on the Eyecad VR billing procedure, the Eyecad VR user profile, the user’s Internet connection and the Digital Atom SRL software installed on the user’s computer are loaded on the server in connection with the use of Eyecad VR and Digital software Atom SRL from the user. The Eyecad VR software automatically generates a report on errors and is sent to Digital Atom SRL servers in the event of system crashes or other failures of the Digital Atom SRL software and services. The automatically generated error report file may include information about the user’s system software or hardware. Digital Atom SRL does not associate or store the information contained in the error report generated automatically with the identifiable personal data of the users. All information relating to the error report provided manually by users (for example, using Digital Atom SRL’s “bug reporter” module) is associated and stored with personal identification data sent voluntarily by the user through an error report.

Chat, forums etc…
Digital Atom SRL products and services may provide users with chat rooms, forums, message boards or instant messaging tools. All information published on chat rooms, forums and message boards is public domain considered and users who exchange messages may not know each other personally. Digital Atom SRL has no obligation to maintain the confidentiality of identifiable personal data that a user makes available to other users or to the public use of such functions. Users must pay attention if they decide to disclose their personal data in public forums. In addition, we inform users that the software information provided is information in the public domain that can be viewed by other users.

Opt-in / Opt-out
Digital Atom SRL offers users the possibility of receiving promotional e-mail messages from Digital Atom SRL. Users may choose not to receive such communications. Instructions on suspending Digital Atom SRL promotional e-mail messages will be provided in e-mails sent to users.

Storage and security of identifiable personal data
The identifiable personal data provided to Digital Atom SRL will be collected, processed and stored by Digital Atom SRL. Digital Atom SRL has adopted a series of fundamental measures to protect the information transmitted by users, including, but not limited to, the creation of processes, equipment and software to prevent unauthorized access or disclosure of such information.

Modification, updating and deletion of identifiable personal data
If you have doubts about the correctness of identifiable personal data stored by Digital Atom SRL or if you wish to review, modify or correct such data, or delete them from the Digital Atom SRL archive or deactivate them, contact Digital Atom SRL on www.eyecadvr.com . Digital Atom SRL may unreasonably refuse repetitive requests, which require considerable technical effort, which compromise the privacy of others or which are physically difficult.

More information
Digital Atom SRL may from time to time update its Privacy Policy without prior notice.

How to contact Digital Atom SRL
For any questions or complaints regarding this privacy statement or Digital Atom SRL’s privacy practices, contact Digital Atom SRL through the website www.eyecadvr.com. You can contact Digital Atom SRL at the address below:

Digital Atom SRL
Piazza Federico di Svevia
Siracusa, SR, 96100, Italy

Email address: info@eyecadvr.com
Telephone number: +39 0931 1756027 (available in English and Italian)

Revision date: November 12, 2019