PRIVACY POLICY

SEVIO s.r.l. Privacy Policy

Dear Customer,

SEVIO s.r.l. as a provider of privacy and security tools on the Internet is deeply committed to protecting and respecting the privacy of anyone who accesses its website https://sevio.it/ (hereinafter referred to as the “Site”) or its portal https://portal.sevio.it/ (hereinafter referred to as “SEVIO Portal”).

We hereby wish to provide you with information on the processing of personal data sent by you by means of the form in the “Contact” section of the Site and the SEVIO Portal, in compliance with European Regulation no. 679/2016 (hereinafter referred to as “GDPR”) and the directives of the Italian Data Protection Authority (“Garante della Privacy”) with regard to the processing of personal data.

We therefore invite you to take note of this privacy policy and to express your consent to the processing of the data you wish to provide to us. Privacy policy in compliance with the European Regulation no. 679/2016 (GDPR) and the directives of the Italian Data Protection Authority with regard to the protection of natural persons with regard to the processing of personal data.

Update of 17.10.2020

  1. Data Controller The Data Controller is SEVIO s.r.l., a company incorporated under Italian laws, with registered office in Bergamo, Via dei Caniana, 6/A in the person of its present legal representative. The Data Controller SEVIO s.r.l. can be contacted at the certified email address sevio@legalmail.it or at the email address privacy@sevio.it.
  2. Methods and legal purposes of personal data processing. SEVIO s.r.l. collects the personal data communicated by the User as part of the online registration processes to the Site or the SEVIO Portal in order to provide the SEVIO Services, to enable the User to communicate with SEVIO, to receive newsletters, commercial information, and technical assistance, including through the sending of email communications if the User agrees to receive such communications. Pursuant to Article 4(1) no. 1 of the GDPR, “personal data” means “any information relating to an identified or identifiable natural person”. In particular, in the pursuit of the purposes described above, SEVIO s.r.l. collects personal data (personal information, email address, (encrypted) password, postal address, telephone number, name of the company for which the User works) through the Contact section of the Site and in the registration section in SEVIO Portal. Such data are processed by SEVIO s.r.l. within the limits and for the purposes illustrated below. The User’s personal data will be kept in a form that permits his/her identification for the time strictly necessary for the purpose for which they were collected and subsequently processed and, in any case, within the limits of the law. In order to ensure that your personal data are always accurate, up to date, complete and relevant, we invite you to report any changes made through your registered account or to the following email address: privacy@sevio.it. Your personal data will be processed in printed, computerised and telematic form and included in the exclusively company databases to which the persons in charge of data processing will have access. Except as otherwise provided herein, Users’ personal data will not be disclosed to third parties for purposes not permitted by law or without their express consent. The processing may be carried out by third parties who provide specific processing, administrative or instrumental services necessary to achieve the above purposes. All data processing operations are carried out in such a way as to ensure the integrity, confidentiality and availability of the personal data in accordance with Articles 25 and 28 GDPR.
  3. Duration of personal data processing. Personal data will be kept in a form that allows the identification of the user for the time strictly necessary for the purpose for which they were collected and subsequently processed and, in any case, within the limits of the law. In order to ensure that personal data are always accurate, updated, complete and relevant, the data subjects are invited to report any changes made through their account or to the following email address privacy@sevio.it.
  4. Communication of personal data belonging to third parties. The possibility exists of SEVIO s.r.l. processing the personal data of third parties, and in case only the email address, communicated directly by a User when he/she decides to propagate access to SEVIO Portal to another User. In such cases, SEVIO s.r.l., in compliance with current legislation, will comply with the obligation to provide information to the reported User and, where necessary, will request his/her express consent when registering his/her personal data in its archives. When you cease to access our Site or SEVIO Portal or do not use our Services, we will retain the data provided by you solely for legal obligations.
  5. Failure to provide personal data. The provision of personal data to SEVIO s.r.l., in particular, personal data, email address, and telephone number is necessary to achieve the purposes described above. This data is essential to fulfil obligations deriving from legal or regulatory provisions or for the provision of other services rendered on the SEVIO Portal. Failure to provide any of the necessary data may make it impossible to execute the contract for the purchase of products or the supply of SEVIO Services. Failure to provide the data may therefore, depending on the case, constitute a legitimate and justified reason for not executing the contract for the supply of SEVIO Services.
  6. Security measures. SEVIO s.r.l. has adopted certain security measures in order to minimise the risks of destruction or loss, including accidental, of the data, unauthorised access or processing that is not permitted or does not comply with the collection purposes indicated in this privacy policy, in accordance with the provisions of Articles 32 to 35 GDPR. However, since it is not possible to fully ensure that the measures adopted for the security of the Site and the sending of data and information on the Site are able to limit or exclude any risk of unauthorised access or dispersion of data, we invite you to ensure that your computer is equipped with updated antivirus software for the protection of network data transmission, both incoming and outgoing, and that your Internet service provider has adopted firewalls and anti-spamming filters suitable for the security of network data transmission.
  7. Right to access data and other rights of the User. SEVIO s.r.l. informs you that you are entitled, at any time, to exercise the rights provided for by the GDPR, namely:
    1. Right of access by the data subject (Article 15 GDPR)
      1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
        • the purposes of the processing;
        • the categories of personal data concerned;
        • the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
        • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
        • the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
        • the right to lodge a complaint with a supervisory authority;
        • where the personal data are not collected from the data subject, any available information as to their source;
        • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
      2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
      3. The controller shall provide a copy of the personal data undergoing processing. any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
      4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
    2. Right to rectification (Article 16 GDPR) The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
    3. Right to erasure («right to be forgotten») (Article 17 GDPR).
      1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
        • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
        • the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
        • the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
        • the personal data have been unlawfully processed;
        • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
        • the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
      2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
      3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
        • for exercising the right of freedom of expression and information;
        • for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
        • for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
        • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
        • for the establishment, exercise or defence of legal claims.
      4. Right to restriction of process (Article 18 GDPR)
        1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
          • the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
          • the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
          • the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
          • the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
        2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
        3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
      5. Notification obligation regarding rectification or erasure of personal data or restriction of processing (Article 19 GDPR). The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.
      6. Right to data portability (Article 20 GDPR)
        1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
          • the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
          • the processing is carried out by automated means.
        2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
        3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
        4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
      7. Right to object (Article 21 GDPR)
        1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
        2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
        3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
        4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
        5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
        6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
      8. Automated individual decision-making, including profiling (Article 21 GDPR).
        1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
        2. Paragraph 1 shall not apply if the decision:
          • is necessary for entering into, or performance of, a contract between the data subject and a data controller;
          • is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests;
          • is based on the data subject’s explicit consent.
        3. In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
        4. Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.
      9. Communication of a personal data breach to the data subject (Article 34 GDPR)
        1. When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall communicate the personal data breach to the data subject without undue delay.
        2. The communication to the data subject referred to in paragraph 1 of this Article shall describe in clear and plain language the nature of the personal data breach and contain at least the information and measures referred to in points (b), (c) and (d) of Article 33(3).
        3. The communication to the data subject referred to in paragraph 1 shall not be required if any of the following conditions are met:
          • the controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption;
          • the controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects referred to in paragraph 1 is no longer likely to materialise;
          • it would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.
        4. If the controller has not already communicated the personal data breach to the data subject, the supervisory authority, having considered the likelihood of the personal data breach resulting in a high risk, may require it to do so or may decide that any of the conditions referred to in paragraph 3 are met.

      Such rights may be exercised with respect to SEVIO s.r.l. by contacting the email address privacy@sevio.it.

  8. Cookies. Cookies are small text strings that the websites visited by the User send to his/her device, where they are stored and then retransmitted to the same sites on the next visit. While browsing the site, the User may also receive cookies on his/her device which are sent by different sites or web servers (so-called “third parties”). Technical cookies” are defined as those used for the sole purpose of obtaining anonymous statistical information on the use of the site and checking its correct functioning. The data could also be used to ascertain responsibility in the event of hypothetical computer crimes against the website and therefore against its Data Controller (point (c) of Article 13(1) GDPR). They are not used for other purposes and are normally installed directly by the Data Controller or website operator. They can be split into browsing or session cookies, which ensure normal browsing and use of the website (making it possible, for example, to make a purchase or authenticate yourself to access a reserved areas); analytics cookies, similar to technical cookies when used directly by the site manager to collect information, in aggregate form, on the number of users and how they visit the site itself; functionality cookies, which enable the user to browse the site according to a series of selected criteria (for example, language, products selected for purchase) in order to improve the provided service. Defined as “Profiling cookies” are those which collect information about the user’s browsing habits and used to send advertising messages in line with the preferences expressed by the user when surfing the web. This site uses Google Analytics for statistical purposes only and not for profiling activities. This site uses profiling cookies in compliance with European Regulation no. 679/2016 (GDPR) and with the provisions of the Italian Data Protection Authority, and with what is indicated in the specific banner on the home page and on the Cookie page.
  9. Applicable law and any amendments. This privacy policy is governed by Italian law and by transposed EU law. SEVIO s.r.l. may also amend or simply update, in whole or in part, this privacy policy as a result of changes in the laws or regulations that govern this matter and protect the rights of Users. Amendments and updates to this privacy policy will be notified on the homepage of the Site as soon as they are adopted and will be binding as soon as they are published in that same section.

Thank you for carefully reading this privacy policy and for your consent.

SEVIO S.r.l.