Notice regarding the processing of personal data of users of the website “sabiana.it”

Articles 13 and 14 of Regulation 2016/679/EU (hereinafter also the “GDPR”)

Why this notice?

Sabiana S.p.A (hereinafter also “Sabiana” or the “Data Controller”) endeavours to respect and protect your privacy and wants you to feel safer, both while you simply browse the site and in case you decide to register by providing us with your personal data, so that you can use the services that are available to our Users and/or Clients. In this page, Sabiana would like to provide you with some information regarding the processing of the personal data of users who visit or consult the website that may be accessed electronically via the address https://www.sabiana.it (the “Site). The notice applies only to the website of Sabiana and not to other websites that the user may consult via links (for which we refer you to their privacy notices/policies). The reproduction or use of pages, materials and information contained inside the Site, by any means and on any medium, is forbidden without the prior written consent of Sabiana. Copies and/or print outs are allowed for strictly personal and not commercial use (for requests and clarifications, contact Sabiana at the addresses below). Other uses of the content, services and information on this site are forbidden.

With regard to the content offered and the information provided, Sabiana will endeavour to maintain the content of the Site reasonably updated and revised, without offering any guarantees regarding the adequacy, accuracy or completeness of the information provided and waiving explicitly any liability for any omissions in the information provided on the Site.

Source - Browsing data

Sabiana would like to inform you that the personal data that you provide and which are acquired at the time of the request of information and/or contact, the registration on the site and the use of services on a smartphone or any device used to access the Internet, as well as the data necessary for the provision of such services, including browsing data and data used for the purchase of the products and services offered by Sabiana but also the so-called “browsing” data of the site on the part of the Users, will processed in compliance with the applicable legislation. The computer systems and software procedures used for the operation of this website acquire, during their normal operation, certain personal data, the transmission of which is implicit in the use of the Internet. This information may not be collected in order to be associated to identified data subjects but that, by its very nature, may, if processed and associated with data held by third parties, allow the identification of the users of the website. This category of data includes “IP addresses” or the domain names of the computers used by the users who connect to the site, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the web server, the size of the file obtained in response, the numerical code that indicates the status of the response provided by the web server (completed, error, etc.) and other parameters related to the operating system and the user’s computer environment. These data are used for the exclusive purpose of retrieving anonymous statistical information regarding the use of the site and to check that the website of Sabiana is functioning properly. We would like to note that the aforementioned data may be used to ascertain responsibility in case of computer-based offences to the detriment of the Sabiana website or other sites that are connected or linked thereto: aside from these eventualities, data on web contacts are currently not held for more than a few days.

Source - Data provided by the user

Sabiana collects, stores and processed your personal data in order to provide the products and services offered on the Site, or to fulfil legal obligations. With regard to certain specific Services and Products, Sabiana may also process your data for commercial purposes. In such cases you will be asked for specific, distinct, optional consent that may be withdrawn at any time with the modalities and at the addresses below.

The optional, explicit and voluntary sending of e-mails to the addresses indicated in the appropriate section of the Website, as well as the filling in of questionnaires (e.g. forms), communication via chat, push notifications via app, social networks, call centres, etc., results in the subsequent acquisition of some personal data concerning you, including those collected through the use of the Apps and related services, which are necessary for us to reply to requests. We would also like to point out that, when you use a mobile connection to access the content and digital services offered directly by Sabiana or by our Partners, it may be necessary to transfer your personal data to such third parties. We would like to inform you that you may access the Site or connect to areas where you can publish information using blogs or inboxes, communicate with other, e.g. by going from the Sabiana site to Facebook®, LinkedIn®, Youtube®, Twitter® and other social network sites, re-view products and offers and publish comments or content. Before you interact with such areas, we invite you to read carefully the General Conditions for Use, taking into account that, in certain circumstances, the information published may be viewed by whoever has access to the Internet and that all the information that you include in your publications may be read, collected and used by third parties.

Purposes of processing and legal basis

Data are processed for purposes:

  1. strictly related to the registration on the site www.sabiana.it, to the services and/or Apps developed or made available by Sabiana, to the use of related information services, to the management of contact or information requests, for the purchase of products and services offered via the Sabiana website;
  2. of ancillary activities linked to the management of the requests of the User/Customer and sending of feedback that may include the transmission of promotional material;
  3. related to the fulfilment of obligations arising from EU and national regulations, for the protection of public order, for detecting and suppressing criminal offences;
  4. of direct marketing or for sending advertising material, direct sales, filling in of market surveys or commercial communication related to products and/or services offered by Sabiana; such activity may also concern products and services of Companies of the Sabiana Group and may be performed through sending advertising/informative/promotional material and/or invitations for the participation to initiatives, events and offers aiming to reward users/customers, either by “traditional” methods (e.g. paper post and/or operator calls) or via “automated” contact systems (e.g. SMS and/or MMS, telephone calls without the intervention of an operator, e-mail, fax, interactive applications, pursuant to article 130 paragraphs 1 and 2 of Legislative Decree 196/03 and subsequent amendments and integrations;

The provision of data for the purposes under 1), 2) and 3), related to a precontractual and/or contractual phase or concerning a request by the user or provided for by a specific provision of the law, is mandatory; if the data are not provided, you will not be able to receive the information and access the services you may have requested. With regard to point 4) of this Notice, the consent to the processing of the data on the part of the user/customer is free and optional and may be withdrawn at any time, without consequences for the usability of the products and services, except for the impossibility for Sabiana to keep users/customers updated on new initiatives or on particular promotions or advantages that may be available.

Sabiana may send commercial communications related to products and/or services similar to those who have already been supplied, pursuant to Directive 2002/58/EU, by using electronic or paper-based addresses that you have provided on such occasions and to which you may object with the modalities and at the addresses below.

Modalities, logic of the processing, time of storage and security measures

Processing is also done with the support of electronic or automated means and is carried out by Sabiana and/or third parties, whose services Sabiana may use to memorise, manage and transmit said data. The processing of the data will be done with logics of organisation and elaboration of your personal data, also in relation to logs on the access and use logs of the services made available via the Internet, of the products and services used related to the aforementioned purposes or, in any case, in such a way so as to guarantee the security and confidentiality of the data. The personal data that are processed will be stored for the time periods provided for in the applicable legislation at any one time.

With regard to the aspect of protection of personal data, the user/customer is invited, pursuant to article 33 of the GDPR, to inform Sabiana of any circumstances and events which may result in a potential “violation of personal data (data breach)” so that it may immediately assess the situation and adopt any actions necessary to address the event by sending a message to databreach@sabiana.it or by contacting Customer Service. The measures adopted by Sabiana do not relieve the Customer from paying due attention to the use, where requested, of a password/PIN of appropriate complexity, that must be updated periodically, especially if such information has been breached by/become known to third parties, and to keep them safe and unavailable to third parties, so as to avoid their improper and unauthorised use.

Cookies

A cookie is a brief string of text that is sent to your browser and, eventually, stored on your computer (or on your smartphone/tablet or any other device you use to access the Internet); cookies are sent in general every time you visit a website. Sabiana uses cookies for several purposes, in order to provide you a fast and secure digital experience, by, for example, allowing you to keep the connection to the protected area active while you browse the pages of the site.

The cookies that are stored on your terminal cannot be used to retrieve any data from your hard disk, to transmit computer viruses or to identify and use your e-mail address. Each cookie is unique in relation to the browser and the device that you are using to access the Website or to use the Sabiana App. In general, cookies are used to improve the operation of the website and the user’s experience when using the website, even if cookies may be used to send advertising messages (as specified below). For more information on what cookies are and how they work, you can consult the website “All about cookies”, http://www.allaboutcookies.org.

FürFor detailed information on Cookies, please read the dedicated page (https://sabiana.it/en/cookies)

Scope of communication and transfer of data.

For the aforementioned purposes, Sabiana may communicate and have processed, in Italy or abroad, he personal data of the users/customers by third-party subjects with whom we have a relationship, in the sense that such third parties provide us with services at our request. We will provide these parties exclusively with the information necessary for the provision of the services requested, taking all measures needed for the protection of your personal data. The data may be transferred outside the European Economic Area if this is necessary for the management of your contractual relationship. In that case, the recipients of the data will assume obligations of protection and security equivalent to those guaranteed by the Data Controller. In case of use of services provided directly by Partners, we will only provide the data that are strictly necessary for the performance of such services. In any case, we will communicate only the data that are necessary for the aforementioned purposes; where required, the guarantees related to the transfers of data to third countries will apply. We may also disclose personal data to our suppliers of commercial services, for marketing purposes; to that end, they will be appointed as external data processors. Further, personal data may be communicated to competent public persons and authorities for compliance with legal obligations or for the ascertainment of responsibility in case of computer-based crimes to the detriment of our site; they may also disclosed or allocated to third parties (in their capacity as data processors or, in the case of suppliers of IT services, independent data controllers) who provide electronic and telematic services (e.g. hosting services, administration and development of websites) and whose services Sabiana uses to perform its technical and organisational tasks and activities that are instrumental for the operation of the website. The persons who belong to the aforementioned categories operate as separate Data Controllers or in the capacity of special Data Processors appointed by Sabiana.

The personal data may also be disclosed to Sabiana’s employees/consultants who have received appropriate training and are appointed Persons in charge of processing.

You may consult the categories of recipients to whom the data may be disclosed by contacting Sabiana at the addresses below.

Rights of the data subjects

You may at any moment exercise the rights granted to you by the law, among which:

  1. a) the right of access to your personal data, obtaining confirmation of the aims pursued by the Data Controller, of the categories of data involved, the recipients to which such data may be disclosed, of the applicable time of storage, of the existence of automated decision-making processes;
  2. b) the right to obtain, without delay, the rectification of the personal data which concern you and are incorrect;
  3. c) the right to obtain, where provided for, the erasure of your data;
  4. d) the right to obtain the restriction of the processing or to object thereto, when possible;
  5. e) the right to request the portability of the data that you have provided to Sabiana, i.e. to receive them in a structured, commonly used and machine-readable format, and to transmit the data to another controller, within the limits and on the conditions provided for by article 20 of the GDPR;
  6. You may also lodge a complaint with the Personal Data Protection Authority pursuant to article 77 of the GDPR.

    For the processing under point 4) of the purposes, the Customer may always withdraw consent and exercise the right to object to direct marketing (in “traditional” or “automated” form). Unless otherwise indicated, such objection will apply both to traditional and automated communication.

    The Data Controller and the Data Processors of the Personal Data

    The Data Controller is Sabiana S.p.A. with its registered office at Via Piave, 53 Corbetta 20011 (MI). The aforementioned rights may be exercise on request of the Data Subject with the modalities mentioned by Customer Service or on the website of the Company or by using the following address: Sabiana S.p.A. -Attn. Privacy- Via Piave, 53 Corbetta 20011 (MI) or via e-mail: privacy@sabiana.it.

    The use of the Website, including the websites developed for tablet and/or smartphone, by the Customer and/or the User implies the thorough knowledge and acceptance of the content and any instructions included in this version of the information notice published by Sabiana from the moment the website is accessed. Sabiana would like to inform you that this information notice may be amended without any warning; we therefore suggest that you check it regularly.

    This privacy notice was updated on 24 May 2018.g

    If you wish to cancel your registration to the website please write to info@sabiana.it.

    If you wish to exercise your rights in relation to the treatment of data please notify us on the privacy@sabiana.it address.

    databreach@sabiana.it

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