Privacy

Policy [Link]




First level

INFORMATION RELATING TO THE PROCESSING OF PERSONAL DATA

Who is the data controller?
SPM Srl

What personal data is collected or acquired by the [Link] website?
Data provided voluntarily: name, surname, profile picture, country, postcode, town, date of birth, e-mail address,
language, telephone number, tax code, VAT number, iban
Geolocation data

Why are my data processed?
For your registration to [Link]
To configure your Assignment Letter
For the generation of your Receipts or Invoices
For the payment of your commissions
For the use of the [Link] services
To check the correct operation of [Link]
If necessary, to ascertain, exercise or defend the rights of the owner in court
To fulfill obligations under regulations and applicable national and supranational legislation

What are my rights?
You can request access to the data concerning you, their correction or their cancellation, as well as, the limitation of the
treatment, the opposition to the treatment as well as the portability of the data by contacting the Data Controller by e-
mail at the address: spm@[Link]
You can lodge a complaint with the competent supervisory authority

Click here to read the complete information relating to the processing of your personal data

Second level
The second level is accessed by clicking on the link, to the complete information of the first level

What must be displayed on the device when the user clicks on the title above in the Web Version menu.


Who is the data controller?
SPM Srl

What personal data is collected or acquired by the [Link] website?
Data provided voluntarily: name, surname, profile picture, country, postcode, town, date of birth, e-mail address,
language, telephone number, tax code, VAT number, iban
Geolocation data

For what purposes are your data processed?
For your registration to [Link]
For the use of the [Link] services
To configure your Assignment Letter
For the generation of your Receipts or Invoices
For the payment of your commissions
To check the correct operation of [Link]
If necessary, to ascertain, exercise or defend the rights of the owner in court
To fulfill obligations under regulations and applicable national and supranational legislation


For what purposes are your data processed?
From the second to the sixth purpose, the execution of the contract between SPM srl and the user
For the first and eighth purposes, the legitimate interest of SPM srl
For the seventh purpose, the need to fulfill legal obligations

Is the provision of data mandatory? What happens if you don't provide the data?
The provision of data in the registration form is mandatory for the conclusion and continuation of the contract. The refusal
to provide the aforementioned data therefore does not allow the registration and use of [Link].

How long do we keep your data?
The personal data provided during registration will be kept by registering your account until you ask to withdraw your
registration from [Link].
The geolocation data will be kept for the time in which the geolocation services of your device are kept active and
[Link] is active.

Who will process your data? Who can your data be communicated to?
The data may be processed by the employees of the corporate functions appointed to pursue the aforementioned
purposes, who have been expressly authorized to process and who have received adequate operating instructions.
The Data may be processed, on behalf of the owner, by external subjects designated as data processors, who carry out
specific activities on behalf of the owner, for example, server maintenance.
The Data may be communicated to external subjects operating as data controllers, by way of example, authorities and
supervisory and control bodies and in general subjects, public or private, entitled to request the Data.

Will your data be transferred outside the EU?
No

What are your rights?
By contacting SPM srl at the e-mail address spm@[Link], the interested party can ask the Company for access to the
Data concerning him, their cancellation, the correction of inaccurate Data, the integration of incomplete Data, the
cancellation of the Data, the limitation of the treatment in the cases provided by art. 18 GDPR, as well as oppose, for
reasons related to your particular situation, the treatment carried out for the legitimate interest of the owner.
Furthermore, if the processing is carried out with automated tools, the interested party has the right to receive the Data in
a structured format, commonly used and readable by an automatic device, and, if technically feasible, to transmit it to
another holder without hindrance.
The interested party has the right to lodge a complaint with the competent supervisory authority in the Member State in
which he habitually resides or works or in the State in which the alleged violation occurred.


Third level
The third level is accessed by clicking on the link of the second level. A text box opens for each link.

Who is the data controller?
SPM Srl
Address: - Via Fontana dell’Oste, 29/A, 00034 – Colleferro (RM) – Italy – [Link] 155945810009
Email Address: spm@[Link]

What personal data is collected or acquired by the [Link] website?
[Link] usage data
[Link] acquires some personal data during its normal operation, the transmission of which is implicit in the use
of communication protocols or relating to your device or operating system and the IT environment of the same.
This is information that is not collected to be associated with identified interested parties, but which, by their very nature,
could, through processing and association with data held by third parties, allow users to be identified. This category of
data includes:
• internet protocol address (IP)
Geolocation data
[Link] acquires data relating to your geographical position (GPS, Wi-Fi, GSM network) to allow you to use our
services.
This data can only be collected when [Link] is active and if you have activated the use of geolocation services.
You can deactivate the geolocation services at any time by accessing the appropriate section of the permissions for the
localization of the operating system of your device. The choice to disable geolocation services is not definitive and you can
reactivate geolocation services in the same way.
Disabling the geolocation service does not allow the use of the functions present in [Link]
Data voluntarily provided by the user
On the registration page you will be asked to provide the following personal data: name, surname, profile picture, country,
postcode, town, date of birth, e-mail address, language, telephone, tax code, VAT number, iban

Why are your data processed? What legitimizes the treatment? How long do we keep your
Is the provision of data mandatory? What data?
happens if you don't provide the data?
To check the correct operation of Legitimate interest Until the end of the control and
[Link] and for its maintenance maintenance activities.

Until you ask to revoke your
For your registration to [Link]. Execution of the contract
registration at [Link]


Until you ask to revoke your
registration at [Link]
Execution of the contract
To configure your Assignment Letter and, after revocation, for the

ordinary prescription period of
10 years.
Until you ask to revoke your
registration at [Link]
Execution of the contract
For the generation of your Receipts or Invoices and, after revocation, for the

ordinary prescription period of
10 years.
Until you ask to revoke your
registration at [Link]
Execution of the contract
For the payment of your commissions and, after revocation, for the

ordinary prescription period of
10 years.

As long as the geolocation

For your geolocation and to allow you to use
Execution of the contract services of the device are kept
the services of [Link] izi di
active and [Link] is
[Link]
active
 Until you ask to revoke your
registration at [Link]
To fulfill obligations under regulations and
Need to fulfill legal obligations and, after revocation, for the
applicable national and supranational
ordinary prescription period of
legislation
10 years.

In the case of judicial litigation,

for the entire duration of the
If necessary, to ascertain, exercise or defend
Legitimate interest same, until the exhaustion of the
the rights of the owner in court
terms of availability of the

appeal actions

Once the aforementioned storage deadlines have elapsed, personal data will be destroyed, erased or made anonymous,
compatibly with the technical cancellation and backup procedures.

Mandatory provision of data
The provision of data in the registration form is mandatory for the conclusion and continuation of the contract. The
refusal to provide the aforementioned data therefore does not allow the registration and use of [Link].

Who will process my data? To whom can my data be communicated?
The data will be processed exclusively by SPM Srl employees and collaborators expressly authorized to process it.
The data will not be disclosed or transferred to third parties.
The data will be processed by subjects who carry out treatments on our behalf who perform the function of data
controller in particular to:
- company that takes care of server maintenance
The updated list containing the recipients is available by sending an email to spm@[Link]

Will my data be transferred outside the EU?
No

What are my rights?
You can ask the Data Controller for access to the data concerning you, their cancellation, the correction of inaccurate
data, the integration of incomplete data, as well as the limitation of treatment in the cases provided for by art. 18 of the
GDPR
You can object, at any time, in whole or in part, to the processing of data necessary for the legitimate pursuit of the
owner's interest.
In addition, if the conditions for exercising the right to portability pursuant to art. Are present 20 of the GDPR, you can
receive the data provided to the Data Controller in a structured format, commonly used and readable by an automatic
device, as well as, if technically feasible, to transmit them to another data controller without hindrance.
You can lodge a complaint with the competent supervisory authority, (in particular in the Member State in which you
habitually reside or work or in the State in which the alleged violation occurred).
The rights can be exercised by writing to the Data Controller by post, to the address indicated above, or by e-mail to the
following e-mail address: spm@[Link]. It is understood that, where your request is submitted by electronic means,
the information will be provided in a commonly used electronic format.