Privacy Policy

Keliweb S.r.l. with registered office in Via Mario Cozza 7, Rende (CS – 87036), VAT number 03281320782 (hereinafter “Owner” or “Company” or “Keliweb”) is constantly committed to protecting the privacy of its users and customers. This document will allow you to know our privacy policy to understand how your Personal Data (as defined below) are managed when you use the Keliweb website (hereinafter the “Site”) and when you use our services (such as: registration of domain names, provision of email accounts, provision of hosting services, electronic billing service, provision of other services offered by Keliweb, hereinafter referred to as the “Services”) and to allow you, where appropriate, to give express and informed consent to the processing of your Personal Data. The information and data you provide or otherwise acquired in the context of using the Site or registering for the various Services will be processed in compliance with the provisions of EU Regulation 2016/679 (“Regulation”), of Legislative Decree 196/2003 and subsequent amendments (“Privacy Code”), of the applicable provisions issued by the Supervisory Authority and of the confidentiality obligations that inspire Keliweb's activity. According to the provisions of the Regulation and of the Privacy Code, the treatments carried out by Keliweb will be based on the principles of lawfulness, correctness, transparency, purpose limitation and retention, data minimization, accuracy, integrity and confidentiality.

We remind you that in the various sections of Keliweb Site, where we collect your Personal Data, specific information may be published pursuant to art. 13 of the Regulation for its necessary acknowledgment before providing the requested data.

Furthermore, in relation to some Services, Keliweb carries out additional and specific treatments described in the Appendix, in addition to what is indicated in this Privacy Policy.

INDEX

1. Data Controller and Personal Data Protection Officer
2. Personal Data being processed
3. Purpose and legal basis of the treatment. Nature of the contribution.
4. Recipients of Personal Data
5. Transfers of Personal Data
6. Storage of Personal Data
7. Rights of data subjects
8. Changes
9. Appendix

1. Data Controller and Personal Data Protection Officer

Keliweb operates as Data Controller of Personal Data. The Owner's structure is equipped with a data protection officer (Data Protection Officer or “DPO”). The DPO is available for any information concerning the processing of Personal Data performed by Keliweb. The DPO can be contacted by writing to: dpo@keliweb.it.

2. Personal Data being processed

By processing of Personal Data we mean any operation or set of operations, performed 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, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction.

In particular, the personal information processed by Keliweb consists, also depending on its decisions on how to use the Site and the Services, from the following categories (“Personal Data”):

• Identification and personal data, such as name and surname, tax code, date and municipality of birth and any company to which they belong and VAT number;
• Contact details, such as e-mail address, telephone number, postal address and fax, if any;
• Eventuali ulteriori dati di fatturazione non ricompresi in quelli sopra elencati e dettagli di pagamento in relazione ai Servizi acquistati che possono variare a seconda del metodo di pagamento selezionato (e.g. pagamento con carta di credito, bonifico, PayPal), quali l'importo da lei pagato, il buon esito della transazione, alcune informazioni sulla carta di credito da lei eventualmente utilizzata per effettuare il pagamento;
• Informazioni raccolte tramite i cookie (e le sue preferenze rispetto all'utilizzo dei Cookies), rispetto ai quali si rimanda all'Informativa sui Cookie.

Furthermore, in the use of some Services (for example, in the event of assignment of domain names in favor of third parties, in the context of the use of the electronic invoicing system or on the occasion of the exchange of e-mails or messages with our operators), the Personal Data of third parties transmitted by you to Keliweb could be processed. In such cases, you act as an independent Data Controller, assuming all legal obligations and responsibilities. In this sense, you grant the widest indemnity on this point with respect to any objection, claim, request for compensation for damage from treatment, etc. that should reach Keliweb from third parties whose Personal Data have been processed through its use of the Services in violation of the applicable Personal Data protection regulations. In any case, if you provide or otherwise process Personal Data of third parties in the use of the Service, you guarantee from now on - assuming all connected responsibility - that this particular hypothesis of treatment is based on an appropriate legal basis (for example, the consent of the interested party) pursuant to art. 6 of the Regulation which legitimizes the processing of the information in question.

In the context of certain Services and / or for the pursuit of some specific purposes, further and different categories of Personal Data may also be processed with respect to those listed above, as better specified below.

3. Purpose and legal basis of the treatment. Nature of the contribution.

The treatment we intend to carry out has the following purposes:

1. Provision of the Services and management of the contractual relationship – Allow the provision of the Services requested by you and the subsequent and autonomous management of your personal account, which you can access by registering and creating your user profile that will be issued to you for the purpose of providing the Services, including the collection, storage and processing of data for the purpose of establishing and subsequent operational, technical and administrative management of the relationship connected to the provision of the Services and the making of communications relating to the performance of the established relationship;
2. Management of contact / assistance requests – Responding to requests for information or contact transmitted through the “Contact” area of ​​the Site or to requests for assistance or support in relation to the Services provided by us that we may receive via email, telephone, or by opening assistance tickets within your personal account;

The legal basis for the processing of Personal Data for the purposes referred to in letters (a) and (b) above is art. 6(1)(b) of the Regulations as the treatments are necessary for the provision of the Services requested by you. The provision of Personal Data for these purposes is optional but failure to provide it would make it impossible to activate and provide you with the Services requested or to respond to your requests for assistance or information.

3. Newsletter – Sending you the Keliweb newsletter via e-mail, which includes advertising, informative material and commercial and promotional information relating to Keliweb products and services. If you are a registered user and have requested our newsletter, you can also consult it within your personal account (hereinafter this activity will be referred to as the “Newsletter”). The legal basis of this treatment is based on the release of your consent pursuant to art. 6(1)(a) of the Regulation, provided by filling in the form dedicated to requesting our Newsletter or by means of specific ticks or check boxes.
4. Fulfillment of legal obligations – Fulfilling legal, accounting and tax obligations. This treatment is legitimate pursuant to art. 6(1)(c) of the Regulation. Once the Personal Data has been provided, the processing may be necessary to fulfill legal obligations to which Keliweb is subject; it is not possible to refuse the provision of Personal Data for this purpose, since it is a treatment deriving from legal obligations.
5. Marketing – Sending you advertising material, commercial and promotional information relating to Keliweb products and Services, as well as carry out market research or contact you to get your opinion on our Services. The Marketing activity can be carried out via email, via SMS, telephone contact by one of our operators or within your personal account (in case you are a Keliweb customer). The processing of your Personal Data for Marketing purposes is based on the release of your consent pursuant to art. 6(1)(a) of the Regulation. You can revoke your consent to the processing of your Personal Data for Marketing purposes within your personal account, or through the link in the footer of the e-mails received, or according to the other methods indicated in the “Rights of the interested party” section. The withdrawal of your consent to this treatment has no consequence on the use of the Services and on the navigation of the Site. Furthermore, we specify that, by subscribing to the Company's Telegram channel, you express your desire to receive, through this channel, information on Keliweb's offers and promotions and to stay more generally updated on the activities carried out by the Company. We also point out that, if you are a user of Facebook and/or Instagram, you may receive promotional messages on your profile as better described below in the section of the Appendix relating to Social Media Channels.
6. Personalized promotional activities – Sending you, according to the methods indicated for the performance of Marketing activities (see section 3 (e)), personalized commercial proposals based on the Services you have purchased or on the basis of the customer group to which you belong (for example, Keliweb could offer you other Services to complete or support those already purchased). This type of analysis is typically carried out, without the use of cookies, on purchase data relating to both natural and legal persons. This means, for example, that based on the Service you are using, you may receive pertinent communications from Keliweb (for example, if the capacity of the Service is reaching its limit, you will be notified and invited to increase the capacity of the Service itself or complementary and/or compatible services may be offered to you with the one you have purchased). This treatment is necessary for the pursuit of the legitimate interest of the Data Controller to personalize its commercial proposals, pursuant to art. 6(1)(f) of the Regulation, and on the basis of a balance of interests performed by the Data Controller following which we believe that Keliweb's interest in carrying out this treatment is not detrimental to its fundamental rights and freedoms. The sending of such communications is in any case always subject to the consent you express to receive communications for marketing purposes.
7. Soft-spam – Carrying out direct marketing via email for services similar to those subscribed to by you, unless you have opposed this processing initially or on the occasion of subsequent communications, for the pursuit of Keliweb's legitimate interest in promoting products or services in which you may reasonably be interested (hereinafter the activities indicated here will be referred to as soft-spam activities); his treatment finds its prerequisite of lawfulness in the art. 130 co. 4 of the Privacy Code: “if the data controller uses, for the purpose of direct sale of his products or services, the e-mail coordinates provided by the interested party in the context of the sale of a product or service, he may not request the consent of the interested party, provided that the services are similar to those being sold and the interested party, adequately informed, does not refuse such use, initially or on the occasion of subsequent communications. The interested party, at the time of collection and on the occasion of sending each communication made for the purposes referred to in this paragraph, is informed of the possibility of opposing the treatment at any time, easily and free of charge”. Opposition to this treatment has no consequence on the use of the Services and you can exercise it by writing an email to privacy@keliweb.it or using the “unsubscribe” functions present in the emails that will be sent to you.
8. Verification of your level of satisfaction – Collecting your opinion with respect to the assistance activities provided by Keliweb or with respect to the Services and products supplied by us in order to improve and develop them. This activity can be carried out through contacts by email / SMS / telephone contact only if you have given your consent for marketing purposes. Furthermore, again in the event that you have given your consent for Marketing purposes, Keliweb may invite you to write a review on Trustpilot. On this point, we specify that the Data Controller of your Personal Data associated with the Trustpilot platform (such as, for example, the information you provide when creating an account or when you leave a review or post a reply) is Trustpilot A/S (for more information on the treatments carried out by Trustpilot A/S, you can consult the related privacy policy available at the following link: https://it.legal.trustpilot.com/for-reviewers/end-user-privacy-terms). Otherwise, the assessment of the assistance service that you can carry out when closing the ticket by casting your vote by marking from 1 to 5 “stars”, is based on the legitimate interest of the Company pursuant to art. 6(1)(f) of the Regulation which deems this treatment not harmful to its rights and interests, it being understood that it is a faculty, being able to freely decide not to express any vote (by clicking on “Back to the list of tickets”). Equally, you will be able to share your assessment with the Company with respect to the Service you have purchased, also within dedicated areas present within the interface you use to access the Service you have purchased. Even these assessments, which may be released by you on a completely voluntary basis, will be examined and processed on the basis of the legitimate interest of the Company pursuant to art. 6(1)(f) of the Regulation.
9. Verification of the quality and effectiveness of online advertising campaigns – Carrying out analysis activities by tracking through the use of cookies and other similar tools, aimed at verifying and measuring the quality and effectiveness of Keliweb's online advertising campaigns (e.g., how many users who landed on the Keliweb site and purchased Services actually came from marketing campaigns carried out through Facebook, Instagram and so on), in order to improve the performance of these campaigns, as well as the Services offered by Keliweb. The legal basis of this treatment is the Company's legitimate interest in improving its campaigns and Services, pursuant to art. 6(1)(f) of the Regulation. It should be noted that this activity is carried out by Keliweb and Register S.p.A. (as companies part of the same corporate group) as joint data controllers, by virtue of a joint data controller agreement stipulated between them pursuant to art. 26 of the Regulation. Through this agreement, the parties have defined their respective obligations with reference (among other things) to the purposes and methods of the processing in question and the related conditions of lawfulness, the procedures to be followed in order to provide you with a timely response in the event that you intend to exercise a right granted to you by the Regulation and the respective responsibilities in the event that Keliweb or Register S.p.A. should suffer a security incident involving the breach of your Personal Data. To receive further information on the co-ownership agreement, you can send a request to dpo@keliweb.it. Likewise, you can exercise your rights with respect to the processing in question by contacting Keliweb directly according to the methods indicated in the “Rights of the interested parties” section, having the right to exercise them against each of the joint data controllers.
10. Security and prevention of fraudulent conduct – For the exclusive purposes of security and prevention of fraudulent conduct, on the basis of a legitimate interest of Keliweb to prevent fraud and scams committed to its detriment or to the detriment of its customers, pursuant to art. 6(1)(f) of the Regulation and on the basis of both Recital 47 of the Regulation, which expressly provides that it is “legitimate interest of the data controller concerned to process personal data strictly necessary for fraud prevention purposes”, as well as on the basis of various balancing of interests carried out by the Data Controller from which it does not appear that the processing in question is harmful to his fundamental rights and freedoms. In particular, activities of this type include:
    1. An automatic control system, also implemented through the use of cookies and other similar tracking tools, which involves the detection and analysis of some user behavior on the Site, associated with their IP addresses and other Personal Data associated with navigation. The consequences of this treatment are that if a person tries to engage in fraudulent conduct on the Site, for example to benefit several times from the same promotion without being entitled to it, Keliweb reserves the right to exclude this person from the promotion or to adopt any other appropriate measure for its own protection. It should be noted that this activity is carried out by Keliweb and Register S.p.A. (as companies part of the same corporate group) as joint data controllers, by virtue of a joint data controller agreement stipulated between them pursuant to art. 26 of the Regulation. Through this agreement, the parties have defined their respective obligations with reference (among other things) to the purposes and methods of the processing in question and the related conditions of lawfulness, the procedures to be followed in order to provide you with a timely response in the event that you intend to exercise a right granted to you by the Regulation and the respective responsibilities in the event that Keliweb or Register S.p.A. should suffer a security incident involving the breach of your Personal Data. To receive further information on the co-ownership agreement, you can send a request to dpo@keliweb.it. Likewise, you can exercise your rights with respect to the processing in question by contacting Keliweb directly according to the methods indicated in the “Rights of the interested parties” section, having the right to exercise them against each of the joint data controllers.
    2. A real-time payment anti-fraud verification system, when a purchase is made on the Site: this processing consists in the communication of some Personal Data (specifically name, surname, email address, postal address and country from which the connection is detected, IP address) to the company specialized in anti-fraud services MaxMind Inc., which assigns a fraud score to the transaction based on the automated processing of the Personal Data communicated by the Company. The scoring is carried out using a machine learning algorithm which formulates an assessment of the fraudulence risk of each transaction; more details on how the algorithm works are available here. Based on the value of the score assigned, if this exceeds a certain threshold, the transaction is refused and reported as “fraudulent” and subjected to an internal check by authorized personnel. In order to proceed with the verification of the transaction and the identity of the customer concerned, Keliweb will proceed to ask the customer for a photo together with an identification document suitable for this verification. In the event of a positive outcome of this assessment, Keliweb will proceed to activate the requested Services. On the contrary, the negative outcome of the checks will make it impossible to carry out the transaction and the interested party will be able to obtain an explanation or contest the decision by giving reasons to the Customer Assistance service.
    3. The Data Controller, in line with the provisions of Recital 49 of the GDPR, processes, also through its suppliers (third parties and/or recipients), the Personal Data of the interested party relating to traffic to a strictly necessary and proportionate extent to guarantee network and information security, i.e. the ability of a network or an information system to resist, at a given level of security, unforeseen events or unlawful or malicious acts that compromise the availability, authenticity, integrity and confidentiality of Personal Data stored or transmitted.
11. Analisi dei profili aziendali dei visitatori del Sito – Keliweb utilizza un servizio fornito da Leadinfo B.V. che consente di rilevare, tramite cookie, le visite delle aziende nel nostro Sito in base agli indirizzi IP dei visitatori e ci mostra le relative informazioni disponibili al pubblico (e.g., nomi e indirizzi delle aziende). Si precisa che la raccolta dell’indirizzo IP verrà effettuata solo nel caso in cui lei abbia prestato il suo consenso espresso all’uso di tecnologie traccianti, richiesto alla visita del nostro Sito. Si precisa inoltre che ogni ulteriore trattamento svolto da Leadinfo verrà effettuato dallo stesso in qualità di autonomo titolare del trattamento secondo quanto indicato nella relativa Informativa sulla privacy disponibile sul sito di Leadinfo: https://www.leadinfo.com/en/. Precisiamo inoltre che, alla pagina, www.leadinfo.com/en/opt-out, lei potrà opporsi alla raccolta dei suoi dati personali da parte di Leadinfo (sulla base del legittimo interesse dello stesso) con la conseguenza che, in caso di opposizione, i suoi dati personali non verranno più utilizzati per compilare profili dei visitatori dei siti web delle aziende clienti di Leadinfo (tra cui Keliweb).

Oltre a quanto sopra, le precisiamo che, al fine di consentirle di perfezionare i pagamenti tramite il Sito e/o la sua area riservata, Keliweb fa uso di servizi di pagamento forniti da piattaforme terze che potrebbero a loro volta raccogliere ed elaborare alcune sue informazioni personali per finalità proprie (e quindi in qualità di Titolari autonomi rispetto a Keliweb). In particolare, Stripe (quale piattaforma utilizzata da Keliweb al fine di gestire i pagamenti da lei effettuati mediante carta di credito) potrà a sua volta raccogliere ed elaborare alcuni dei suoi dati personali (e.g., dati transazionali, informazioni relative al dispositivo tramite il quale lei si connette ai servizi di Stripe) per gestire e migliorare i servizi che ci fornisce, oltre che per il rilevamento e la prevenzione delle frodi. Per saperne di più su Stripe e sulle attività di trattamento da questo svolte, la invitiamo a consultare l'informativa sulla privacy di Stripe all'indirizzo https://stripe.com/privacy.

4. Recipients of Personal Data

Your Personal Data may be shared with the following subjects (collectively “Recipients”), for the purposes referred to in section 3 above, with:

1. Persons authorized by Keliweb to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality, such as Keliweb employees;
2. Persons, companies or professional firms that provide assistance and consultancy to Keliweb in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services;
3. Subjects with whom it is necessary to interact for the provision of the Services, such as subjects who provide the payment service, subjects delegated to carry out technical maintenance activities or service providers connected to and/or in support of the Services provided by Keliweb (such as, for example, IT and communication service providers);
4. Register S.p.A. and other companies of the team.blue Group of which Keliweb is a part, Italian or foreign;
5. MaxMind Inc., a company specializing in anti-fraud services, for the purpose indicated in section 3(j)(ii);
6. Facebook per le attività di Marketing indicate alla sezione 3(e), come meglio descritte nell'Appendice realtiva ai Canali Social Media;
7. Leadinfo B.V. per le attività di analisi dei profili aziendali dei visitatori del Sito descritte alla sezione 3(k) che precede;
8. Subjects, bodies or authorities to whom it is mandatory to communicate your Personal Data by virtue of provisions of the law or orders of the authorities (for example, during criminal investigations, Keliweb may receive requests from the judicial authority to provide information on your account and on the data acquired by Keliweb in the provision of its Services).

The complete list of data processors is available by sending a request to privacy@keliweb.it.

5. Transfers of Personal Data

Some of your Personal Data is shared with Recipients who could be found outside the European Economic Area. Keliweb ensures that the processing of your Personal Data by these Recipients takes place in compliance with the Regulation. Indeed, transfers may be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission. More information is available by writing to privacy@keliweb.it.

6. Storage of Personal Data

Your Personal Data will be stored according to the following storage criteria:

• Personal Data processed for the purposes referred to in section 3(a) (Provision of Services and management of the contractual relationship) and (b) (Management of contact / assistance requests) will be kept for the time strictly necessary to achieve the indicated purposes. Furthermore, since these are treatments carried out for the provision of Services, Keliweb will be able to keep Personal Data up to the time allowed by the Italian legislation to protect its interests (Article 2946 of the Italian Civil Code and subsequent amendments), in particular it will keep the data necessary to demonstrate that it has correctly fulfilled its contractual obligations for the duration that the legislation provides, in general, for the prescription of the action for breach of contract.
• Personal Data processed for the purposes referred to in section 3(d) (Fulfillment of legal obligations) will instead be kept for the time required by the specific obligation or applicable law. By way of example, invoices and other documents of a fiscal nature will be kept for ten years.
• For the purposes referred to in sections 3(c)(Newsletter) and (e) (Marketing), your Personal Data will be processed for this purpose until your consent is revoked. Also in this case, the possibility for Keliweb to keep your Personal Data is reserved in any case, and in particular the evidence of your possible expression and revocation of consent, up to the time allowed by Italian law to protect your interests.
• For the purpose referred to in section 3(f) (Personalized promotional activities), the retention times of your data are equivalent to the retention times of data processed for Marketing purposes.
• For the purpose referred to in section 3(g)(Soft-spam), your Personal Data will be processed until you object to such processing;
• For the purpose referred to in section 3(h) (Checking your level of satisfaction), your Personal Data will be processed for a duration equal to the provision of the Services you requested;
• For the purposes referred to in section 3(i) (Verifying the quality and effectiveness of online advertising campaigns), or to measure the effectiveness and quality of Keliweb's advertising campaigns, your Personal Data will be processed for 25 months from collection;
• For the purposes referred to in section 3(j) (Security and prevention of fraudulent conduct), Keliweb will process Personal Data up to the time allowed by Italian legislation to protect its interests (Article 2946 of the Italian Civil Code and subsequent amendments). With particular reference to the purpose referred to in section 3(j)(i), the data are kept for the time necessary for the Company to be able to prevent and combat fraudulent conduct carried out through the Site, such as, for example, benefiting from the same promotion several times without being entitled to it.
• Gli indirizzi IP (aziendali) raccolti per la finalità di cui alla sezione 3(k) (Analisi dei profili aziendali dei visitatori del Sito) e i profili aziendali associati a tali indirizzi IP sono conservati per un massimo di tre anni dalla loro raccolta.

More information about the data retention periods and the criteria used to determine these periods can be requested by writing to privacy@keliweb.it.

7. Rights of data subjects

You have the right to ask the Company, at any time, for access to your Personal Data, the rectification or cancellation of the same, you have the right to request the limitation of treatment in the cases provided for by art. 18 of the Regulation, as well as to obtain the Personal Data concerning you in a structured format, commonly used and readable by automatic device, in the cases provided for by art. 20 of the Regulation.

You also have the right to oppose the processing of your Personal Data at any time if this is based on legitimate interest, or if the processing takes place for commercial promotion activities in accordance with the provisions of article 21 of the Regulation.

To exercise your rights, you can contact the Company by sending an email to: privacy@keliweb.it

In any case, you always have the right to lodge a complaint with the competent supervisory authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to the legislation in force, or to take the appropriate judicial offices (art. 79 of the Regulation).

8. Changes

This Privacy Policy is effective from 29/07/2023. Keliweb reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. If the changes to this Privacy Policy concern substantial changes in the treatments or may in any case have a significant impact on the interested parties, Keliweb will take care to appropriately notify the interested parties.

---

Appendix

The Privacy Policy describes the processing that Keliweb carries out when you use the Site or when you use our Services. This Appendix integrates the Privacy Policy in order to illustrate the information we collect and the further specific processing we carry out in relation to the services identified below. For anything not specifically regulated in this Appendix (with reference, for example, to the contact details of the “Data Controller and Personal Data Protection Officer” and the management of the “Rights of interested parties”) it is possible to refer to to the Privacy Policy.

Domain name management

Roles and responsibilities in the processing of domain name registration data.
A domain name (often called simply a “domain”) is a name associated with an IP address on the Internet. A domain is composed of several parts, one of which is the extension, also called top-level domain (“TLD”), or the part of the domain that follows the dot.

The classification of TLDs includes two types:

• Tgeneric TLDs (generic top-level domain or “gTLD”): for example .com, .org, .info, .biz ecc., which have an international diffusion;
• National TLDs (country code top-level domain or “ccTLD”): these are domains referring to a country. For example, the ccTLD for Italy is .it.

Three different subjects are involved in the process of registering a domain name: Registry, Registrar and Registrant.

• The term “Registry” refers to a national or international body responsible for establishing rules and procedures for the assignment of domain names, the management of registers and the primary nameservers of the various TLDs. The complete list of Registries and related policies can be consulted at this link: https://www.iana.org/domains/root/db.
• The term “Registrar” identifies an organization authorized by the Registry to carry out operations on the domains of the TLD for which it has accreditation. It is possible to verify the Registrar of a gTLD domain name by accessing the ICANN service available on this page: https://lookup.icann.org/. To verify the Registrar of a ccTLD domain, it is possible to identify the web address of the relevant Registry of interest on the page https://www.iana.org/domains/root/db where you will find the whois/RDAP search service of the single Registry.
• Finally, the “Registrant” is the natural or legal person who registers a domain name.

Keliweb acts as Registrar for the ccTLD .it as a subject authorized by NIC.it (or Registro.it). If you request the registration of extensions other than .it (with respect to which Keliweb has no accreditation), the registration will be intermediated by other accredited subjects for the registration of these domain names with the competent Registry from time to time.

In practice, for the registration of a domain name, the Registrant will present his request to Keliweb which, in turn, will forward the request to the reference Registry or to accredited subjects for the registration of domain names with reference to extensions for which Keliweb is without accreditation. In the event that the evaluation carried out by the reference Registry on the conditions for registration is successful, the domain name will be registered and made out to the Registrant who will become the assignee and will be able to claim the rights according to the applicable legislation and for the times indicated in the contract of service subscribed.

Following the registration of a domain name with the gTLD extension, the Personal Data relating to the assignee of the domain name in question will usually be published, and therefore disseminated, within the public WHOIS/RDAP database and can be consulted on the Registration data lookup tool (https://lookup.icann.org/en) made available by ICANN for domain names with the gTLD extension.

Domain names with the ccTLD extension may be published on the WHOIS databases managed by the relevant Registries, based on the policies of each Registry.

Keliweb typically qualifies as Data Controller with regard to the processing of data relating to the registration and management of domain names. The privacy role of Keliweb, however, depends on the Registry competent from time to time for the gTLD or ccTLD for which registration is requested. For example, for the ccTLD .it, the competent Registry (NIC.it/Registro.it) plays the role of independent data controller and qualifies Keliweb as data processor, based on the non-negotiable provisions of the contract, which can be freely consulted here online, which Keliweb is required to stipulate with the aforementioned Authority. This means that as regards the processing activities connected to the management of the .it extensions (and all the other extensions for which the competent Registry places Keliweb as data processor), the information relating to the processing and the requests to exercise the rights of the interested parties (see section 7 of the Privacy Policy) must be addressed to the Registry competent from time to time for the extension that is intended to be registered.

Furthermore, in the event that, for the purpose of registering a domain name, it is also required to provide additional Personal Data relating to third parties (such as, by way of example and not limited to, the contact details of the administrative manager - the so-called “Admin-C” – and technical – so-called “Tech-C” – of a specific domain name), Keliweb typically acts as data controller with reference to such Personal Data. In this case, you act as an independent data controller, assuming all legal obligations and responsibilities. In this sense, you grant the widest indemnity on this point with respect to any objection, claim, request for compensation for damage from treatment, etc. that should reach Keliweb from such third parties whose data have been processed in violation of the regulations on the protection of applicable Personal Data. In any case, if you provide Personal Data of third parties as part of the registration of a domain name, you guarantee from now on - assuming all related responsibility - that this particular hypothesis of treatment is based on an appropriate legal basis pursuant to the art. 6 or 49(c) of the Regulation which legitimizes the processing of the data in question.

The personal data being processed.
As regards the processing of Personal Data carried out as part of the domain name registration service, it should be noted that Keliweb will only implement the processing strictly necessary to provide the service and for the billing and accounting management of the domain name, except further processing on the basis of an appropriate legal basis pursuant to art. 6 of the Regulation (for example your consent). The data collected by Keliweb as part of the domain name registration request are only those strictly necessary for the provision of the service, provided by the interested party himself during the domain name registration phase. In some specific cases, Keliweb may request a copy of the identity document where required by the reference Registry, in particular in the event that particularly delicate operations are requested, such as requests for cancellation of a domain name or requests for change of assignee.

Purpose of the treatment.
The treatments carried out by Keliweb are based on principles of correctness, lawfulness, transparency and protection of the privacy of the interested party.

The information and data you provide are used exclusively:

• for domain name registration and management purposes, which involves verifying the data provided for the registration, billing and accounting management of the domain name, assistance and support in management, ancillary operations such as requests for cancellation , transfer or change of owner, as well as the communication of important information on the renewal of the domain (“Provision of the Service”);
• for purposes of security and prevention of fraudulent conduct (“Combating Abuse and Fraud”);
• to fulfill legal obligations, in particular those deriving from the legislation in force regarding the registration of domain names (“Compliance”);
• to communicate the data necessary for registration to independent third party data controllers, such as, for example, the Registries competent from time to time for the extension to be registered (“Communication of data to independent third party data controllers”);
• to protect the industrial property rights of third parties or to verify reports of abuses allegedly committed by you to the detriment of third parties, for example for the protection of industrial property rights (“Protection of the legitimate interest of third parties”).

Legal basis of the processing and nature of the provision.
Processing for the purpose of providing the service and communicating data to independent third party owners is necessary in order to execute the service contract between you and Keliweb, pursuant to art. 6(1)(b) of the Regulation. The provision of such data is in itself optional; however, in the absence of this provision, Keliweb will not be able to provide the requested service.

The treatment for the purpose of Contrasting Abuses and Frauds is based on Keliweb's legitimate interest in preventing frauds and scams committed against it or against its customers, pursuant to art. 6(1)(f) of the Regulation and on the basis of Recital 47 of the Regulation.

Processing for the purpose of protecting the legitimate interest of third parties is based on the legitimate interest of such third parties to protect their rights, such as industrial property rights, or in the case of abuses presumably committed by you to the detriment of such third parts. This processing activity is legitimate pursuant to art. 6(1)(f) of the Regulation.

Processing for Compliance purposes is legitimate pursuant to art. 6(1)(c) of the Regulation. Once the personal data have been provided, the processing may indeed be necessary to fulfill legal obligations to which Keliweb is subject. It is not possible to oppose this treatment, since it is a treatment deriving from legal obligations.

Recipients of personal data.
The Personal Data of the domain name holder (as well as of third parties such as Admin-C and Tech-C, where required from time to time for the registration of the specific domain name by the reference Registry), for purposes strictly related to the provision of the service, may be communicated to third parties who act as independent data controllers. In particular, the data will be communicated to the national and foreign Registries to which Keliweb is required to transmit the technical and administrative documentation required by sector legislation, as well as to any other subjects accredited for the registration of domain names with reference to extensions for which Keliweb is uncredited. The latter subjects typically act as data processors on behalf of Keliweb.

The sharing of data with independent third party owners is necessary for the Provision of the Service and finds its legal basis in the art. 6(1)(b) of the Regulation. The Registries will process the data of the Registrants to keep the register of domain names updated and to ensure compliance with the relevant applicable laws and policies. We invite you to consult the privacy information issued by the relevant Registry from time to time. Keliweb may be required to communicate your personal data to the Internet Corporation for Assigned Names and Numbers (hereinafter, “ICANN”), in order to comply with ICANN policies and procedures. ICANN also requires Keliweb, as Registrar, to deposit a copy of the data necessary for the management of the domain names in escrow with an accredited Escrow Agent. Keliweb uses for this service the company NCC Group Software Resilience (NA) LLC (hereinafter, “NCC”), based in the United States, designated by ICANN.

It should be noted that, for gTLD extensions, and in some cases also for ccTLD extensions where permitted or imposed by the competent Registry, Keliweb may be required to communicate your data to third parties for the purpose of Contrasting Abuse and Fraud, on the basis of the art. 4 of the ICANN Temporary Specification for gTLD Registration Data, available at this link https://www.icann.org/resources/pages/gtld-registration-data-specs-en/#4 or, for ccTLDs, on the basis of policy from time to time imposed by the competent Registry.

Keliweb could also communicate personal data relating to a domain name to third parties on the basis of their own legitimate interest, upon their express and detailed request, for the purpose of protecting their rights (including industrial property rights), for of Protection of the legitimate interest of third parties.

Transfer of personal data.
As part of the domain name registration services, the data is communicated to the subjects listed in the “Recipients of personal data” section above, who could be found outside the European Economic Area (“EEA”), such as example ICANN and NCC, the Registry of the country of reference of the ccTLD or gTLD to be registered. Keliweb ensures that the processing of your Personal Data by these Recipients takes place in compliance with the Regulation.

The legal basis of the aforementioned transfers to the competent Registries from time to time is art. 49(1)(b) of the Regulation and art. 49(1)(c) of the Regulation, as the transfer outside the EEA is necessary for the execution of the contract concluded between the interested party and the owner, or between the owner and a third party in favor of the interested party.

As regards the transfer of data to NCC in the context of the registration of the gTLDs, or in case of use by Keliweb of third party Registrars for the registration of some gTLD extensions, the transfer takes place on the basis of the Standard Contractual Clauses approved by the European Commission, pursuant to art. 46 of the Regulation.

More information is available by writing to dpo@keliweb.it.

Data Retention.
The Personal Data processed for the purposes of providing the Service and communicating the data to independent third party owners will be kept for the time strictly necessary to achieve the indicated purposes. Furthermore, since these are treatments carried out for the provision of the domain name registration and management service, Keliweb will process the Personal Data up to the time allowed by the Italian legislation to protect its interests (Article 2946 of the Italian Civil Code and subsequent amendments). In particular, it will keep the data necessary to demonstrate that it has correctly fulfilled its contractual obligations for the duration that the legislation provides, in general, for the prescription of the action for breach of contract.

For Compliance purposes, Personal Data will instead be kept until the time required by the specific obligation or applicable law.

For the purposes of Contrasting Abuse and Fraud and Protection of the legitimate interest of third parties Personal Data will be kept for the time necessary for Keliweb to be able to prevent and combat fraudulent conduct and to protect the legitimate interest of third parties, i.e. for 10 years.

Further information regarding the retention periods of Personal Data and the criteria used to determine these periods can be requested by writing to the Data Controller or the DPO.

Hosting

If you have purchased a hosting service, the Company reserves the right to carry out checks on its use. In particular, if a massive and unauthorized sending of emails is detected, the Company will proceed to block (automatically) the sending of such communications and subsequently contact it in order to verify if there are any illegal uses of the service and thus guarantee the security of the own systems. This purpose is based on Keliweb's legitimate interest in preventing fraud and scams committed to its detriment or to the detriment of its customers, pursuant to art. 6 (1) (f) of the Regulation and on the basis of both Recital 47 of the Regulation.

Email

Affiliate Program

In the event that you have joined the Affiliate Program, Keliweb will also process your Personal Data in order to fulfill the contractual obligations assumed between the parties as a result of your joining the Affiliate Program. In addition to the identification and contact data indicated in the Privacy Policy, in order to pay any commission you may have accrued according to the conditions and methods set out in the applicable terms, Keliweb will also process your IBAN address or the email address associated with the your PayPal account in order to be able to complete the payment of the amount due according to the method you have chosen. This processing finds its legal basis in Article 6(1)(b) of the Regulations as it is carried out in order to be able to fulfill the contractual obligations established by the Affiliate Program.

Social Media Channels

Keliweb uses some social channels (Instagram, Threads, LinkedIn, Twitter and Facebook) for communication purposes and, in particular, to publish content relating to the activities carried out and the Services offered by the Company, as well as to interact and communicate with users who are interested in the Company profile. Each social channel has its own policy on how it treats the personal data of its users. Keliweb therefore invites you to consult the privacy information made available by the managers of the various social networks when accessing their platforms and interacting with the Company's pages and social profiles.

At the same time, Keliweb informs you of the following in order to allow you a more aware management of your interactions with Keliweb through social channels:

• Sending updates – If you are a user of one (or more) of the social channels used by the Company, you will be able to receive notifications and communications relating to the activities carried out by Keliweb on your pages. For example, if you have decided to follow Keliweb's LinkedIn page, you will be able to receive notifications relating to posts published by Keliweb on your page. Depending on the preferences you set on your account, you may receive these notifications:
  • within the app;
  • push (i.e. sent to your device);
  • to the e-mail address associated with the account you created on these platforms.
  In order to manage and customize the receipt of these notifications according to your preferences, we invite you to use the settings made available by the social platforms themselves (for example, if you wish to receive more information on how to manage the settings relating to LinkedIn notifications, please consult the following page: https://www.linkedin.com/help/linkedin/answer/a526130/attivazione-e-disattivazione-delle-notifiche-email-e-su-dispositivi-mobili?lang=it).
• Marketing – If you are a Facebook and/or Instagram user, you may receive personalized promotional messages on your profile based on Keliweb's use of the targeting features made available by Facebook. Keliweb uses these features in order to sponsor its posts and promotional content to bring them to the attention of certain segments of Facebook users (for example, if you have browsed our site to search for information on certain services, you will be able to view promotional messages from Keliweb on the his social profile). This treatment will be carried out only if you have given your express consent to the use of tracking technologies, when requested when visiting our site. It should also be noted that in the context of these activities, Keliweb and Facebook act as joint controllers of the treatment and that the related joint controller agreement is available on the following page: https://www.facebook.com/legal/controller_addendum. For more information on the treatments carried out by Facebook, including the conditions of lawfulness identified by them and the methods made available to the interested parties for the exercise of their rights, it is possible to consult the related Facebook privacy policy available at the following link: https://www.facebook.com/policy.php.
• LinkedIn Newsletter – If you are a LinkedIn user, you can subscribe to our “Keli News”, the Keliweb newsletter which includes advertising material, information and commercial and promotional information relating to Keliweb products and services. In this case, the Newsletter will also be sent to the e-mail address associated with your LinkedIn account (for further information on the functioning of the Newsletter on LinkedIn, consult the following page: https://www.linkedin.com/help/linkedin/answer/a522525). The legal basis of this treatment is based on the release of your consent pursuant to art. 6(1)(a) of the Regulations, provided by selecting the appropriate “Subscribe” checkbox. You may subsequently revoke your consent to the processing of your Personal Data for this purpose at any time by unsubscribing from Keli News again using the appropriate functions made available by LinkedIn. We also specify that, even if you have not subscribed to Keli News (or have registered first and subsequently unsubscribed), you can continue to receive our Newsletter (referred to in section 3(c)(Newsletter ) of this Privacy Policy, as well as receiving the marketing communications referred to in section 3 (e) (Marketing)) in the case in which you have expressed your consent for these (separate) purposes.
• Surveys – Again through social channels, Keliweb could start surveys using the special features made available by social channels in order to know your opinion on certain issues. For example, Keliweb could start a survey via LinkedIn Polls to ask you what you think about certain topics. In the event that you decide to participate in these surveys, your vote (as well as the information you have made public on your LinkedIn profile) will be visible to Keliweb, while they will not be visible to other voters or to other LinkedIn users who will only be able to view the total aggregate responses as a percentage after the survey is closed. For more information on how your personal data is processed when you participate in a survey via LinkedIn, please consult the following page: https://www.linkedin.com/help/linkedin/answer/a527270. The legal basis of this treatment is based on the release of your consent pursuant to art. 6(1)(a) of the Regulation, provided by completing the survey.
• LinkedIn contact requests – When you interact with Keliweb's social profiles (e.g., because you subscribe to the LinkedIn Newsletter, when you interact with a post published by Keliweb on LinkedIn or on Instagram, when you reply to one of our surveys), Keliweb will be able view the information you have made public on your profile. In the event that Keliweb deems that your interests may be aligned with those of Keliweb (e.g., because you too work or work for a company that operates in an IT sector), Keliweb reserves the right to send you a contact request via LinkedIn so you can add it to your network of contacts. The Company believes it can base this treatment on the basis of the legitimate interest aimed at building a network of contacts on LinkedIn with people with whom Keliweb shares common interests; it is carried out pursuant to art. 6(1)(f) of the Regulation, and on the basis of a balance of interests performed by the Data Controller following which we believe that Keliweb's interest in carrying out this treatment is not detrimental to its fundamental rights and freedoms. You can of course object by replying to our message as well as by writing to: privacy@keliweb.it.

---

Useful links

Data portability

Privacy reports

---