SBS Go Tune - Privacy Policy

1. What types of data are processed through the Website, the App and / or the provision of the Service for what purposes?

   If you are a visitor to the Website or a user of the App, the following types of personal data will be processed for the following purposes:
   Navigation data:
   The computer systems and software procedures used to operate the Website and / or the App acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes IP addresses or domain names of computers and terminals used by users, the addresses in URI / URL (Uniform Resource Identifier / Locator) notation of the requested resources, the time of the request, the method used in submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's IT environment. This data, necessary for the use of web services, are also processed for the purpose of: (i) obtaining statistical information on the use of the services (most visited pages, number of visitors by time or day, geographical areas of origin, etc. ); and (ii) check the correct functioning of the services offered. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Website and / or the App and / or other SBS Tools. The navigation data is processed for our legitimate interest in guaranteeing the security of the Site, checking its correct functioning and obtaining statistics in relation to its use (Article 6, paragraph 1, letter f) of the GDPR).

   Data voluntarily provided by you:

   • in the letters / e-mails / faxes spontaneously sent to us: the optional, explicit and voluntary sending of your personal data to the addresses of mail, e-mail, fax number published on the Site or on the App involves the subsequent acquisition of such data, necessary to respond to requests sent by you in relation to the Site (Article 6, paragraph 1, letter b) of the GDPR). You are free not to provide such data. However, failure to provide them may make it impossible to obtain what is requested;
   • on the occasion of calls made to our telephone numbers: when you contact our telephone numbers or our customer service, we may process the personal data you spontaneously communicate to us during the telephone conversation or reasonably requested by us to provide you with what is necessary (art . 6, co. 1, let. B) of the GDPR). You are free not to provide such data. However, failure to provide them may make it impossible to obtain what is requested;
   • through the contact form on the Site or on the App: if there is a contact form on our Site and / or on the App (in the "Contacts" section). If you decide to use this contact form, we will collect and store your data for the sole purpose of following up on your requests (Article 6, paragraph 1, letter b) of the GDPR). You are free not to provide such data. However, failure to provide them may make it impossible to obtain what is requested.

   Furthermore, if you use the Service, we will process the personal data that you will provide us at the time of registration to download the App (e-mail, password and credentials of the authentication system) and the personal data relating to, and / or present in, User Content and / or in the User's Design. These data will be processed to (i) execute the Contract, (ii) to fulfill your specific requests before accepting the Contract, (iii) to allow you to use the Service (Article 6, paragraph 1, let. b) of the GDPR). Personal data relating to, and / or present in, User Content and / or User Design will be deleted from the SBS systems immediately after the execution of the printing and / or personalization service at the point of sale, and after SBS printing and / or personalization will no longer be able to access and / or process such personal data. However, it is understood that the User may keep the User's Design in their device and / or through their cloud services and / or share it with other users of the App.

2. If I am a user who has downloaded the App, for what purposes will my personal data be processed?

   If you decide to register for the purpose of downloading the App and / or use the Website to use the Service, your personal data will also be processed for the following purposes:

   • to execute a contract of which you are a party and pre-contractual measures adopted at your request (Article 6, paragraph 1, letter b) of the GDPR): we will process your data for the purpose of downloading the App, providing them the services reserved for registered users of the App and the Service in general, in execution of the General Conditions of the Go Tune Service or any other contracts and agreements to which you are a party, as well as to implement any pre-contractual measures adopted at your request;
   • to fulfill legal obligations (art. 6, co. 1, let. C) of the GDPR): we will process your personal data to comply with legal obligations in tax matters and consumer protection;
   • to pursue our legitimate interest in knowing how and how much the App, the Website and the other SBS Tools are used by visitors (Article 6, paragraph 1, letter f) of the GDPR): in order to pursue our legitimate interest in knowing how and how much the App, the Website and the other SBS Tools are used by the Users, we generate, also through third party suppliers, statistical and aggregate data regarding the number of pages viewed, the number of users and, more in general, the methods of use of the SBS Tools, without ever tracing back to its identity. To generate these statistics and aggregate data, our suppliers use the so-called cookies (please see paragraph 10 below);
   • to pursue our legitimate interest in exercising or defending a right in court or out of court (Article 6, paragraph 1, letter f) of the GDPR): we may process your personal data to pursue our legitimate interest in exercising or defend our right in court or out of court, even in the event of breach of the Contract or violations of the law;
   • to provide the Service (art. 6, co. 1, let. B) of the GDPR): for the processing of personal data carried out in order to execute the Contract, please read paragraph 1.

   With your optional consent, we may also process your personal data for marketing and / or profiling purposes. In relation to these treatments, please read the following paragraphs 3 and 4.

3. Will you also process my data for marketing purposes?

   With your optional consent (Article 130 of Legislative Decree 196/2003; Article 6, paragraph 1, letter a) of the GDPR), which can be expressed by selecting the appropriate box, we will process your data for marketing purposes ( direct sales, sending advertising material, carrying out market research, commercial communication, surveying the degree of customer satisfaction). In case of consent, we may contact you by e-mail to propose the purchase of products and / or services offered by us, present offers, promotions and commercial opportunities or propose you to participate in questionnaires, studies, market research or surveys on the grade. customer satisfaction. By checking the consent box relating to marketing purposes, you consent to be contacted by us via e-mail. In any case, you may freely and free of charge revoke your consent to the processing of your personal data for marketing purposes at any time, by making a request to us in the manner indicated in paragraph 12 below. In relation to promotional communications sent by e-mail, you may revoke the your consent to the processing of your e-mail address for marketing purposes also by clicking on the unsubscribe link (opt-out) present in each promotional e-mail.

4. Will you also process my data for profiling purposes?

   With your optional consent (Article 6, paragraph 1, letter a) of the GDPR), which can be expressed by selecting the appropriate box, your personal data (i.e. both personal and contact data and information relating to services / goods purchased) may also be processed by SBS for profiling purposes, or to reconstruct your tastes and consumption habits, identifying your consumer profile, in order to be able to send you commercial offers consistent with the identified profile and in particular personalized promotional communications based on: (i) the products and services to be she purchased; (ii) the information you voluntarily provided to us during registration; (iii) the pages visited. The consent to the processing of personal data for profiling purposes is entirely optional, and in the event of failure to provide or consent, the possibility of using the Service will not be affected in any way. The consent to the processing of personal data for profiling purposes also extends to the detail of the goods and / or services purchased; however, the data relating to the detail of the goods purchased will be kept by SBS, for profiling or marketing purposes, until the relative consent is revoked and in any case for a maximum period of 36 months.

5. Will you carry out automated data processing and analysis anonymously?

   Yes, we will carry out automated processing and analysis of data anonymously for statistical purposes and to acquire useful information about the use of the Website, App and Service.

6. Will my personal data be disclosed to third parties?

   It is possible that, at the request of the judicial authority or the judicial police, we may have to communicate data relating to Users, in the cases required by law. In this case, we may also communicate your data to lawyers or law firms, where necessary to pursue our legitimate interest in exercising or defending a right in court.

   Where required by law, your personal data relating to a purchase of the Service may be disclosed to the Revenue Agency. Your data may be disclosed to the judicial authority at the request of the same in the cases provided for by law.

7. Who can learn about my data?

   Your personal data may be disclosed to our employees and collaborators who deal with the management and maintenance of the SBS Tools, assistance to Users who request information or send us other requests and the management of purchases on the Store, as well as, based on the any optional consents expressed by you, send promotional communications or carry out profiling activities. Furthermore, the following categories of subjects, who, as data processors, provide us with services that are instrumental to the performance of our business, may become aware of your personal data: IT and logistic service providers; providers of outsourcing and cloud computing services, analytics service providers (which provide us with statistics and aggregate data on the use of the Website); management service providers; external professionals and consultants; companies in charge of carrying out marketing activities on our behalf.

8. How will my personal data be processed and for how long will they be kept?

   Your personal data will be processed with automated and non-automated tools. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access. The navigation data will be kept for a maximum period of 7 (seven) days, unless further storage is necessary to ascertain responsibility in the event of hypothetical computer crimes against the Website or to fulfill requests from the Judicial authority. If you have contacted us by letter, e-mail, fax or via the contact form on the Website or in the App to obtain information relating to the Website or the App and the services offered therein, your data will be stored. for a maximum of 60 days from the day we have provided you with the requested information, unless further data retention is necessary to comply with legal obligations or to exercise or defend our right in court. If you have contacted us in relation to a purchase, we will keep the correspondence for 10 years, as required by the applicable legislation on the conservation of documents and business correspondence.

   Your data collected for downloading the App will be kept as long as your account remains active and will be deleted immediately after your account is closed.

   The data relating to the purchases of a Service may be kept for 10 years if required by the applicable law in the material tax.

   In the event that you have consented to the processing of your personal data for marketing purposes, your personal data will be processed until you have revoked your consent to the processing of your data for marketing purposes. Your contact details will in any case be kept to pursue any other purposes of the processing for which they were collected. The data will be processed for profiling purposes for the periods indicated in the previous paragraph 4. The personal data relating to, and / or present in the User Content and / or in the User's Design will be processed for the time indicated in the previous paragraph 5.

9. Will my data be transferred outside the European Economic Area?

   No, your personal data will be stored and processed exclusively within the territory of the European Economic Area.

10. What are my rights?

    You have the right to exercise at any time, free of charge and without formalities, the following rights under Articles. 15 to 22 of the GDPR, including: (i) the right to access personal data (i.e. the right to obtain confirmation from us that data processing concerning you is in progress and, in this case, to obtain access to personal data, obtaining a copy, and to the information referred to in art.15 of the GDPR), (ii) rectification (i.e. the right to obtain the modification of inaccurate data concerning you or the integration of incomplete data ) or the cancellation of the same, if one of the reasons indicated by art. 17 of the GDPR, or the limitation of the processing that concerns you (i.e. the right to obtain, in the cases indicated by art.18 of the GDPR, the marking of the data stored with the aim of limiting their processing in the future), (iii) the right to data portability (i.e. the right, in the cases indicated by art.20 of the GDPR, to receive from us, in a structured format, commonly used and readable by automatic device, the data concerning you, as well as to transmit such data data to another data controller without hindrance). You also have the right to object at any time, for reasons connected with your particular situation, to the processing of personal data concerning you pursuant to Article 6, paragraph 1, letters e) (execution of a task in the public interest o connected to the exercise of public powers) or f) (legitimate interest) of the GDPR, including profiling on the basis of these provisions. If personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for these purposes, including profiling to the extent that it is connected to such direct marketing. You also have the right to withdraw your consent at any time, when a processing is based on your consent. The withdrawal of consent does not affect the lawfulness of the processing based on consent before the withdrawal.

11. How can I contact you and exercise my rights?

    You can exercise your rights by contacting us by letter to the following address "SBS SpA, with registered office in Via Circonvallazione S/N, 28010 Miasino (NO), ITALY - for the attention of the Privacy Office" or by e-mail at privacy@sbsmobile.it. We remind you that you always have the possibility to lodge a complaint with the Guarantor for the protection of personal data (www.garanteprivacy.it) or the different Supervisory Authority of the Member State of the European Union in which you reside or work or in which it occurred. the alleged violation.