Privacy Policy

This information is provided pursuant to art. 13 of Legislative Decree 196 of June 30, 2003 ("Personal Data Protection Code"), as supplemented and/or amended by Legislative Decree 101 of August 10, 2018, and art. 13 of EU Regulation no. 2016/679 ("General Data Protection Regulation").

SOFTSYSTEM Srl - Via Martin Luther King 28, 56020 Montopoli in Val D'Arno (PI) (hereinafter, the "Data Controller"), hereby informs you, pursuant to art. 13 of Legislative Decree 196 of June 30, 2003 (hereinafter, the "Privacy Code"), as amended by Legislative Decree no. 101 of August 10, 2018, and art. 13 of EU Regulation no. 2016/679 (hereinafter, the "GDPR"), that your data will be processed in the manner and for the following purposes:

1. Object of the treatment

The Data Controller takes care to protect your personal data and complies with applicable data protection legislation (Privacy Code, Legislative Decree no. 101 of August 10, 2018, and GDPR 12016/679). Your personal data is treated confidentially and is transferred to third parties only as provided in this Policy or with your consent. We process the personal data you provide us when using the website and/or after registering on the website.

In particular, we deal with:

Personal, identifying, and non-sensitive data (in particular, name, surname, tax code, VAT number, email address, telephone number – hereinafter, "personal data" or "data") provided directly by you when registering on the site and/or requesting to use the individual social-educational and social-welfare services offered; strictly nominative data of minor users – data not directly provided by you – and in any case acquired within the limits of the provisions of Article 14, paragraph 5, GDPR – the transmission of which is connected to the use of Internet communication protocols (for example, page accesses, amount of data transferred, status message for successful accesses, session ID numbers, IP addresses, URLs, etc.). This data allows us to reconstruct the path of your visits to the site.

2. Purpose of the processing

Your personal data are processed:

A) without your express consent (Article 24, letters a), b), and c), of the Privacy Code and Article 6, letters b), and e), of the GDPR), for the following Service Purposes:

process a contract request or a pre-contractual request;

execute pre-contractual measures adopted upon your request;

prepare internal statistics;

fulfill tax obligations arising from existing relationships;

fulfill obligations established by law, by a regulation, by community legislation or by an order of the Authority;

protect the vital interests of the data subject or of another natural person;

carry out tasks of public interest or connected to the exercise of public authority vested in the data controller;

prevent or detect fraudulent activity or abuse that is harmful to the website;

pursue a legitimate interest of the Data Controller or third parties, within the limits and under the conditions set forth in Article 6, letter f), GDPR;

exercise the rights of the Data Controller (for example, the right to defense in court);

B) Only with your specific and unequivocal consent (Articles 23 and 130 of the Privacy Code and Article 7 of the GDPR), for the following Marketing Purposes:

send by email newsletters, commercial communications and/or advertising material on products and/or services offered by the Data Controller, different and/or dissimilar from those already purchased.

3. Nature of the provision of personal data

Providing your Data for the purposes described in point 2, letters A), n. i and ii) is necessary. Without providing it, we cannot guarantee your registration on the Site or the ability to process your requests. Providing Data for the purposes described in point 2, letter b), is optional. You can therefore decide not to provide any data or withdraw our consent to process previously provided data. In this case, you will no longer receive our newsletters, but you will continue to receive our services and retain the right to register on the site.

4. Methods of processing

The processing of your personal data is carried out through the operations indicated in art. 4, Privacy Code and art. 4, n. 2), GDPR and specifically: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking,

communication, deletion and destruction of data. The processing of your data will be based on the principles of correctness, lawfulness and transparency and may

be carried out also through automated methods aimed at storing, managing and transmitting them and will be carried out using suitable tools, as far as

reason and the state of the art, to guarantee security and confidentiality through the use of suitable procedures that avoid the risk of loss,

unauthorized access, unlawful use and dissemination.

5. Data retention period

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and for no longer than 2 years from the date of data collection for Marketing Purposes. After this retention period, the data will be destroyed or anonymized.

6. Access to data

The personal data processed by the Data Controller will not be disclosed, i.e. they will not be made known to any other subjects.Unspecified, in any form whatsoever, including making them available or simply consulting them. However, they may be disclosed to employees of the Data Controller and to certain external parties who collaborate with them. In particular, your data may be made accessible to:

employees and collaborators of the Data Controller, consultants authorised to manage the site and provide related services (for example: services

customers, IT department, etc.), in their capacity as internal managers and/or data processors and/or system administrators;

third-party companies or other entities (for example: credit institutions, professional firms, consultants, insurance companies, etc.) that carry out

outsourced activities on behalf of the Data Controller, in their capacity as external Data Processors and/or Data Processors.

Your data may also be disclosed, to the extent strictly necessary, to parties authorized to access them pursuant to legal provisions, regulations, and EU legislation.

7. Communication of data

Without your express consent (pursuant to art. 24 letters a), b), d), Privacy Code and art. 6 letters b), c), GDPR), the Data Controller may communicate your data for the purposes indicated to Supervisory Bodies, Judicial Authorities as well as to all other subjects to whom communication is mandatory by law for the fulfillment of the purposes.

said.

8. Data transfer

Personal data will be managed and stored on servers of the Data Controller and/or third-party companies duly appointed as Data Processors, located within the European Union, or in accordance with the provisions of Articles 45 et seq. of the GDPR. The servers are currently located in the European Union. The data will not be transferred outside the European Union. In any case, it is understood that, should it become necessary to relocate the server locations to Italy and/or the European Union and/or non-EU countries, such relocation will always be in compliance with Articles 45 et seq. of the GDPR. In such cases, however, the Data Controller hereby ensures that the transfer of data outside the EU will be in compliance with applicable legal provisions, stipulating, if necessary:

necessary, agreements that guarantee an adequate level of protection and/or by adopting the standard contractual clauses provided for by the European Commission.

9. Browsing data

The computer systems and software procedures used to operate the website may acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature, it could, through processing and association with data held by third parties, allow users to be identified (e.g., parameters relating to the user's operating system and IT environment). This data is used by the Data Controller solely to obtain anonymous statistical information on the use of the Website and to verify its proper functioning, and is deleted immediately after processing. This data may also be used to ascertain liability in the event of hypothetical cybercrimes against the Website.

10. Cookies

When you use our site, cookies are stored on your computer. Cookies are small text files that are stored on your computer and provide us with certain information. They are widely used to make websites work, or work more efficiently, to improve the user experience, as well as to provide certain information to the owners of the site. Our site uses cookies that remain on your computer for different periods of time. Some expire at the end of each session, and some remain for longer periods so that when you return to our site, you can benefit from a better user experience. Web browsers allow you to exercise some control over cookies through your browser settings. Most browsers allow you to block cookies or block cookies from certain sites. Browsers can also help you delete cookies when you close your browser. However, you should keep in mind that this may affect any opt-outs or preferences you have set on the site.

will be lost. Please consult your browser's technical information for instructions. If you choose to disable cookies or refuse to accept cookies, some parts of the service may not function properly or may be significantly slower.

11. Rights of the interested party

As a data subject, you have the rights set forth in Article 7 of the Privacy Code and Article 15 of the GDPR, specifically:

obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet recorded, and their communication in an intelligible form;

get the indication:

a) the origin of the personal data;

b) the purposes and methods of the processing;

c) the logic applied in case of processing carried out with the aid of electronic instruments;

d) the identifying information of the data controller, data processors, and the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, of the GDPR;

e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representatives in the territory of the State, managers or persons in charge;

obtain:

a) the updating, rectification or, when relevant, integration of the data;

b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;

c) certification that the operations referred to in letters a) and b) have been brought to the attention, including with regard to their content, of those to whom the data were communicated or disseminated, except in the case in which such fulfillment proves impossible or involves the use of means manifestly disproportionate to the right protected;

to object, in whole or in part:

a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection;

b) to the processing of your personal data for the purposes of sending advertising or direct sales materials, or for market research or commercial communications, through the use of automated calling systems without human intervention, via email, and/or through traditional marketing methods such as telephone and/or mail. Please note that the data subject's right to object, set forth in point b) above, for direct marketing purposes via automated means extends to traditional means, and that the data subject may exercise the right to object even partially. Therefore, the data subject may decide to receive communications only via traditional means, only automated communications, or neither type of communication.

Where applicable, you also have the rights referred to in Articles 16 – 21, GDPR (Right to rectification, right to be forgotten, right to restriction of processing, right to data portability).

data, right to object), as well as the right to lodge a complaint with the Guarantor Authority.

12. How to exercise your rights

You have the right to request from the Data Controller access to your data, its rectification or erasure, the integration of incomplete data, and the restriction of its processing; to receive the data in a structured, commonly used, and machine-readable format; to withdraw any consent you may have given regarding the processing of your sensitive data at any time and to object, in whole or in part, to the use of the data; to lodge a complaint with the Authority, as well as to exercise the other rights granted to you by applicable law. You may exercise your rights at any time by sending:

a registered letter to SOFTSYSTEM Srl

Via Martin Luther King 28, 56020 Montopoli in Val D'Arno (PI).

an email.

13. Minors

If the data subject is under 14 years of age, such processing is lawful only if and to the extent that such consent is given or authorized by the holder of parental responsibility for whom the identifying data is acquired.

14. Owner, manager and persons in charge

The Data Controller is SOFTSYSTEM Srl - Via Martin Luther King 28, 56020 Montopoli in Val D'Arno (PI). The updated list of data processors and data controllers is kept at the Data Controller's headquarters.

15. Changes to this Policy

This Policy may be subject to change. We therefore recommend that you check this Policy regularly and refer to the most up-to-date version.