Privacy

Privacy


PRIVACY POLICY

IN ACCORDANCE WITH ART. 13 OF EU REGULATION 2016/679 (GDPR).

This information is provided pursuant to EU Reg. 2016/679, on the processing of personal data, with reference to any information that allows the Data Controller to identify you and obtain data concerning you, as well as to know your preferences, if any, directly or indirectly.
Personal data is processed in accordance with the requirements of the GDPR, according to the purposes and methods described below.

1. HOLDER OF THE TREATMENT The data controller is SBOSTATS S.R.L. (P.IVA 04035000985), Via A. Inganni, 93 - 20147 Milano, in the person of the legal representative p.t..
The Holder can be contacted at the following email address: privacy@sbostats.com.

2. PURPOSES, METHODS OF PROCESSING, PERSONAL DATA COLLECTED AND LEGAL BASIS
With regard to the processing of personal data SBOSTATS guarantees the observance and application of the principles of correctness, lawfulness, transparency, minimization, limitation of purpose and storage, with the use of security measures to ensure the integrity and confidentiality and avoid undue access to third parties or unauthorized personnel, to protect your confidentiality and your rights.
Personal data will be collected and processed, by means of computer and paper, according to the purposes and types of data indicated below, in compliance with the provisions in force and, in particular, the security measures prescribed by the Guarantor Authority, as well as with the observance of any measure capable of ensuring the necessary confidentiality and security.
a) Contractual/pre-contractual purposes.
The data provided and collected during registration to the web portal sbostats.com, including personal identification information (first name and last name) and contact information (email, telephone, username used for third party messaging services and residential address), as well as any other information required for this purpose - such as, for example, tax data and payment data - are used to fulfill regulatory, accounting and tax obligations and for any purpose related to the contractual obligation / pre-contractual and execution of the contract. tax data and payment data - are used to fulfill regulatory, accounting and tax obligations and for any purpose related to the contractual / pre-contractual obligations and the execution of the contract between the owner and the person concerned.
The processing of personal data for the aforementioned purposes does not require specific consent, since it is an indispensable activity for fulfilling legal obligations and for the pre-contractual and contractual phases of the relationship. Any refusal to provide the requested data will make it impossible to provide the related services.
Following the processing of your personal data for contractual purposes, in accordance with the provisions of art. 130, co. 4, Legislative Decree no. 196/2003 (Privacy Code), you may receive communications and commercial offers related to the services offered by the Owner (marketing purposes with contractual legal basis).
b) Marketing purposes
The personal contact data provided (phone, email and username used for third party messaging services) may be used by the Owner for telephone contacts, for sending newsletters, information and promotional/commercial offers.
In this case, the processing of personal data is carried out subject to consent given explicitly and optionally during the free registration to the portal sbostats.com or through special contact forms owned by Sbostats (except when using paid services offered by the Owner, which allow the latter to send information and promotions to interested parties, under the terms indicated in the preceding paragraph). Failure to consent involves the impossibility of receiving communications and offers reserved.
The aforementioned communications are sent through the Sendinblue platform (https://it.sendinblue.com/legal/privacypolicy/) and through the use of digital messaging services (SMS and MMS) also of third parties - such as, for example. Whatsapp, Telegram, Instagram, Facebook, LinkedIn, Web Push - as well as in paper form, with the sending of promotions / commercial offers to the address of residence of the interested parties (only if it has been indicated during the registration to our portal and / or during the activation of its services).
c) Profiling activities
The personal data relating to your preferences, habits and use of our services, collected through navigation on our portal sbostats.com and following the use of services reserved for registered users, may be subject to profiling for commercial and marketing purposes, to allow the improvement of these services and to be able to offer services optimized according to the preferences expressed.
The profiling activity involves automated decision-making processes and is carried out by means of algorithms that will create a behavioural and commercial profile, processing the data collected according to the following procedures.
If you consent to the use of cookies, you are free to choose which of them you want to activate. They can be collected anonymous information, to be used for statistical purposes and optimization of the web portal, our app and services offered (eg Google Analytics); can also be activated cookie profiling that, again with your consent, are directed to create profiles of users that allow them to receive promotional messages / trade in line with the preferences expressed during the navigation on the web (eg Facebook Pixel).
For more information please see the extended Cookie Policy, which can be viewed at the following address: sbostats | Cookies.
Always with your explicit consent - expressed during registration and activation of services provided by the Owner, described in detail on the portal sbostats.com - the activities carried out on our website, on our app and the way you use our services may be tracked, in order to offer you a better and optimal use of the same, in line with your preferences and habits, as well as commercial offers aimed at improving your experience of using our services.
Always with your explicit consent - expressed during registration and activation of services provided by the Owner, described in detail on the portal sbostats.com - the activities carried out on our website, on our app and the way you use our services may be tracked, in order to offer you a better and optimal use of the same, in line with your preferences and habits, as well as commercial offers aimed at improving your experience of using our services.
3. COMMUNICATION AND DISCLOSURE OF PERSONAL DATA
The personal data provided are not subject to disclosure, except in cases where this is required by law or is necessary for the management of services required.
In these cases, the data may be communicated to external managers and employees who provide their services for the Owner such as - by way of example - professionals, public bodies, banks, insurance companies, trade associations, as well as companies or professionals with whom the Owner has relationships aimed at the management of specific services (such as administrative, legal, accounting, email and newsletter management, web marketing and customer care).
The personal data provided to external companies and professionals will be used by them exclusively to carry out the agreed services.
The Data Controller may also communicate the personal data processed to Public Bodies within the limits of the provisions of the law, as well as to Police Forces and Judicial Authorities where required and always for judicial and public order purposes.
The interested party may know the list of external data processors and any third parties to whom the Controller has communicated his personal data by making a request to the contacts indicated in paragraph 1. of this statement.

4. ACCESSIBILITY AND SECURITY OF PERSONAL DATA
The interested party may request access to his/her personal data, at any time, by making a request to the Data Controller at the contacts indicated in paragraph 1. of this information notice.
Access to personal data may also be granted by the Data Controller to employees and collaborators, within the limits provided for and regulated in the relationship with the latter and in special assignments for the processing of personal data on behalf of the Data Controller, provided that this is necessary for the purposes of carrying out the tasks assigned to them and the activities performed by them.
It takes place in compliance with the technical and organizational measures adopted by the Owner for the protection and safeguard of personal data, providing different levels of access and appropriate control tools.
The processing of personal data, both in paper and digital / computer, is done in accordance with the principles established by the GDPR, preventing - with appropriate technical and organizational measures - unauthorized or unlawful processing or loss, destruction or damage of data held by the Owner.
Should the Data Controller consider that the security and protection of the personal data of the interested parties may have been jeopardized, he/she will inform them according to the modalities provided for by the regulations in force, as well as, where necessary, communicating the data breach to the competent Guarantor Authority.

5. STORAGE OF PERSONAL DATA
Personal data is stored in digital format, taking into account the purposes for which it is collected and processed. Data in digital format are stored on encrypted servers owned by Leaseweb Website Terms of Use & Cookie Statement | Leaseweb. The maximum storage period for collected data is ten years (e.g. for accounting and tax purposes, for contractual purposes and in all other cases for which the regulations in force allow data to be stored for this period) or for the periods prescribed by the regulations in force, as in the case of rights and obligations arising from the contract between the Data Controller and the data subject.
The expected retention period for commercial and marketing purposes is five years.
The period of conservation of data subject to profiling activities is connected to the duration of the services activated by the interested party and the consent given by the same for this purpose.
At the end of the aforementioned periods, personal data may continue to be stored by the Data Controller in an anonymous form and for purely statistical purposes.

6. TRANSFER OF DATA ABROAD
Your personal data will not be transferred abroad to countries other than those belonging to the European Union that do not ensure adequate levels of data protection.

7. RIGHTS OF THE INTERESTED PARTY
In relation to the data subject to the processing envisaged by this statement, you are entitled to the following rights:
  • Access (art. 15 EU Reg. 2016/679);
  • Correction (art. 16 Reg. UE 2016/679);
  • Deletion (art. 17 Reg. UE 2016/679);
  • Limitation (art. 18 Reg. UE 2016/679);
  • Portability (art. 20 EU Reg. 2016/679), understood as the right to obtain from the Data Controller the data in a structured format in common use and readable by an automatic device in order to transmit them to another Data Controller, provided that the digital nature of the processing allows it and that this does not involve the infringement of the rights and freedoms of others, including the intellectual property rights of the Data Controller or trade secrets related to it; it does not apply, moreover, in cases where the processing is based on legitimate interests;;
  • Opposition (art. 21 EU Reg. 2016/679).

Opposition and requests for deletion of data are subject to compliance with legal obligations regarding the processing and storage of documents and the possible existence of a legal basis that legitimizes the processing itself.
Consequently, the requests for opposition and cancellation will be accepted only in the case in which the right of the interested party does not contrast with treatments that are in any case legitimate and that prevail with respect to the different will expressed by the latter.
The interested party, in the case in which it considers that the modality of management of the personal data from part of the Holder is not however conformed to the enforced norm, will be able to propose claim before the Authority Guarantor.

Last modified for this policy: February 22, 2021.
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