PRIVACY POLICY pursuant to Articles 13 and 14 of EU Reg. 2016/679, "Regulation".

The https://www.smartitude.eu/ website pays the utmost attention to the privacy of its visitors and users. To this end, this Privacy Policy ("Privacy Policy") describes how https://www.smartitude.eu/ together may collect, use and share your Personal Information and explains your rights in relation to that Personal Information.
This Privacy Policy applies to all users, including unregistered visitors, registered users (collectively, "Users", "you" or "your") and all services, including our websites, web applications, mobile applications and related services. This Privacy Policy is not intended to supersede the terms of any other contract you enter into with us, nor any rights you may have under other applicable data protection laws.
We encourage you to read this Privacy Policy and ensure that you fully understand our practices with respect to your Personal Information before accessing or using our Services. If, after reviewing and fully understanding this Privacy Policy, you object to our practices, you should immediately leave this Site and cease any further use of our Services. If you have any questions or concerns regarding this Privacy Policy, please contact us at marketing@smartitude.eu.
This policy describes our privacy practices - what Personal Information we collect about our Users, what we do with it, how we share it, and your rights with respect to that Personal Information.

1. CATEGORIES OF PERSONAL DATA
SMARTITUDE collects and processes the following data from those who access and visit the Site:
- Automatically collected personal data
Browsing data: The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to 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 user's operating system and IT environment.
Aggregate level information about user behavior on the Site collected through the use of cookies; for more information on SMARTITUDE's use of cookies.
- Personal data directly provided by you
Personal, contact and other data you provide when filling in the form on our website
Any contact with SMARTITUDE through direct contact or the optional and spontaneous sending of messages, whether by e-mail or traditional mail, to the SMARTITUDE addresses indicated on the Website entails the subsequent acquisition of the address, including e-mail, of the sender or of the relevant telephone number, necessary in order to respond to requests, as well as any other personal data included in the relevant communication;

2. PURPOSE AND LEGAL BASIS OF PERSONAL DATA PROCESSING
Personal data are collected and processed by telematic means, also with the aid of electronic and information means, in accordance with the principles of necessity, lawfulness, correctness, proportionality and transparency for the purposes and under the conditions of lawfulness (so-called legal bases) set out below:
To enable you to navigate on our Site and benefit from the services offered therein
To provide you with assistance where you request it and to answer your request by email or telephone;
For personnel search and selection purposes if you submit your CV on request or spontaneously. For further information on the use of your personal data
To send you via electronic communications, such as e-mail, sms and mms and other digital channels authorised by you, advertising and promotional material.
To ascertain liability in the event of hypothetical computer offences against the site and to deal with any conduct in breach of the provisions of the Data Protection Authority.
To comply with obligations imposed by laws or regulations or orders from competent authorities. The legal basis for such processing is the need to fulfil a legal obligation.
Finally, it should be noted that navigation data are subsequently used to obtain anonymous statistical information on the use of the site and to check its correct functioning.

3. NATURE OF PROVIDING PERSONAL DATA
The provision of data marked with an asterisk in the forms available on our Site is compulsory for the provision of the services requested, and failure to provide such data, or incomplete or untruthful communication, will make it impossible to provide the service requested. The provision of personal data other than those indicated above is optional and any refusal to provide such data will result in the impossibility, even partial, of pursuing the purposes indicated above.

4. RECIPIENTS OF PERSONAL DATA
For the purposes of the above-mentioned purposes, your personal data will be processed by authorised personnel of SMARTITUDE as well as authorised personnel of third parties acting as our data processors.

5. PERIOD AND PLACE OF STORAGE OF PERSONAL DATA
SMARTITUDE stores your personal data via servers located within the European Economic Area for as long as is strictly necessary to pursue the above-mentioned purposes in compliance with civil and tax retention obligations and within the limits provided for by law.
The data processed to fulfil any contractual obligation with you, may be retained for the duration of the contract as well as for 10 years after the end of the fiscal year following the fiscal year in question, in order to deal with any tax assessment and/or dispute.
In the event of litigation: in the event that we need to defend ourselves or take action or even make claims against you or third parties, we may retain personal data that we reasonably deem necessary to process for such purposes, for as long as such a claim may be pursued.

6. HIS RIGHTS
As a data subject, pursuant to Articles 15-21 of the Regulation you have the right to:
receive confirmation of the existence of your personal data, access their content and obtain a copy (right of access);
update, amend and/or correct your personal data (right of rectification);
request the deletion or restriction of the processing of data in the cases provided for in the Regulation, including where data have been processed in breach of the law or where storage is not necessary in relation to the purposes for which the data were collected or otherwise processed (right to erasure and right to restriction);
withdraw consent, where given, at any time and without prejudice to the lawfulness of the processing based on the consent given before the withdrawal (right to withdraw consent);
within the limits of the Regulation, receive a copy of the data provided by you in a structured, commonly used and machine-readable format and request that such data be transmitted to another data controller if technically feasible (right to data portability);
you also have the right to object at any time to the processing of your data for direct marketing purposes including profiling insofar as it is connected with such direct marketing and in cases where the processing is based on legitimate interest (p. 2 lett. d - right to object).
You may exercise your rights at any time by writing to the following email address: or by sending a registered letter with acknowledgement of receipt to the following address Via Ildebrando Vivanti 99 - 00144 Rome (c.a. DPO SMARTITUDE).
We would like to remind you that in order to manage your consents where given (including revocation) and to change or update your personal data and profile, you can access your reserved area at any time and use the functionalities available in the 'change profile' section.
You may at any time lodge a complaint with the supervisory authority in the event of a breach of data protection regulations. More information can be found at the garanteprivacy website.

7. CONTACT DETAILS OF THE DATA CONTROLLER AND DATA PROTECTION OFFICER
The Data Controller is: Federico Capano at Via Ildebrando Vivanti 99 - 00144 Rome
The Data Protection Officer or DPO can be reached at the following email address: marketing@smartitude.eu or by sending a registered letter A/R to the following address, Via Ildebrando Vivanti 99 - 00144 Roma
8. COOKIES
The site uses only 'technical' cookies, such as navigation or session cookies, functionality cookies and analytical cookies, created and used by the website operator.
The site uses the service offered by Google Analytics in order to have a complete and reliable service of statistics on the use of the site. The data acquired through Google analytics may also be used by Google, according to the terms of service provided by Google.
9. UPDATES
This notice may be updated over time, in which case we will inform you. Last updated: December 2021.