Smart Technologies Privacy Policy

We treat your data with care!

Pursuant to Legislative Decree No. 196 of 30 June 2003 of the CODE REGARDING THE PROTECTION OF PERSONAL DATA, Smart Technologies guarantees compliance with the regulations on the protection of personal data. The personal data acquired will be used exclusively for the performance of contractual and customer relationship activities and WILL NOT BE TRANSFERRED to third parties, except in the cases legally admitted and listed below in point 4 of the INFORMATION.

 

Electronic communications, E-mails, Newsletters, data acquired through the website or Internet connection

Domain names, IP addresses and browser types, possibly detected through the institutional website or the newsletter sending system, are used to track traffic statistics and are in no way accompanied by any personal information. Subject to the prior consent in writing, explicit, free and documented - pursuant to art. 23 and 24 of the Code - Smart Technologies also communicates commercial offers, news and updates to its customers via e-mail and mobile telephony. In no case will unsolicited e-mails arrive via your addresses. At any time it is possible to renounce this type of communication or request the cancellation, modification or updating of all personal information in our possession, by sending an e-mail to the dedicated address This email address is being protected from spambots. You need JavaScript enabled to view it..

 

Information on the protection of personal data

Our company holds or is preparing to hold some data concerning you. Pursuant to art. 13 of the 'Code regarding the protection of personal data' Legislative Decree 30 June 2003 n. 196 we inform you about the use of your personal data and your rights. Further information can be obtained on the website of the Guarantor Authority www.garanteprivacy.it.
t is also possible to contact the Data Controller at the address This email address is being protected from spambots. You need JavaScript enabled to view it..

 

1. Owner and manager of the treatment

The Data Controller is Smart Technologies, via al sant. di ns della Guardia 36 i r, 16162 Genova. The Manager is not designated (optional designation based on Article 29 paragraph 1), but we specify that other employees, collaborators or associated companies functional to the completion of the contract or supply requested by you may become aware of the data.

 

2. Purpose of the Treatment

The processing of your personal data, collected from the Data Controller or from third parties on its behalf, will be exercised: A) for purposes relating to the execution of the contract (supply, sale, transport, etc.) and legal obligations (invoicing, writing and accounting records , etc.). The data will be processed for the duration of the contractual relationship, for subsequent legal obligations and possibly for further subsequent commercial communications; B) for commercial and marketing purposes, for information and promotion of products and offers, for surveying the quality of services provided, for market research, etc. Sensitive data are not used for these purposes.

 

3. Provision of data

• For the purposes referred to in point 2.A the provision of data IS MANDATORY and the refusal to provide them could prevent us from satisfying
  Your requests. For the processing of the data thus provided, the Data Controller is not obliged to request consent (Article 24.1-b / d);
• For the purposes referred to in point 2.B, the provision of data is OPTIONAL and helps to optimize a profitable business relationship; the lack of your consent DOES NOT PRECLUDE in any way the supply of products or services.

4. Communication and dissemination of data

• For the purposes referred to in point 2.A, your data may be communicated in Europe - for the same purposes and to the extent of strict competence - to the commercial network of the Data Controller and of group companies or associates, transporters, credit institutions, administrative, tax, contractual, legal, medical, labor, collaborators consultants; to public or private bodies, also following inspections or verifications (Tax Police, Labor Inspectorate, social security institutions, etc.).
• For the purposes referred to in point 2.B, your data may be communicated in Europe to companies that are part of the production and distribution chain or connected to the Data Controller, marketing, statistics and market research, information and commercial promotion services companies operating for account of the Holder. Personal data are not subject to disclosure.

5. Processing methods

The treatment is carried out with manual and electronic tools.

 

6. Rights of the interested party

Your rights are listed below in articles 7, 8, 9, 10 of the aforementioned Legislative Decree 196/2003 'Personal data protection code'. We remind you in particular that based on art. 7 has the right to know at any time what your data we have and how they are used, to request its updating, rectification, transformation into anonymous form, cancellation, blocking (for data processed in violation of the law) and to oppose to their treatment. The opposition presupposes your legitimate reason, while you can always exercise it in relation to advertising material, direct sales or market research. To exercise your rights, you can contact the Data Controller, Smart Technologies, to the e-mail address This email address is being protected from spambots. You need JavaScript enabled to view it..

 

For a transparent and complete information

Electronic communications, company newsletters, mobile telephony, spam

Smart Technologies uses the MailUp® service for managing and sending e-mail and sms messages, a professional system used by the most important Italian companies that allows you to collect detailed data on the recipients of communications - starting from the opening of the message to the topics clicked - in full compliance with the legislation governing privacy and the related data processing. For this, Smart Technologies also provides all the details on this data collection and processing. In fact, European legislation allows the use of so-called "web bugs" only after correct and complete information is provided to the user (you can find the full text of the European directive regarding e-mails at this link: ec.europa.eu).

 

The following is the text that MailUp® for a rigorous anti-spam policy (1) recommends adding to your information, a recommendation that Smart Technologies shares and fully implements.

 

Email and SMS Analytics

Smart Technologies uses MailUp®, a professional solution to manage the sending of newsletters, e-mail marketing campaigns and sms marketing, with the aim of analyzing traffic, optimizing the contents and the quality of the messages sent. MailUp® is a system physically located in Italy and offered by the company NWEB Srl (2), which manages the system in full compliance with the law and in agreement with the sender. The system does not use cookies, small text files that allow anonymous analysis of how the site is used, but works by inserting a unique tracking code on some links (at the discretion of the sender) and an image, which allows to detect the downloading of the images contained in the message (which is interpreted as the opening of the message by the recipient), or an equivalent system based on css (style sheets) to detect the opening of messages and -mail in the case of sending with embedded images (Mhtml). These techniques are commonly called "web bugs". Whoever sends the message has the right to activate or deactivate the detection of this information, as well as being able to enter
additional tracking codes on links, originating from web analytics systems. Any information stored in the MailUp® system is the date and time of downloading the images / css or clicking on one of the links traced. At the web log level, the IP and the client used to download the image / css or to click on one of the traced links are also stored on the MailUp® frontend servers, for a period of 6 months. This last information is only available to the Judicial Authority (eg Postal Police) if requested, but it is not visible or accessible by the sender, nor can it be viewed within MailUp®.

 

(1) Spam is defined as any e-mail message, regardless of content, sent to multiple users who have not explicitly consented to the sending of such e-mail. The abuse of personal data, such as the use of e-mail addresses to send unsolicited messages, in Italy is a crime that is severely punished, whether it is a B2B or B2C user. If you believe you are the victim of abuse or a spam episode, please describe the incident in detail to This email address is being protected from spambots. You need JavaScript enabled to view it. and also copy the sender of the offending communication. If possible, attach the message in full.

(2) NWeb is a member of the Internet Advertising Bureau Italia, the most prestigious international organization of companies working in the Internet sector, and is also a company with ISO 9001: 2000 Certified Quality. The e-mails sent with MailUp are also Zero Impact (R), certified by Lifegate. NWeb provides the "MailUp" e-mail marketing and newsletter management service. This service is a tool that allows you to send newsletters, text messages and e-mail marketing. It is used by hundreds of customers, both in Italy and abroad, who are directly responsible for the processing of their communications data.

 

Legislative Decree 196 of 30 June 2003 - TITLE II: RIGHTS OF THE INTERESTED PARTY

Art. 7. Right of access to personal data and other rights

1. The interested party has the right to obtain confirmation of the existence or not of personal data concerning him, even if not yet recorded, and their communication in an intelligible form.

 

2. The interested party has the right to obtain information:

• a) the origin of the personal data;
• b) the purposes and methods of the processing;
• c) of the logic applied in case of treatment carried out with the aid of electronic instruments;
• d) the identity of the owner, manager and the representative appointed under article 5, paragraph 2;
• e) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents.

3. The interested party has the right to obtain:

• a) updating, rectification or, when interested, integration of data;
• b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; < / li>
• c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible or involves the use of means that are manifestly disproportionate to the protected right.

4. The interested party has the right to object, in whole or in part:

• a) for legitimate reasons, to the processing of personal data concerning him, even if pertinent to the purpose of the collection;
• b) to the processing of personal data concerning him for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.

Art. 8. Exercise of rights

1. The rights referred to in Article 7 are exercised with a request addressed without formalities to the owner or manager, also through a person in charge, to whom suitable feedback is provided without delay.

2. The rights referred to in Article 7 cannot be exercised with a request to the owner or manager or with an appeal pursuant to Article 145, if the processing of personal data is carried out:

• a) based on the provisions of the decree-law of 3 May 1991, n. 143, converted, with modifications, by the law July 1991, n. 197, and subsequent amendments, concerning money laundering;
• b) based on the provisions of the decree-law of 31 December 1991, n. 419, converted, with modifications, by law 18 February 1992, n. 172, and subsequent amendments, regarding support for victims of extortion requests;
• c) by parliamentary committees of inquiry set up pursuant to article 82 of the Constitution; pg 3 of 3 last updated 05/2010
• d) by a public entity, other than public economic entities, on the basis of an express provision of the law, for exclusive purposes relating to monetary and currency policy, the payment system, the control of intermediaries and credit and financial markets, as well as the protection of their stability;
• e) pursuant to article 24, paragraph 1, letter f), limited to the period during which an effective and concrete prejudice could arise for the carrying out of defensive investigations or for the exercise of the right in court; < / li>
• f) by suppliers of electronic communications services accessible to the public in relation to incoming telephone communications, unless an actual and concrete prejudice may arise for the carrying out of defensive investigations pursuant to law no. 397;
• g) for reasons of justice, in judicial offices of all levels or the Higher Council of the Judiciary or other self-governing bodies or the Ministry of Justice;
• h) pursuant to article 53, without prejudice to the provisions of law no. 121.

3. The Guarantor, also upon notification of the interested party, in the cases referred to in paragraph 2, letters a), b), d), e) and f), shall provide in the manner referred to in articles 157, 158 and 159 and, in the cases of referred to in letters c), g) and h) of the same paragraph, shall act in the manner referred to in article 160.

4. The exercise of the rights referred to in Article 7, when it does not concern data of an objective nature, may take place unless it concerns the rectification or integration of personal data of an evaluation type, relating to judgments, opinions or other subjective assessments, as well as an indication of conduct to be held or decisions being taken by the data controller.

 

Art. 9. Methods of exercise

1. The request addressed to the owner or manager can also be sent by registered letter, fax or e-mail. The Guarantor can identify another suitable system with reference to new technological solutions. When it concerns the exercise of the rights referred to in Article 7, paragraphs 1 and 2, the request can also be formulated orally and in this case it is briefly noted by the person in charge or manager.

2. In exercising the rights referred to in Article 7, the interested party may confer, in writing, a proxy or proxy to individuals, entities, associations or organizations. The interested party can also be assisted by a trusted person.

3. The rights referred to in article 7 referring to personal data concerning deceased persons may be exercised by those who have an interest of their own, or act to protect the interested party or for family reasons worthy of protection. < / p>

4. The identity of the interested party is verified on the basis of suitable elements of evaluation, also by means of available deeds or documents or by showing or attaching a copy of an identification document. The person acting on behalf of the interested party exhibits or attaches a copy of the power of attorney, or of the proxy signed in the presence of an appointee or signed and presented together with an unauthenticated photocopy of an identification document of the interested party. If the interested party is a legal person, an organization or an association, the request is made by the natural person legitimated according to the respective statutes or regulations.

5. The request referred to in article 7, paragraphs 1 and 2, is formulated freely and without constraints and can be renewed, unless there are justified reasons, after not less than ninety days.

 

Art. 10. Reply to the interested party

1. To ensure the effective exercise of the rights referred to in Article 7, the data controller is required to adopt suitable measures aimed, in particular:

• a) to facilitate access to personal data by the interested party
• b) to simplify the procedures and reduce the time required for replying to the applicant, also in the context of offices or services responsible for relations with the public.

2. The data are extracted by the manager or persons in charge and can be communicated to the applicant also orally, or offered for viewing by electronic means, provided that in such cases the understanding of the data is easy, also considering the quality and quantity of the information. If requested, the data will be transposed on paper or electronic media, or their transmission electronically.

3. Unless the request refers to a particular treatment or to specific personal data or categories of personal data, the reply to the interested party includes all personal data concerning the interested party however processed by the owner. If the request is addressed to a health professional or a health organization, the provision referred to in Article 84, paragraph 1 is observed.

4. When the extraction of data is particularly difficult, the response to the request of the interested party can also take place through the exhibition or delivery of copies of deeds and documents containing the personal data requested.

5. The right to obtain the communication of the data in an intelligible form does not concern personal data relating to third parties, unless the breakdown of the data processed or the deprivation of some elements makes the personal data relating to the interested party incomprehensible .

6. The communication of data is carried out in an intelligible form also through the use of intelligible handwriting. In case of communication of codes or abbreviations, the parameters for understanding their meaning are provided, also through the persons in charge.

7. When, following the request referred to in Article 7, paragraphs 1 and 2, letters a), b) and c), the existence of data concerning the interested party is not confirmed, asked for a contribution not exceeding the costs actually incurred for the research carried out in the specific case.

8. The contribution referred to in paragraph 7 cannot in any case exceed the amount determined by the Guarantor with a general provision, which can identify it on a flat-rate basis in relation to the case in which the data are processed by electronic means and the answer is given orally. With the same provision, the Guarantor can provide that the contribution may be requested when the personal data appear on a special support for which reproduction is specifically requested, or when, with one or more owners, a considerable use of means is determined in relation to the complexity or extent of the requests and the existence of data concerning the interested party is confirmed.

9. The contribution referred to in paragraphs 7 and 8 is also paid by postal or bank transfer, or by payment or credit card, where possible upon receipt of the reply and in any case no later than fifteen days from such feedback.