C.V.M.I. Srl
P.zza Vittorio Emanuele II – 25087 – Salò (BS)
Vat Number 01406260933

Owner’s email address

info@isuledda.it

If you are only using the website https://www.isuledda.it without providing us with information, i.e. if you do not enroll or otherwise, we will only collect the personally identifiable information that your browser transmits to our server. If you want to view our website, we collect the following data, by itself or through third parties, that is technically necessary for us to ensure both the stability of the website and its security, as well as to display it.
Among the types of Personal Data that https://www.isuledda.it collects, by itself or through third parties, there are:
email address, Cookies, Usage Data, Name, last name, phone number, nation, town, postal code and various types of Data, cities and unique identifiers of devices for advertising (Google Advertiser ID or IDFA identifier, for example).
Specific explanations displayed prior to the Data collection or in the specific sections of this privacy policy provide complete information on each type of Personal Data.
Personal Data may be, in case of Usage Data, collected automatically when using https://www.isuledda.it or may be freely provided by the User.
Unless specified otherwise, all Data requested by https://www.isuledda.it is mandatory and failure to provide this Data may make it impossible for https://www.isuledda.it to provide its services. In cases where https://www.isuledda.it specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. If Users are uncertain about which Personal Data is mandatory, they should contact the Owner.
Any use of Cookies – or of other tracking tools – by https://www.isuledda.it or by the owners of third-party services used by https://www.isuledda.it serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.Users are responsible for any third-party Personal Data obtained, published or shared through https://www.isuledda.it and confirm that they have the third party’s consent to provide the Data to the Owner.

Methods of processing

The Owner has taken appropriate technical and operational security measures to protect user data from manipulation, loss, destruction or access, accidental or intentional, by unauthorized persons. Our security measures are constantly reviewed and updated to keep up with technological changes.
In addition to the Owner, in some cases, the Data may be accessible to other persons in charge, involved with the operation of https://www.isuledda.it (administration, legal, sales, system administration, marketing) or external parties (such as third-party technical service providers, hosting providers, IT companies, communications agencies, mail carriers,) appointed, if necessary, as Data Processors by the Owner. The updated list of the persons in charge, if necessary, could be requested to the owner.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner, without relying on consent or any other legal bases as follow, may be allowed to process Personal Data until the User objects to such processing (“opt-out”). This does not apply, whenever the processing of Personal Data is subject to European data protection law;
• Providing Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• The owner is subject to a legal obligation and data processing is necessary for compliance with it;
• Data processing is related to a task that is performed in the exercise of official authority vested in the Owner or in the public interest;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

The Owner will gladly help to clear up the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is devised at the Owner’s operating headquarters and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own.
To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:

• for the duration of subscription services and subscription to the newsletter
• 10 years for preservation of accounting documentation pursuant to art. 2220 cc
• 10 years for marketing, unless revocation of consent and cancellation from the newsletter

The Owner may be allowed to retain Personal Data for more than the indicated period whenever the User has given consent to such processing, until the consent is not withdrawn. The Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to data portability, the right to erasure, the right to rectification and the right to access cannot be enforced after expiration of the retention period.

The Owner collects the Data concerning the User to provide its services and for the following purposes: Contacting the User, Managing contacts and sending messages, Advertising, Interaction with external social networks and platforms, Heat mapping and session recording, Analytics, Remarketing and behavioral targeting, Hosting and backend infrastructure, SPAM protection and Displaying content from external platforms.
To find out more about such purposes and about the specific Personal Data used for each purpose please read the respective sections of this document.

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do as follow:

• Withdraw their consent at any time. Users have the right at any time to withdraw consent, even if they had previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. If the processing is carried out on a legal basis other than consent the User has the right to object to the processing of his Data. For any other detail, please check the other section in this policy.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding some aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users can, under certain circumstances, restrict the processing of their Data. If this happens, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the cancellation of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if possible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users have at any time the right to objects the processing Data for direct marketing purposes without giving any justification. To know whether Personal Data is processing for direct marketing purposes, please read the dedicated sections of this policy.

How to exercise these rights

The contacts provided in this policy could be used from Users to exercise their rights. These requests will be addressed by the Owner as early as possible and can be exercised free of charge; they will be addressed by the Owner always within one month.

Legal action

The Owner can used User’s Personal Data for legal purposes, both in Court or in the stages leading to possible legal action arising from improper use of https://www.isuledda.it or related services.
The User has to know to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

Apart from the information contained in this privacy policy, https://www.isuledda.it may provide the User with additional and contextual information regarding particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

If operating and maintenance actions are needed, https://www.isuledda.it and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More information about the collection or processing of Personal Data may be requested from the Owner at any time. At the beginning of this policy Users can find more information.

How “Do Not Track” requests are handled

https://www.isuledda.it does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Definitions and legal references

PERSONAL DATA (or DATA)
Any information that in connection with other information that directly or indirectly — including a personal identification number — allows for the identification or identifiability of a natural person.

USAGE DATA
Information collected automatically through https://www.isuledda.it (or third-party services used in this Website), which can include: domain names of the computers utilized by the Users who use https://www.isuledda.it or the IP addresses, the URI addresses (Uniform Resource Identifier), the method utilized to submit the request to the server, the time of the request, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the size of the file received in response, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the information about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

USER
The individual using https://www.isuledda.it which is the Interested Party or any other person authorized by the Interested Party, whose personal data are the subject of data processing.

DATA SUBJECT
The natural person to whom the Personal Data refers.

DATA PROCESSOR (OR SUPERVISOR)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

DATA CONTROLLER (OR OWNER)
The natural or legal person, public administration or any other agency responsible, either individually or jointly with any other controller, for decisions on the purposes and methods of data processing and the instruments used, including data security procedures, with regard to the operation and use of the site. The Controller of Data Processing, unless otherwise specified, is the owner of https://www.isuledda.it.

https://www.isuledda.it (OR THIS APPLICATION)
The hardware or software instrument by which the Personal Data of the User is collected and processed.

SERVICE
The service provided by https://www.isuledda.it as described in the relative terms (if available) and on this site/application.

EUROPEAN UNION (OR UE)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

COOKIE
Small sets of data stored in the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to https://www.isuledda.it, if not stated otherwise within this document.