Privacy Privacy policy

Privacy

Information notice pursuant to EU Regulation 2016/679 (“GDPR”)

What types of data do we collect?


When you use our services, you agree that our company collects some of your personal data. This page explains what data we collect, why we collect it and how we use it.

We process two types of data:

  • data provided by the user
  • data we collect automatically

Data provided by the user


When using the site, for example in the contact form, we may ask you to provide certain data required to use our service.

These are, for example, the data we request:

  • address, email
  • first and last name
  • phone number
  • message

to use e-commerce services we also need to ask you for the following data

  • full address
  • street number
  • any shipping address
  • password for registration

For the warranty extension the following data are required

  • First Name
  • Last Name
  • Date of Birth
  • E-mail
  • Address
  • City
  • Postal Code
  • Province
  • Country
  • Retailer Name as shown on the receipt
  • Date of purchase
  • Receipt serial number
  • Purchased Model Code

 

For professionals and companies, you may be asked to provide the following data:

  • company name, VAT number, contact person name, email address, phone number
  • other data, such as business category and full address, and additional information specific to the requested service for example quotes

When using the service, by submitting forms in general your IP address and the date and time are also provided. You can use the “contacts” features and, if active, the “Chat” service to communicate with our Customer Center.

Third-party data

If you provide personal data of third parties, for example those of your family members or friends, you must ensure that these individuals have been properly informed and have consented to the processing as described in this notice.

Data of minors under 16

If you are under 16 years of age you cannot provide us with any personal data nor can you register on the site, and in any case we do not assume responsibility for any false statements you may provide. If we become aware of untrue statements, we will immediately delete any personal data acquired.

Data we collect automatically


We collect the following data through the services you use:

  • technical data, log files for example IP address, browser type, information about your computer, downloaded data
  • data collected using cookies or similar technologies, for more information please visit the “Cookies” section.

1. How do we use the collected data?


We use the collected data to provide our services, to respond to your requests and, if you explicitly ask us to, to inform you about our commercial activities or to offer you a more personalized service aligned with your interests, for the operational management of browsing, for the processing of statistical data on access and consultation, for data security management.

1.1. To ensure access to our services and improve delivery


We use your data to ensure your access to our services and their provision, including:

  • registration and creation of a reserved area if provided by the website
  • communications related to the provision of the service
  • contact with the Customer Center, including via the Chat feature if active
  • administrative, financial or accounting activities

These processing activities are necessary to correctly provide the services of this site to users who use them.

1.2. To inform you about our commercial activities


We use the collected data, if you have expressly given consent, to inform you about promotional activities that may interest you.

In particular, if the service is active, we use them to:

  • notify you of promotional, commercial and advertising activities about events and initiatives, via email or by sending SMS or phone calls.
  • carry out analysis and reporting activities related to promotional communication systems, for example tracking the number of opened emails, clicks on links within the communication, the type of device used to read the communication and its operating system, or the list of users unsubscribed from the newsletter.

Contact management and message sending
These services allow the management of a database of email contacts, phone contacts or contacts of any other type used to communicate with the User. These services may also allow the collection of data relating to the date and time when the messages are viewed by the User, as well as the User’s interaction with them, such as information about clicks on links included in the messages. This website sends its users’ contacts to these services for promotional information only if the user authorizes the sending of promotional emails. This preference can be managed at the time of registration or in the profile section of the reserved area, and in any case each email sent with these services includes a link for unsubscribing at any time.

  • MailChimp The Rocket Science Group, LLC.
    Service for managing addresses and sending email messages provided by The Rocket Science Group, LLC.
    Personal Data collected, last name, email, first name and company name, city, province.
    Place of processing, United States – Privacy Policy. Participant in the Privacy Shield.

 

1.3. To offer you a personalized service


In some cases, to improve our commercial offering, we use external services such as Facebook Pixel and Google Ads remarketing for marketing campaigns, provided that you have expressly given your consent see the cookies section

2. Is providing data mandatory?


Providing personal data is mandatory only for processing required to deliver the services offered by the site refusal for purposes related to service provision makes it impossible to use the service itself. It is optional for promotional and profiling purposes and any refusal to give consent has no negative consequences on the provision of the service offered on the website and related applications.

3. Who are the data controllers and recipients?


 

3.1. Data Controller


The Data Controller is [COMPANY], represented by its legal representative pro tempore.

Where applicable, the Controller makes use of data processors to achieve the purposes specified in point 1 and to oversee the protection of personal data. The Controller can be contacted using the numbers and addresses on the site or on the contacts page.

For any request related to your personal data, see point 3.2 below.

 

3.2. Parties to whom personal data may be disclosed


The data collected in connection with the provision of the service may be disclosed to:

  • companies that perform functions strictly related and instrumental to the operation, including technical operation, of the site’s services, such as hosting providers, providers of services aimed at reviewing and auditing the site, direct marketing and customer care providers, providers of storage and backup services, administrative, payment and billing services, and providers of components and technical consultancy for the provision of certain service features.
  • administrative and judicial authorities, pursuant to legal obligations

Your personal data are processed at the Controller’s operational offices and any other place where the parties involved in the processing are located. For more information, contact the Controller. Your personal data may be transferred outside the European Union to be processed by some of our service providers. In this case, we ensure that the transfer takes place in compliance with applicable law and that an adequate level of protection of personal data is guaranteed based on an adequacy decision, standard contractual clauses defined by the European Commission or Binding Corporate Rules.

We never transfer or sell personal data to third parties.

4. How can you access, modify, delete or obtain a copy of your data?


 

4.1. Access to personal data from your reserved area and withdrawal of consent opt-out


If the site has an active personal reserved area, you can, at any time, view and manage your personal data in your reserved area. For example, you can withdraw previously given consents by accessing your reserved area and removing the relevant checkbox. If this website does not have an active reserved area, you can request information about your data from the Data Controller.

4.2. Export and deletion of personal data processing


To export your personal data takeout or request deletion, you can send a request to the email address shown on the site.

Your personal data will be exported within 30 days or, if the export is particularly complex, within three months.

Deletion will be carried out within the technical time frames provided and in accordance with the retention period set out in point 5 below.

4.3. Exercising your rights


Any natural person who uses our service may:

  • obtain from the Controller, at any time, information about the existence of their personal data, their origin, the purposes and methods of processing and, where present, obtain access to personal data and the information referred to in Article 15 of the GDPR
  • request the updating, rectification, integration, deletion, restriction of processing where one of the conditions provided for in Article 18 of the GDPR applies, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is unnecessary for the purposes for which the data were collected and or subsequently processed
  • object, in whole or in part, for legitimate reasons, to the processing of data, even if relevant to the purpose of the collection, and to the processing of personal data for purposes of commercial information or sending advertising material or direct sales, or for carrying out market research or commercial communication. Each user also has the right to withdraw consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal
  • receive their personal data, provided knowingly and actively or through the use of the service, in a structured, commonly used and machine-readable format, and transmit them to another controller without hindrance
  • lodge a complaint with the Italian Data Protection Authority

For any questions or requests regarding your personal data and the protection of your privacy, you can write to the email address indicated on the site.

5. How and for how long will your data be stored?



Personal data will be stored in paper and or electronic IT form for the time strictly necessary to achieve the purposes referred to in point 1, in compliance with your privacy and applicable regulations.

Data are processed and stored for the time required for the purposes for which they were collected.

Personal Data collected for purposes related to the performance of a contract between the Controller and the User will be retained until that contract has been fully performed. Personal Data collected for purposes related to the Controller’s legitimate interests will be retained until such interests have been satisfied. The User may obtain further information about the legitimate interests pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When processing is based on the User’s consent, the Controller may retain Personal Data for a longer period until such consent is withdrawn. The Controller may also be obliged to retain Personal Data for a longer period to comply with a legal obligation or at the order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, upon expiry of this period, the right of access, deletion, rectification and the right to data portability can no longer be exercised.

Invoices, accounting documents and transaction data are stored for 11 years as required by law, including tax obligations.

In the event of exercising the right to be forgotten by expressly requesting the deletion of personal data processed by the Controller, we remind you that such data will be stored in a protected form with limited access only for the purposes of crime detection and repression for a period not exceeding 12 months from the date of the request, and will subsequently be securely deleted or irreversibly anonymized.

Finally, we remind you that for the same purposes, data relating to telematic traffic, excluding the content of communications, will be stored for a period not exceeding 6 years from the date of communication, pursuant to Article 24 of Law no. 167/2017, which implemented EU Directive 2017/541 on counter-terrorism.

 

6. How do we ensure the protection of your data?


Data are collected by the parties indicated in point 3, in accordance with the applicable regulations, with particular regard to the security measures provided for by the GDPR Article 32 for processing through IT, manual and automated tools, and with logic strictly related to the purposes indicated in point 1, and in any case in a way that ensures the security and confidentiality of the data.

7. Can this privacy notice change over time?


This notice may be subject to changes. If substantial changes are made to the use of user data by the Controller, the user will be notified by publishing them prominently on the relevant pages or by alternative or similar means.


Cookies

Cookies and similar technologies

1. What are cookies?


Cookies are small text files that most websites send to users, who store them on their devices, to be transmitted again to the same sites on subsequent visits. Cookies and or similar technologies for example SDK technologies for mobile may be stored permanently persistent cookies on your device or have a variable duration, they may be deleted when the browser is closed or have a duration limited to the single session session cookies. Cookies may be installed by this site first-party cookies or by other websites third-party cookies.

Cookies are used for different purposes, as specified in point 2 below on this page. Some of the purposes of installing cookies may also require the User’s consent. Some types of cookies described may not be active because they are linked to periodic advertising campaigns or features that are temporarily not active.

2. Which cookies are present on the site?


 

2.1. First-party cookies and related purposes


The main purposes of the cookies installed by this site are:

i technical, they are used for purposes related to the provision of the service and to enable or improve site navigation. These cookies are essential to ensure the proper functioning of our platform.

ii analytics, to collect statistical information about the use of the service by users for example number of visitors, pages visited. We use these cookies to analyze traffic on our pages anonymously, without storing personal data.

2.2. Third-party cookies and related purposes


The main purposes of third-party cookies installed are:

i analytics, to collect statistical information about the use of the service by users for example number of visitors, pages visited. These cookies are used to analyze traffic on our pages anonymously, without storing personal data.

ii performance, through these cookies it is possible to develop and implement the service, improving your browsing experience and thus the use of the service.

iii profiling,

  • marketing, we analyze your online actions so that, through third-party partners, we can provide you with content and commercial offers in line with your interests, also based on your previous browsing experience. This information is managed separately from identifying data in the possession of Subito.
  • personalized advertising, through these cookies we show you advertising according to your preferences, habits or consumption choices.

In addition, cookies specifically designed for social networks may be activated. They allow the user to interact through social networks share function, Facebook. When a page contains this command, a direct connection with the selected social network is established. Besides cookies, to improve the service and browsing or for profiling activities, similar technologies may be allowed on your mobile devices such as tools from Google Firebase and Facebook. The use of these technologies is governed by the privacy policies of those companies and not by this site’s privacy notice.

Statistics
Allow analysis of traffic data and are used to track the User’s behavior.

  • Google Analytics with anonymized IP Google Inc.
    Google Analytics is a web analysis service provided by Google Inc. It uses the personal data collected to track and examine the use of this site, to compile reports and share them with other services developed by Google.
    Google may use Personal Data to contextualize and personalize ads in its advertising network. This integration of Google Analytics anonymizes your IP address. Anonymization works by shortening the IP address of Users within the borders of member states of the European Union or in other countries party to the European Economic Area agreement. Only in exceptional cases will the IP address be sent to Google servers and shortened within the United States.
    Personal Data collected, Cookies and Usage Data.
    Place of processing, United States – Privacy PolicyOpt Out. Participant in the Privacy Shield.
  • Facebook Ads conversion tracking Facebook, Inc.
    Statistics service provided by Facebook, Inc., which allows the tracking of conversions such as purchase, sign-up, etc. The service connects Facebook ads with the actions performed within this Website.
    Personal Data collected, Cookies and Usage Data.
    Place of processing, United States – Privacy Policy. Participant in the Privacy Shield.

Live CHAT services
If installed, they would allow direct interaction from the website with live chat platforms. This allows the User to contact the site’s support service or allows the site to contact the User while browsing.
These services may collect Usage Data related to the pages where they are installed, and conversations may be recorded.

  • Zendesk Chat Zendesk, Inc.
    Zendesk Chat is a service for interacting with the Zendesk live chat platform, provided by Zendesk, Inc.
    Personal Data collected, Data communicated while using the service.
    Place of processing, United States – Privacy Policy. Participant in the Privacy Shield.

Remarketing and behavioral targeting
If advertising campaigns are underway and activated, these services would allow the website and its partners to communicate, optimize and serve advertising based on the User’s past use of this site.
This activity is carried out through tracking Usage Data and the use of cookies, information that is transferred to the partners to whom the remarketing and behavioral targeting activity is linked.
In addition to the opt-out options offered by the services listed below, the User can opt out of receiving cookies from a third-party service by visiting the Network Advertising Initiative opt-out page. Facebook

  • Remarketing Facebook, Inc.
    Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc., which links the activity of this Website with the Facebook advertising network.
    Personal Data collected, Cookies and Usage Data.
    Place of processing, United States – Privacy PolicyOpt Out. Participant in the Privacy Shield.
  • AdWords Remarketing Google Inc.
    AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc., which links the activity of this Website with the Adwords advertising network and the DoubleClick Cookie.
    Personal Data collected, Cookies and Usage Data.
    Place of processing, United States – Privacy PolicyOpt Out.

Tags
Scripts used on this Website.

  • Google Tag Manager Google LLC
    Google Tag Manager is a tag management service provided by Google LLC.
    Personal Data collected, Cookies and Usage Data.
    Place of processing, United States – Privacy Policy. Participant in the Privacy Shield.

 

3. Display of content from external platforms that may install cookies third parties


These services allow content hosted on external platforms to be displayed directly from the pages of this Application and to interact with them. If a service of this type is installed, it is possible that, even if Users do not use the service, it collects traffic data relating to the pages where it is installed and releases cookies. Please refer to the privacy policy of the respective sites.

  • Google Maps Widget Google Inc.
    Google Maps is a map display service managed by Google Inc., which allows this Application to integrate such content within its pages.
    Personal Data collected, Cookies and Usage Data.
    Place of processing, United States – Privacy Policy. Participant in the Privacy Shield.
  • Google Fonts Google Inc.
    Google Fonts is a font style display service managed by Google Inc., which allows this Application to integrate such content within its pages.
    Personal Data collected, Usage Data and various types of Data as specified by the service’s privacy policy.
    Place of processing, United States – Privacy Policy. Participant in the Privacy Shield.
  • YouTube Video Widget Google Inc.
    YouTube is a video content display service managed by Google Inc., which allows this Website to integrate such content within its pages.
    Personal Data collected, Cookies and Usage Data.
    Place of processing, United States – Privacy Policy. Participant in the Privacy Shield.

4. How is consent opt-in to the use of cookies given?


Consent to the use of profiling cookies is given by the user as follows, by clicking the button to accept their installation found on the banner containing the short notice. It can be revoked at any time.

All technical cookies do not require consent, therefore they are installed automatically when accessing the site or service.

5. How to withdraw opt-out consent to the use of cookies?


Cookies can be completely disabled from the browser using the appropriate function provided by most browsers.

However, please note that disabling cookies may make some site features unusable.

Below are links to the information pages of the main browsers for more details on disabling cookies, Chrome, Firefox, Internet Explorer, Safari, Edge.

To individually disable third-party performance and profiling cookies click the links to the third-party notices expressly indicated in this cookie policy.

With reference to profiling cookies aimed at offering you personalized advertising, please note that, if you opt out, you will still receive generic advertising.

To opt out and disable personalized ads by changing the settings on your mobile devices, follow the instructions below:

5.1. Android


  1. on your device, open the “Google Settings” app
  2. scroll down and select “Google”
  3. select “Ads”
  4. select “Opt out of interest-based ads” or “Disable ad personalization”

5.2. iOS


iOS devices use Apple’s Advertising Identifier. For more information on how to limit ad tracking with this identifier, visit the “Settings” app on your device or visit https://support.apple.com/it-it/HT205223.

6. Further information about cookies and how to opt out


The platforms Youonlinechoice and Networkadvertising.org offer the possibility to refuse or accept cookies from many digital advertising providers.

We recommend using these platforms to manage the withdrawal of consent to cookie use.

To learn more about targeted advertising, you can consult the following pages:

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