Privacy Policy
Informational notice pursuant to Art. 13 of Legislative Decree 196/2003 “Personal Data Protection Code”, updated to EU Regulation “GDPR” No. 2016/679 – (General Data Protection Regulation).
SPM di Terzi Rosangela
Via Leopardi 102, 21050 Gorla Maggiore (VA)
VAT No.: 02502560127
E. info@spmitalia.com
T. +39 0331 365187
Types of data collected
Among the Personal Data collected by this Application, either independently or through third parties, are: Cookies; Usage Data: name, surname, email, phone, address, city, province, postal code, country, company name, VAT number, tax code.
Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information notices displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from providing such Data without any consequence on the availability or operation of the Service.
Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.
The possible use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that they have the right to communicate or disseminate them, releasing the Data Controller from any liability towards third parties.
Methods and place of processing of the collected Data
Processing methods
The Data Controller adopts appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data.
Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases other parties involved in the organization of this Application (administrative, commercial, marketing staff, legal advisors, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Processors may always be requested from the Data Controller.
Legal basis for processing
The Data Controller processes Personal Data relating to the User if one of the following conditions applies:
the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opt-out”) to such processing. However, this does not apply where the processing of Personal Data is governed by European legislation on the protection of Personal Data;
processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;
processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.
In any case, it is always possible to request the Data Controller to clarify the specific legal basis of each processing activity and in particular to specify whether the processing is based on the law, provided for by a contract, or necessary to enter into a contract.
Place
Data is processed at the operating offices of the Data Controller and in any other location where the parties involved in the processing are located. For further information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User may refer to the section relating to details on the processing of Personal Data.
The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or established by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
The User can verify whether one of the transfers described above takes place by examining the section of this document relating to details on the processing of Personal Data or by requesting information from the Data Controller using the contact details provided above.
Retention period
Data is processed and stored for the time required by the purposes for which it was collected.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until such contract has been fully performed.
Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
When processing is based on the User’s consent, the Data Controller may retain Personal Data longer until such consent is withdrawn. Furthermore, the Data Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, Personal Data will be deleted. Therefore, once this period expires, the right of access, deletion, rectification and the right to data portability can no longer be exercised.
Purpose of processing the collected Data
The User’s Data is collected to allow the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), identify possible malicious or fraudulent activities, as well as for the following purposes: Statistics and Contacting the User.
To obtain detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Contact the user
Contact form
Personal Data: last name; email address; first name; email address, company nameViewing content from external platforms
Google Fonts
Personal Data: Usage Data; TrackerStatistics
Google Analytics with anonymized IP
Google Analytics is a web analytics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected to track and examine the use of this Application, compile reports, and share them with other Google services. Google may use the Personal Data to contextualize and personalize the ads of its own advertising network. This integration of Google Analytics anonymizes your IP address. This anonymization works by shortening Users’ IP addresses within European Union member states or other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google’s servers and shortened within the United States.Personal Data processed: Usage Data; Tracking Tool.
Place of processing: Ireland – Privacy Policy – Opt Out.Tag management
Google Tag Manager
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
User Rights
Users may exercise certain rights with reference to the Data processed by the Data Controller.
In particular, the User has the right to:
withdraw consent at any time. The User may withdraw consent to the processing of their Personal Data previously expressed.
object to the processing of their Data. The User may object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
access their Data. The User has the right to obtain information about the Data processed by the Data Controller, about certain aspects of the processing, and to receive a copy of the processed Data.
verify and request rectification. The User may verify the accuracy of their Data and request that it be updated or corrected.
obtain restriction of processing. When certain conditions apply, the User may request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than storing it.
obtain deletion or removal of their Personal Data. When certain conditions apply, the User may request the deletion of their Data by the Data Controller.
receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain the transfer of such Data to another controller without hindrance. This provision applies when the Data is processed by automated means and the processing is based on the User’s consent, on a contract to which the User is a party, or on pre-contractual measures related to it.
lodge a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, Users have the right to object to such processing for reasons related to their particular situation.
Users are informed that, where their Data is processed for direct marketing purposes, they may object to such processing without providing any reason. To find out whether the Data Controller processes Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise the rights
To exercise their rights, Users may send a request to the contact details of the Data Controller indicated in this document. Requests are submitted free of charge and will be processed by the Data Controller as quickly as possible, in any case within one month.
Further information on processing
Legal defense
The User’s Personal Data may be used by the Data Controller in legal proceedings or in the stages leading to possible legal action for the defense against misuse of this Application or related Services by the User.
The User declares that they are aware that the Data Controller may be required to disclose the Data upon request by public authorities.
Specific notices
Upon request by the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning specific Services, or the collection and processing of Personal Data.
System logs and maintenance
For operational and maintenance purposes, this Application and any third-party services used by it may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User’s IP address.
Information not contained in this policy
Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details provided.
Response to “Do Not Track” requests
This Application does not support “Do Not Track” requests.
To determine whether any third-party services used support them, the User is invited to consult their respective privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application as well as, where technically and legally feasible, by sending a notification to Users through any contact information available. Users are therefore encouraged to check this page frequently, referring to the date of the last modification indicated at the bottom.
Definition and legal references
Personal Data (or Data)
Personal Data means any information that, directly or indirectly, also in connection with any other information, including a personal identification number, allows a natural person to be identified or identifiable.Usage Data
Usage Data refers to information collected automatically through this Application (also by third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects to this Application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various time details of the visit (for example the time spent on each page) and the details related to the path followed within the Application, with particular reference to the sequence of pages visited, the parameters related to the User’s operating system and IT environment.User
The individual who uses this Application who, unless otherwise specified, coincides with the Data Subject.Data Subject
The natural person to whom the Personal Data refers.Data Processor (or Processor)
The natural or legal person, public authority, agency or any other body that processes personal data on behalf of the Data Controller, as described in this privacy policy.Data Controller (or Controller)
The natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.This Application
The hardware or software tool through which the Users’ Personal Data is collected and processed.Service
The Service provided by this Application as defined in the relevant terms (if available) on this website/application.European Union (or EU)
Unless otherwise specified, any reference made within this document to the European Union shall be deemed to include all current member states of the European Union and the European Economic Area.Cookie
A small portion of data stored within the User’s device.Legal references
This privacy notice is prepared on the basis of multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679. Unless otherwise specified, this privacy notice concerns only this Application.Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
Entity adhering to the Privacy Shield.