Privacy - A-Fold

Privacy

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Introduction

A-FOLD houses is committed to respecting the privacy of your personal information. This Privacy Policy explains how we deal with your personal information that we collect or process.
We will update this Privacy Policy from time to time where we change how we deal with personal information. We will post any changes to the Privacy Policy on our website, and will endeavor to notify you when this occurs.
In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain collection channels. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

Definition of personal information

Throughout this Privacy Policy, we use the term ‘personal information’ to refer to information relating to an identified or identifiable natural person. For example, your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address, and workplace contact details are examples of information that may constitute personal information. Personal information may also include information we may collect about your individual preferences.

Problems, Complaints, or Queries

If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled, disclosed, and/or processed your personal information, please contact our privacy officer via one of the following channels: a.

Or, for individuals in the European Union, please contact our European Union Representative at: a.

On what basis do we process your data? Lawful basis of processing

A-FOLD houses will only collect, monitor, use, disclose, or process any personal information about you with your consent (including as provided in this Privacy Policy) or if it is otherwise lawful to do so. The only personal information collected by us is what has been provided to or collected by us in accordance with this Privacy Policy or has been provided to us lawfully by third parties. We will generally deal with your personal information for the primary purposes set out in this Privacy Policy.
For individuals in the European Union, A-FOLD houses relies on the lawful bases described below the purposes of the GDPR: a. For customers of A-FOLD houses, A-FOLD houses relies on the GDPR lawful bases of contract and legitimate interest. That is, A-FOLD houses will process your data because it is necessary for the performance of a contract or pre-contractual obligations with you, or because A-FOLD houses has a legitimate commercial interest in processing the personal information that is not outweighed by your interests, rights and freedoms. Specifically, this interest includes providing the A- FOLD houses Application to customers on a commercial basis.
A-FOLD houses may also request your explicit consent to process your personal data from time to time. A-FOLD houses also reserves the right to use, disclose or otherwise process any personal information to satisfy any law, regulation or legal request or in relation to A-FOLD houses other legitimate interests (such as where relevant to legal action relating to A-FOLD houses).

When and how do we collect personal information?

Collection Channels

We, or our subcontractors or agents, collect (and combine) personal information in a number of ways, which include: a. where personal information is actively provided to us, including but not limited to: i. where you provide us with personal information, such as through email, our website, upon downloading a mobile app provided by us, using a form or application, or another communication channel, and whether as a customer, prospective customer or any other role;
where you provide personal information to us when you sign up from an A-FOLD houses account; iii. where personal information about you is provided to A-FOLD houses; b. from customers or their clients, or other legitimate third party sources including list brokers and other data providers or organizations that share data in circumstances where it is lawful and/or you have given permission for them to do so. c. Through our website, including through the use of cookies and other tracking tools such as internet tags, tracking pixels, web beacons and unique device identifiers. For further information about the use of passive personal information collection, see below.

What kinds of personal information does A-FOLD houses collect?

We, or our subcontractors or agents, may collect personal information including: a. your full name, contact details (such as your phone numbers, email address, workplace address details and contact preferences), location, and passwords you create for A-FOLD houses; b. information about your preferences, interests, opinions, feedback and experiences with our products or services. This information is collected in order to tailor our communications to you and continuously improve our products and services; c. financial details, if you have provided them to us, such as your bank account, credit card, Paypal or other online payment system details (where you purchase any products or services from us); d. When you visit the A-FOLD houses website, we may also collect personal information about you in the following general categories: i. usage and preference information: we collect information about how you interact with the A-FOLD houses website, including the pages you visit, your preferences and settings that you choose. We may do this through the use of cookies and other similar technologies that uniquely identify you; ii. device information: we may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network; and ii. other information: We may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a website. e. the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to A-FOLD houses and used for the purposes set out in this policy (which may include using their details for marketing purposes); f. any other information you provide directly to us. Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy).

Sensitive Information

We do not seek to collect sensitive information (or “special categories” of information under the GDPR). If we do collect sensitive information, we will only do so with your consent and where you provide it to us directly.
Where you provide us with any sensitive information (including, but not limited to, information about your sexual orientation, religious beliefs, medical and/or criminal history), we will only use this information for the purposes stated at the time of collection and will only share this information with our trusted third parties in the manner stated in this Privacy Policy.

Consequences of not providing personal information

Unless specified otherwise, all Data requested by A-FOLD houses is mandatory and failure to provide this Data may make it impossible for A-FOLD houses to provide you with services. In cases where A-FOLD houses specifically states that some Data is not mandatory, you are free not to communicate this Data without consequences to the products or services provided by A-FOLD houses. 14. Failure to provide personal information may result in A-FOLD houses being unable to provide you with the A-FOLD houses products or services or other content, information, upcoming opportunity, promotion, or event.

For what purposes does A-FOLD houses collect, hold, use and disclose your personal information?

Personal information that A-FOLD houses collects will be used for the following primary purposes: a. to fulfill obligations in respect of any contract between you and A-FOLD houses; to render services related to our company and customers (such as after-sales services and inquiries); to facilitate payments from you; b. if you are a customer or business we trade with, to carry on our trading relationship with you including identifying and contacting you, invoicing your correctly, assessing the risks of providing credit to you or your business, and securing and recovering any debts owed to us.
to provide you with information about your A-FOLD houses account, customer account, transactions, content, services and products;
to provide direct marketing materials, special offers, events, and promotions via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, social media, or any other form of electronic, emerging, digital or conventional communications channel;
to contact you, including sending you any technical, administrative or legal notices relevant to the A-FOLD houses products or services or website;
to maintain the functionality of the A-FOLD houses website, including the provision of information to you relating to the content available on the website; to improve the website and system administration;
to provide you with relevant advertising;
to maintain our relationship with you;
to provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages;
to obtain opinions or comments about products and/or services and to conduct other research and development;
to record statistical data for marketing analysis;
to conduct market research;
To collect, hold, use and disclose personal information as stated above, for the purpose of providing professional services to our clients and customers.
to share personal information with our group companies and their related bodies corporate and agents, and other trusted third parties in the manner described in this Privacy Policy;
for any further purposes stated in a particular collection channel;
where explicitly notified to you, to undertake recruitment for A-FOLD houses; q. to manage your employment with A-FOLD houses (if applicable). r. any other purpose as may be deemed reasonably necessary by A-FOLD houses in the circumstances; as needed to satisfy any law, regulation or legal request, to protect the rights or property of A-FOLD houses, any member of the
A-FOLD houses group, or any member of the public, to protect the integrity of the A-FOLD houses website, to fulfill your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.

Automated decision-making

A-FOLD houses does not make decisions that produce significant effects on you which are solely based on automated decision making.

How do we share your personal information?

Solely for the purposes described above, personal information may be shared with:
A-FOLD houses group companies; b. our marketing and email sending partners; and
other third-party technical service providers, such as mail carriers, hosting providers, IT companies and communications agencies, including their directors, servants and agents and related bodies corporate. 18. These recipients may be engaged by A-FOLD houses to perform a variety of functions, such as legal and accounting services, data storage, support services, conducting market research, processing credit card payments, assisting with promotions and providing technical services for our websites. These companies may have access to personal information if needed to perform such functions. Your credit card details are only used to facilitate your purchase. They are not used for any other purpose and will never be supplied to a third party other than A-FOLD houses or our relevant service provider. If you are a business we trade with, we may disclose your information to debt recovery agents or credit reporting bodies if necessary.
Some of the recipients of your personal information may be located overseas. A-FOLD houses employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by A-FOLD houses. However, the security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. A-FOLD houses will not be held responsible for events arising from unauthorized access to personal information except to the extent required by the relevant privacy laws.
The recipients of your personal information may be located in Italy. 21. For individuals in the EU, please note that the recipients of your personal information may be located in countries in which the privacy or data protection laws differ from those of the European Union, and which are not the subject of an adequacy decision by the European Commission.

How do we hold, and how long do we hold your personal information? Security

A-FOLD houses takes appropriate security measures to keep personal information secure, prevent unauthorized access, disclosure, modification or destruction of personal information. A-FOLD houses, its employees and its subcontractors are obliged to respect the confidentiality of any personal information held by A-FOLD houses.
A-FOLD houses also takes reasonable steps to keep personal information accurate, up to date, complete and relevant. A-FOLD houses will also take reasonable steps to ensure only those necessary have access to your personal information. Personal information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas, as described above. A-FOLD houses retain your information only for as long as necessary for the purposes listed in this Privacy Policy.

Your privacy rights

You have a number of rights under the privacy laws. These include:

a.(access) to request access to your personal information from us, in a commonly used electronic format, On a case by case basis, A-FOLD houses may determine that it is not legally required to give an individual access to personal information, in which case A-FOLD houses will provide you with a written notice of its refusal to provide access;

(correction) to request that we correct your personal information;
(withdrawing consent) to withdraw your consent for us to use your personal information;
(transparency) to be informed generally about the collection and use of your personal data, including where we intend to further process your personal data for additional purposes other than as discussed above; and
If you are an individual in the EU, you have additional rights under the GDPR that you can exercise against the “controller” of your data. Where we are the controller of your data, your rights include:
(access) to request that we transfer your personal information to another service provider of your choosing;
(erasure) to request that we erase your personal data. All reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in us being unable to facilitate or provide you with information about certain services (including the uploading, access to, and receipt of content on a website or the A-FOLD houses Application, and purchase transactions undertaken on a website);
(objection and restriction) in some circumstances, to object to the use of your personal data by us and request that we restrict our use of your personal information; and
(complaint) to lodge a complaint in relation to our processing of your personal data with a data protection supervisory authority under the GDPR.
To exercise these rights, please contact us at the contact details listed at the beginning of this Privacy Policy (refer to clause 5). Please allow for a reasonable amount of time for us to process your request, which will generally be up to 30 days.

Miscellaneous Anonymity and Pseudonymity

Where practicable, A-FOLD houses will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our collection channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the personal information identified above. It will not be practicable to deal with you on an anonymous or pseudonymous basis when we wish to send you direct marketing materials or need to provide you with goods or services requested by you.

Sale of the company

If A-FOLD houses merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

Children

The collection of personal information is neither intended for, nor directed to, persons who are under the age of sixteen (16) years old. Personal information will not be knowingly collected about any person who is known by A-FOLD houses to be under the age of sixteen (16) without the consent of a parent or legal guardian.

Passive Information Collection

As with many commercial websites and mobile and tablet applications, we may also collect information which tells us about visitors to our websites. For example, we may collect information about the date, time and duration of visits and which pages of a website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally including when you are logged into an account, you consent to the collection of such information where it is personal information.
As you navigate through our websites, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as Unique Device Identifiers (UDI), cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). In certain circumstances, this information may be considered anonymous information or personal information under the Privacy Act 1988 (Cth) and the GDPR, dependent on the device used and the method by which an individual connects to the Internet. Your Internet browser automatically transmits to the website you are browsing some of this anonymous information or personal information, such as the URL of the website you just came from, the Internet Protocol (IP) address, the UDI (if applicable) and the browser version your device is currently using. Our websites may also collect anonymous information or personal

information from your device through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of a website might not work without cookies and this may limit the services provided by a website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf.

Our websites may use and combine such passively collected anonymous information or personal information and/or information from various third party sources, including as described above, and may combine this anonymous information or personal information with other personal information collected from you to provide better service to website visitors and users, customize a website based on your preferences, compile and analyze statistics and trends, provide you with relevant advertising when you visit a website or a third party website, and otherwise administer and improve a website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a website, you consent to information about you being collected, compiled and used in this way.

A-FOLD houses and other websites

Our websites may, from time to time, contain links to the websites of other organizations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. A-FOLD houses is not responsible, nor does it accept any liability, for the conduct of companies linked to our websites. 34. We may use third-party advertisements on our Websites. All third party advertising, if paid for, is paid for by the relevant third-party advertisers and are not recommendations or endorsements by A-FOLD houses or any of its affiliates. A- FOLD houses is not responsible for the content (including representations) of any third party advertisement on a website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties.

Privacy Collection Statement

Modular Homes srl, an Italian registered corporation sn via lungofino, 149, Città Sant’Angelo (Pe), Italy (A-FOLD houses) collects personal information about you from and any related A-FOLD houses website or social media page (each, a Website); from our clients and customers; as a result of the receiving professional services; and as provided by you by any other means, including either physically or electronically. In addition, A-FOLD houses may provide you with offers, competitions or surveys which require you to provide personal information to enter or to take part. Personal information is collected for a variety of reasons including to fulfill any existing or prospective contracts between you and A-FOLD houses, to carry on a trading relationship, to provide you with information about A-FOLD houses, in order to allow you to participate in offers, competitions or surveys, to respond to inquiries, to provide you with content, products and services requested by you, to conduct market research and to assist in marketing, and, unless you opt-out or unsubscribe, to keep you informed of other A-FOLD houses publications, products, services and events to provide you with marketing materials, including electronically. Unless you opt-out, personal information collected may also be disclosed by us to other organizations for use by them to inform you about other products, services or events or to give to other organizations that may use this information for this purpose. Our Websites may also collect and use passively collected anonymous information or personal information from various third-party sources and may combine this anonymous information or personal information with other personal information collected from you, to provide better service to Website users, customize a Website based on your preferences, compile and analyze statistics and trends, administer and improve our Websites for your use, and to provide you with targeted advertising when you browse third party websites. For the purposes described above, your information may be shared with A-FOLD houses group companies (and their directors, servants and agents), promotional partners and other trusted third parties including our service providers. Failure to provide personal information may result in A-FOLD houses being unable to provide you with other content, products or services. Our Privacy Policy available at and contains information about how you can access and correct your personal information, how you can lodge a complaint regarding the handling of your personal information and how any complaint will be handled by A-FOLD houses. You may contact our privacy officer with any queries via email at or mail to Modular Homes srl, via lungofino, 149, 65013 Città Sant’Angelo (Pe), Italy