PRIVACY POLICY

www.smoritz.it

Version 2.1 (May 18, 2019)

This information (or "Privacy Policy") is provided in compliance with current regulations on the protection of personal data and, in particular, pursuant to EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (so-called "GDPR") and Legislative Decree 196/2003 (Personal Data Protection Code, so-called "Privacy Code") with reference to the processing of personal data of users who access the website www.smoritz.it (hereinafter also "Site").

This Privacy Policy aims to describe in a simple and transparent manner to users what personal data is processed, for what purpose, by whom, and how, and to inform them of the measures applied to protect their rights and freedoms. Therefore, this Privacy Policy only concerns this Site and is not provided for other third-party websites that may be consulted by the user through links.

1 - Data Controllers

The data controller is AEFFE Lab Srl, with registered office at Via Capestrano, 10/4, 66100 – Chieti (CH), VAT IT02479750693, email address: info@aeffelab.com.

2 - Purposes of Data Processing

By accessing and browsing this Site, as well as using the services offered to users through the Site, information about users as identified or identifiable individuals may be collected and processed. Should personal data be acquired in this way, they will be processed in compliance with current regulations on the protection of personal data solely for the following purposes:

• purposes related to and/or instrumental for allowing access to and use of the Site and its functionalities;
• to execute a service or one or more contractually agreed operations;
• to fulfill any obligations required by law and European regulations;
• for operational, administrative, and management needs internal to the Data Controller and related to the services offered through the Site;
• for statistical purposes, in a completely anonymous and aggregated form; data collected for this purpose is gathered during normal browsing of the Site; for more information, refer to art. 4.3;

With explicit and optional consent, data will be processed for marketing and/or commercial promotion purposes, including paper and/or digital advertising material, regarding the services and/or products offered by AEFFE Lab Srl. More details are available in art. 4.1.

3 - Provision of Personal Data

The provision of personal data for the purposes mentioned in art. 2, paragraph 1, letters a), b), c), d), and e) is mandatory only for the indicated purposes, as the legal basis for processing is the execution of the services requested by the user, the execution of any contractual obligations, or a legitimate interest of the controller. Refusal to provide such data may therefore prevent, for example, the stipulation or execution of contractual relationships, compliance with legal obligations, consultation of the Site with all its functionalities, and the execution of requested services; it will still be possible to browse the Site without providing any personal data, although some functionalities and services may not be available.

The provision of personal data for processing activities for the purposes mentioned in art. 2, paragraph 2, is optional, as the legal basis for processing in this case is the user's free and optional consent. Without explicit consent, such services will not be provided (e.g., the user will not receive the newsletter) without further consequences. If the user does not wish to provide consent for these purposes, they can still use the Site and services for the purposes mentioned in art. 2, paragraph 1, except as provided in the previous paragraph.

The consequences of any refusal to respond or provide consent will always be specified and linked to each service provided: for example, a refusal to process data may prevent the stipulation or execution of contractual relationships, prevent the consultation of the Site and its functionalities (in the case of cookies), or the receipt of the newsletter (in the case of the newsletter service). Therefore, the user will be adequately informed as required for each specific case, but in any case, they may browse the website even if they deny consent to the processing of personal data where requested; in such cases, some functionalities or features of the Site may be disabled.

4 - What Data is Processed?

Depending on the service provided, different types of personal data may be processed, as specified in this article.

4.1 - Browsing Data

The computer systems and software procedures used to operate this Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

4.1.1 - Data Voluntarily Provided by the User (Communications)

The optional, explicit, and voluntary sending of communications via the contact forms on the Site ("form") or via email to the addresses indicated on this Site entails the subsequent acquisition of the data provided by the user, including their email address, and the consent to receive any response messages to their requests.

The personal data provided in this way is used solely to satisfy or respond to the transmitted requests and is communicated to third parties only if necessary for that purpose.

4.1.2 - Data Voluntarily Provided by the User (to Receive Communications for Marketing and/or Commercial Promotion)

Only if personal data (particularly, email address and phone number) is provided by the interested party in the context of a requested service, such data may be used to send communications via email and/or phone related to services similar to those requested by the user, pursuant to art. 130, paragraph 4, Legislative Decree 196/2003, without the need for express and prior consent (so-called soft spam). In any communication, the user is reminded that they can revoke their consent at any time and without formality. The data is deleted upon request by the interested party.

4.2 - Newsletter

The AEFFE Lab Srl newsletter is sent via email to those who explicitly request it by filling out the appropriate form on the Site and authorizing AEFFE Lab Srl to process their personal data for the mentioned purpose.

Consent: Providing data is mandatory only for receiving the newsletter, and refusal will make it impossible to use the service without further consequences.

Purpose: The personal data provided by users will be used solely to send the newsletter and will not be communicated to third parties.

Methods: The collected data will be processed using computerized tools; to prevent data loss, illicit or incorrect use, or unauthorized access to the Site, specific security measures are adopted.

Unsubscribing from the service: to no longer receive the newsletter, simply select the unsubscribe link at the end of each email, or send a specific request to the email address info@smoritz.it.

Unsubscribing is managed in an automated way, so further newsletters may be received for a period following the request, but no later than 72 hours from the cancellation request, as the sending was planned before the cancellation request was received.

4.3 - Cookies

See our Cookie Policy

5 - Methods of Data Processing

1. Personal data is processed lawfully and fairly and used only for the purposes indicated in art. 2. Processing will take place using tools suitable to ensure the security and confidentiality of personal data and with automated tools designed to store, manage, and transmit the data itself. Specific security measures are adopted to prevent data loss and contain the risks of illicit or incorrect use and unauthorized access.
2. Personal data will be stored for the time prescribed by law and, in any case, for the time strictly necessary to carry out the activities for which they were collected and/or until the consent given for the purposes mentioned in art. 2, paragraph 2 is revoked.

6 - To Whom Can the Collected Data be Communicated?

1. Processing related to the web services of this Site takes place at the headquarters of AEFFE Lab SRL and is handled only by technical personnel expressly appointed for processing, both internal and/or external. In particular, where necessary, only with prior consent, data may be communicated to third parties whose collaboration AEFFE Lab SRL may and/or must use for the provision of the services offered. Data acquired through the web, or in any case deriving from web services, may be communicated to the technological and instrumental partners of which the Data Controller uses the services for the provision of the services requested by users/customers, always respecting the purposes indicated in art. 2. To this end, the individuals who will come into contact with the data will be duly appointed as Data Processors pursuant to art. 28 of the GDPR.
2. The data collected for the purposes mentioned above may also be communicated to affiliated companies or companies belonging to the same group as the Data Controller and to parties authorized by law and European regulations.
3. A list of entities to whom the Data Controller communicates the personal data collected for the aforementioned purposes is available and can be consulted at the Data Controller's headquarters and may be requested using the contact details provided.

7 - Changes to the Privacy Policy

This Privacy Policy may be modified, including due to legislative or regulatory changes, technological developments, and the provision of new services or changes to those already provided. Therefore, users/visitors/customers are invited to periodically consult the Privacy Policy of AEFFE Lab SRL.

8 - What are the rights of the data subjects?

1. The data subject is the natural person, identified or identifiable, to whom the personal data being processed refers, i.e., the user accessing the Site and registering.
2. Each data subject has the right to access their data processed by the Joint Controllers at any time (right of access) to verify its accuracy and the lawfulness of the processing performed. The data subject can also exercise all the rights recognized by current national and European regulations on personal data protection (Legislative Decree 196/2003 and EU Regulation 2016/679 and subsequent amendments and additions): in particular, they can request at any time the correction and updating of incorrect or inaccurate data, the limitation of processing, and the deletion of the same (right to be forgotten), as well as lodge a complaint with the Data Protection Authority.
3. With regard to personal data processed by automated means, the data subject can also receive the data concerning them in a structured, commonly used format and, if necessary, transmit it to another data controller (right to data portability).

9 - Right of Withdrawal and Objection

1. Each data subject also has the right to withdraw consent at any time, without affecting the lawfulness of the processing carried out by the Data Controller before such withdrawal.
2. The data subject is also always entitled to object to the processing of their data if it is carried out for direct marketing purposes by the Data Controller; in this case, their data will no longer be processed for these purposes, according to the specific consent previously given, by the Data Controller or any third parties (right to object).

10 - Contact Points

Any request regarding the processing of personal data and any communication related to the exercise of one's rights can be addressed to the Data Controller by sending an email to info@aeffelab.com, or by mail to AEFFE Lab SRL, Via Capestrano, 10/4, 66100 – Chieti (CH) - ITALY.