Privacy policy

1.Scope

This policy is provided pursuant to Art. 13 of Regulation (EU) 2016/679 (“GDPR”) and Law No. 171/2018 of the Republic of San Marino, and covers the migastone.com website, in all its language versions (Italian, English, Spanish, French, German).

2.Controller and contacts

• Controller: Migastone International Srl, Via 28 Luglio 212, 47893 Borgo Maggiore, San Marino, COE SM28583, telephone (+378) 0549 888808, PEC migawin@pec.it
• Data Protection Officer (DPO): Ing. Antonio Mirizzi, Via Tommaso Fiore 82, Triggiano (BA), Italia, rpd@invictusaziende.it
• Representative in the European Union (Art. 27 GDPR): Walter Coslop, Via Ugo Bassi 11, 47822 Santarcangelo di Romagna (RN), Italia, w.coslop@migastone.com

For requests about personal data protection, you may write to the Controller by certified email (PEC), to the DPO or to the Representative in the European Union at the addresses above, or open a request on the support portal ticket.migastone.com.

3.Data processed through this website

migastone.com is a static informational website:

• it contains no contact or registration forms, and no private areas;
• it stores in the user’s browser only the choice expressed in the cookie banner (a technical tool that does not require consent);
• it uses third-party statistics and marketing tools only with prior consent, as described below and in the cookie policy.

4.Browsing data

The computer systems and software procedures that operate this website acquire, in the course of their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols: the IP address, the URI addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server’s response, and other parameters relating to the user’s operating system and computer environment.

These data are necessary for the operation and security of the website and may be used to obtain anonymous or aggregate statistical information. They are retained for no longer than seven days, save for any investigation of criminal offences by the judicial authorities.

5.Statistics and marketing, with prior consent

This processing is based on the data subject’s consent, given separately for each category through the cookie banner. Before a choice is made, or if consent is refused, the tools are not loaded and no data is sent to the providers.

• Statistics (Google Analytics 4): aggregate measurement of visits and page views, with the IP address anonymized and, without consent to the marketing category, with ad personalization signals disabled. Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
• Marketing (Meta Pixel): measurement of the effectiveness of advertising campaigns (page views). Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland.

The data collected by these tools (cookie identifiers, pages visited, technical browser and device data, IP address) are retained for the periods stated in the cookie policy. Consent may be withdrawn at any time via the “Manage cookies” link at the bottom of the page.

6.Contact and support requests

This website has no contact forms: requests are sent through the support portal ticket.migastone.com, by telephone ((+378) 0549 888808) or by PEC (migawin@pec.it). The data provided with the request (contact details and content of the request) are processed to respond to the request for contact or for information on the company’s services and products.

Providing the data is optional; without them, however, it is not possible to receive the response or support requested.

7.Legal bases for processing

• Consent (Art. 6(1)(a) GDPR): statistics and marketing cookies and tools (Google Analytics 4, Meta Pixel).
• Performance of a contract or of pre-contractual measures taken at the data subject’s request (Art. 6(1)(b) GDPR): responses to requests for contact, information and support.
• Legitimate interest of the Controller (Art. 6(1)(f) GDPR): security and operation of the website, through browsing data.

Processing based on legitimate interest takes place only on condition that the interests or fundamental rights and freedoms of the data subject do not override it.

8.Recipients of the data

The data may be processed by internal or external staff of the Controller and by legal entities involved in providing the service requested (for example hosting and technical support providers), acting on the Controller’s instructions. The data collected by the statistics and marketing tools, only with prior consent, are processed by Google and Meta as described above and in the cookie policy. The up-to-date list of recipients is available on request at the Controller’s registered office.

9.Transfers of data to third countries

The providers of the tools subject to consent are based in Ireland but may transfer data to the United States. Google LLC and Meta Platforms, Inc. are listed as certified under the EU-US Data Privacy Framework (EU adequacy decision 2023/1795); in addition or as an alternative, the Standard Contractual Clauses (EU Decision 2021/914) apply.

10.Automated decision-making

The Controller does not carry out automated decision-making or profiling. The Meta Pixel marketing cookies, activated only with prior consent, are described in the cookie policy.

11.Support portal and linked websites

The support portal ticket.migastone.com and the project websites migamatch.com and ingegneriadellerelazioni.com are services separate from this website: this website only provides the links. Any data provided on those services is governed by the policies published on each of them.

12.Data subject rights and complaints

Data subjects have the right to:

• access their personal data (Art. 15 GDPR);
• obtain its rectification (Art. 16 GDPR);
• obtain its erasure (Art. 17 GDPR);
• obtain restriction of processing (Art. 18 GDPR);
• receive the data in a structured, commonly used and machine-readable format (portability, Art. 20 GDPR);
• object to processing (Art. 21 GDPR).

Consent may be withdrawn at any time, without affecting the lawfulness of processing based on consent before its withdrawal (Art. 13(2)(c) GDPR); for cookies, the “Manage cookies” link at the bottom of the page is enough.

Data subjects also have the right to lodge a complaint with a supervisory authority (Art. 13(2)(d) GDPR): the supervisory authority of the EU Member State of habitual residence (for Italy: Garante per la protezione dei dati personali, garanteprivacy.it) or the supervisory authority of the Republic of San Marino.

13.How to exercise your rights and request erasure of your data

Rights, including the request for erasure of the data, are exercised by a request to the Controller sent in one of the following ways:

• registered letter with return receipt to Migastone International Srl, Via 28 Luglio 212, 47893 Borgo Maggiore, San Marino;
• PEC to migawin@pec.it;
• a new request on the support portal ticket.migastone.com.

You may also contact the DPO (rpd@invictusaziende.it) or the Representative in the European Union (w.coslop@migastone.com).

14.Updates to this policy

This policy may be updated to reflect changes to the website or to the law. Each version states its number and publication date.