Miracle Investment Advice Ltd describes the methods of processing your personal data. 

Owner and manager of the data

In accordance with the obligations set out in the EU Regulation 2016/679 concerning the protection of individuals with regard to the processing of personal data (the “Regulation”) we would like to inform you that the start-up Miracle Investment Advice Ltd based in Dublin (Ireland) in The Black Church St. Mary’s Place D07 P4AX and Pioli Fabio, born in Pavia on 7 September 1973 and resident in Sant’Olcese (Genoa) in Salita Vicomorasso 15, 16010 (whose email is info@cfionline.it) represent respectively the owner and manager of the your personal data that will be collected within the contract.

The processing of your personal data will be carried out in compliance with the rules on data protection and will be based on the principles of lawfulness, fairness and transparency. Furthermore all data will be appropriate, relevant and limited to what is necessary with respect to the purposes for which they are processed and for which they are collected and recorded as indicated in this Privacy Policy.

The processed data

Within the site www.miraclapp.com the following information will be collected and processed:

– The information acquired from your interaction with the site such as IP address, pages visited, clicked content and traffic data.

– If you decide to register on the platform, you will be asked for your email address

– Your name and surname together with your e-mail address will be requested if you decide to subscribe to the newsletter 

The purpose and the legal basis on which the data is processed

Your data will be processed for the following purposes: 

–  to inform you of our services and to send you newsletters, commercial communications and questionnaires (via email, SMS and telephone) if you have requested the same. The processing of your personal data for this purpose is carried out on the basis of the legitimate interest of the data controller and, taking into account the means used and the frequency of communications, it is considered that there is no significant impact on the rights and freedom of the User.

– In addition to the above, it is specified that in cases where your personal data is collected via Miraclapp platform ebook download or newsletter subscription tools, the data controller may send you some e-mails and informative and commercial newsletters. The aforementioned communications will be non-invasive and their sending is based on the legitimate interest of the data controller who is interested in making their service known to users who have expressed and interest in one of the features offered by Miraclapp platform.  

How is the data processed

The processing of personal data referred to in the proceding points will be carried out with the use of paper support and with the aid of electronic and IT tools suitable for guaranteeing the security and confidentiality of the data.

To whom we communicate your data

Your data may be communicated by the data controller only and exclusively for the purposes indicated and in the following subject categories:

– The natural persons authorized to process the data necessary to perform the tasks assigned to them: employees of the start-up Miracle Investment Advice Ltd

– Where required, the competent Judicial Authorities

– Where required, the public administrations and supervisory and control authorities. 

Instead, personal data will not be disclosed to undetermined individuals.

Data retention

Your data will be stored, in accordance with the provisions of the applicable legislation, for a period not exceeding that which is necessary to achieve the purposes for which the data was collected. The criteria for determining the data retention period takes into account the permitted processing period and applicable tax regulations, the prescription of legitimate rights and interests that constitute the legal basis of processing.

In relation to the processing for marketing purposes, in the absence of specific rules that provide for different storage times, the data controller will take to use your data for the aforementioned purposes for a period consistent with the interest shown by you in the promotional initiatives and equal to 5 years. In any case, the data controller will take every precaution to avoid using the data for an indefinite period, proceeding periodically to adequately verify the actual duration of his interest in processing the data for marketing purposes, as specified above. 

Subsequently the data will be deleted, aggregated or anonymized. 

Your rights

The current legislation give you specific rights, including those to ask the data controller:

– confirmation that your personal data is being processed and, in this case, request access (right of access)

– the rectification of inaccurate personal data or the integration of incomplete personal data (right of rectification)

– the deletion of the data itself, in the presence of one of the reasons provided for in article 17 of the Regulation (right of cancellation)

– to limit the processing of your data, in the presence of one of the reasons provided bu the article 18 of the Regulation (right of limitation)

– to receive the personal data that you previously provided in a structured format, commonly used and readable by an automatic device and to transmit them to another data controller (right to portability)

– the opposition at any time, for reasons related exclusively to your situation, to the processing of your personal data (right of objection)

To exercise your rights, you can send a request by e-mail to the email address info@cfionline.it.

Pursuant to the Regulation, the data controller is not authorized to charge costs for fulfilling one of the requests indicated in this paragraph, unless they are obviously groundless and excessive, and, in particular, unnecessarily repetitive. If you request more than one copy of your personal data or in cases of excessive and unfounded requests, the data controller may:  (I) charge a reasonable fee, taking into account the administrative costs incurred to process the request or (II) refuse to comply with the request. In these cases, the data controller will inform you of the costs before processing the request.

The data controller may request further information before processing requests, should he need to verify the identity of the natural person who submitted the same.

Without prejudice to any other administrative and jurisdictional appeal, you have the right to lodge a complaint with the Supervisory Authority if you believe that the processing of your data is carried out in violation of the General Data Protection Regulation. Further information is available on the website https://www.dataprotection.ie/

In any case, the data controller is interested in being informed of the possible reasons for a complaint and invites those concerned to use the contact channels indicated above before applying to the Supervisory Authority, so as to be able to prevent and resolve any disputes in a friendly and timely manner, with the utmost courtesy, seriousness and discretion.