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Information regarding data processing

Information regarding data processing

Pursuant to current legislation - 2016/679 EU Regulation (GDPR) and Legislative Decree 196/2003 as amended by Legislative Decree 101/2018 (Privacy Code)-, in relation to personal data concerning you and which will form object of treatment, we inform you of the following.
Pursuant to said law, your personal data will be processed in accordance with principles of fairness, lawfulness, relevance, transparency and protection of your confidentiality and of your rights.

DATA CONTROLLER AND DATA PROTECTION OFFICER
The Data Controller is Sprinta S.r.l. in person of the legal representative pro tempore, based in Torino, corso Turati n.15/H.

You can request cancellation by writing to Sprinta S.r.l. corso Turati n.15/H, 10128 Torino or by sending an email to: responsabileprivacy@sprinta.it.

Pursuant to Art. 37 GDPR, the company has appointed a Data Protection Officer (DPO). The DPO can be contacted at the following email address: dpo@sprinta.it

1. PURPOSES AND LEGAL BASIS FOR DATA PROCESSING

a) The processing is aimed at activating the services offered by the Ediscom portals, at registration, and at managing requests or sign-ups for initiatives reserved for registered users; the legal basis of the processing is the need to fulfil the data subject’s requests pursuant to Article 6(1)(b) of the GDPR;
b) The processing, with your express consent, is aimed at collecting data for marketing purposes in order to send commercial communications by traditional means (ordinary mail and operator-assisted telephone calls) or automated means (e-mail, automated calls without an operator, SMS, RCS, push notifications, instant messaging apps, live chat, chatbots, MMS, social media, WhatsApp, Telegram) relating to the activities of the controller or of third-party clients, customers or partners of the controller belonging to the product categories listed in section 6, for their own marketing purposes; Communications sent by e-mail may contain tracking tools (so-called “tracking pixels”) that make it possible to collect statistical data relating, for example, to the opening of the message and to clicks on the links it contains, in order to monitor the performance of campaigns and improve the offer of products and services. Within the scope of this processing, specifically with regard to activities carried out through social media, data may be uploaded to such platforms (e.g. Meta, Google) in encrypted form for the delivery of social media campaigns; the legal basis of the processing is the data subject’s consent pursuant to Article 6(1)(a) of the GDPR;
c) With your express consent, the processing may be carried out for market and statistical analyses and for the analysis and definition of profiles and preferences for marketing purposes, so that we can offer you products and services that better match your needs, as well as a range of personalised promotions and discounts. Some Ediscom initiatives may include specific questions aimed at building a profile of you based on your tastes, preferences, habits, needs and/or consumer choices, so that we can send you marketing communications in line with your interests; the legal basis of the processing is the data subject’s consent pursuant to Article 6(1)(a) of the GDPR;
d) With your consent, the processing may be carried out in order to disclose data to third parties, as specified in section 6 below, for marketing activities. Some Ediscom initiatives may include specific questions aimed solely at disclosing your data to third parties belonging to product categories that best match your interests. In addition, prior to the actual disclosure of your data to third parties, technical matching operations may be carried out between databases in encrypted form, to ensure that such disclosure is in your interest; the legal basis of the processing is the data subject’s consent pursuant to Article 6(1)(a) of the GDPR;
e) The processing may be aimed at identifying the perpetrators of any unlawful acts, only upon specific request and on behalf of the competent authorities; the legal basis of the processing is the protection of the controller’s rights in relation to the legal obligations to which it is subject.

Finally, the processing may consist of the collection of anonymous, never identifying, information about the user’s behaviour while using the portals, in order to ensure the proper functioning of the controller’s websites and to enable the use of the services offered on them. Services and interactions with external platforms may also be used to offer a better browsing experience. These external services and platforms may collect some user data, governed directly by their own privacy settings; for further details please refer to the Cookie Policy

2. DATA PROCESSING METHODS AND DATA STORAGE TIME

Data processing:
a) is performed via operations or sets of operations as defined in applicable law: collection, recording and organization; processing, including alteration, alignment, combination; use, including consultation, disclosure, selection, extraction; blocking of disclosure, erasure, destruction; security, protection, including availability, confidentiality, completion, protection;
b) is performed by electronic or automated means, with the insertion and collection of data in electronic databases belonging to Sprinta S.r.l., through which operations listed in a) are then conducted;
c) is also performed to complete and enhance the data collected with freely and lawfully available data, by non-electronic means and organized in paper-based filing systems;
d) is performed directly by the controller’s organization, as well as possibly by third parties to provide services to their clients.
e) data collected to perform activities for the purposes described can be transferred abroad in accordance with the rules provided for in applicable law, by taking all appropriate precautions to ensure an adequate level of protection of said data.

Data will be processed by appointees or persons authorized to the processing appointed by the owner to carry out activities instrumental to the purposes described above. The data may also be processed by data processors, who act on behalf of Sprinta S.r.l. ex art. 28 of the GDPR. In particular, the data may be made available to third-party companies that carry out activities on behalf of Sprinta S.r.l. in outsourcing, to companies that provide business information and authorized to access public offices, registers and bulletins, and to banks for the purposes provided for by law. The identification data of any appointed managers may be acquired by writing to Sprinta S.r.l. at responsabileprivacy@sprinta.it or at the physical address of the headquarters of Sprinta S.r.l.

Data provided by the data subject can be consulted by banks where lawfully available and used to update, rectify and complete information already provided and to verify compliance with requirements to access specific benefits and advantages.
Moreover, personal data can be disclosed to third parties and to government departments in order to comply with contractual obligations and the law.

Data will be kept for the time strictly necessary in relation to the purposes pursued, taking into account legal obligations and the limits provided by law in relation to the deletion of data. In particular, the retention period of the data for marketing purposes is limited to the period during which the user is active or until the user revokes consent to the processing.

3. COOKIES

Cookies are text files that websites send to a visitor’s computer or other device connected to the internet, to uniquely identify the visitor’s browser itself or to save information or settings on the browser.
We use cookies to improve our website and to provide clients with better service and functionality. Specifically, we use them to remember the information provided by the user and to memorise the user’s preferences when using the website, allowing Sprinta S.r.l. to improve the performance and design of the website. They may be shared with analytical instrument suppliers and may also enable the provision of promotional information.
You can limit or disable the use of cookies via your browser, however in that case, some features of the websites could become inaccessible.
For more information, please read the specific cookie policy on the website.

4. NATURE OF THE PROVISION OF DATA

Without prejudice to the autonomy of the data subject, providing personal data shall be:
a) obligatory under domestic or EU law or regulations;
b) strictly necessary for implementing the services offered, as well as to fulfil accounting and tax requirements;
c) optional with the aim of performing informational, marketing and promotional activities regarding the services available to the data subject. The controller maintains that any mistake in communicating data considered obligatory (a-b) may render it impossible for the controller to guarantee the suitability of the processing pursuant to the contractual conditions for which it was provided, and may also result in the absence of communication of the data processing results according to legal obligations.

Moreover, please note that should you provide data and consent, you can at any point exercise your rights set forth in point “DATA SUBJECT RIGHTS” below, and that any consent given in relation to receiving messages through traditional or automated means can be revoked or limited to just one of the communication methods mentioned above.

5. REFUSAL TO PROVIDE DATA

Should the data subject refuse to provide personal data:
a) in cases referred to in point 1, a), they will be unable to use the services offered through the portal;
b) in cases referred to in point 1 b), c) and d), there will be no consequences on legal relationships that have been previously established, but it will exclude the possibility of performing informational or promotional activities regarding other initiatives available to the data subject.

6. DISCLOSURE OF DATA

a) With your express consent, personal data can be disclosed to Sprinta S.r.l.’s affiliates, subsidiaries and commercial partners for marketing purposes;
b) with your express consent, personal data can also be disclosed to Sprinta S.r.l.’s third-party clients, stakeholders and partners who, acting as independent data controllers, disseminate commercial communications via the internet, post, email, phone (text message, MMS, telemarketing). These third parties (the updated list of which is always available upon request from the Controller) belong to the product categories described below:
Communications: ICT products and services.
Finance and banking sector: financial firms, insurance companies, investments, social security.
Leisure: publishing, tourism, sport, collecting, photography, hobbies, communication and entertainment, art, music.
Distribution and business: electronics, computers, image and sound, fashion, accessories, clothing, textile, bazaar, cosmetics and sanitary hygiene, chemical, pharmaceutical and bio-technology, food, restaurants with food administration license, supermarkets, drinks, office supplies, furniture.
Automotive: products and services related to cars, industrial vehicles, bicycles and motorcycles, trucks, mechanics and metallurgy.
Energy and water: products related to electricity, hydrocarbons, gas, water and utilities.
NGOs and charities: products and services related to not-for-profit organizations, foundations.
Education, training, university.
Communication and services: advertising agencies, marketing firms, event managers, consultancies, PR firms, advertising sales companies, media centers, telecommunications, market researchers; mobile marketing agencies.
Cosmetic and dental industry.
Ecology and environment.
Construction, civil engineering and real estate products/services: construction, decoration, home, design, real estate agencies.
Exhibitions and events etc.
IT, internet, e-commerce websites.

If you want to know the third companies detailed list to which data could be transmitted, visit this webpage.
Any communication beyond those indicated above and any further dissemination will take place only with your explicit consent.
This list also corresponds to the product categories to which Sprinta's clients belong for whom it directly carries out commissioned marketing campaigns, acting, in that case, as the Data Processor.
c) Data could therefore be disclosed, transferred or provided under license with your express consent to natural and/or legal persons belonging to the categories described above, for the same purposes as those described in this document. These parties operate as “independent controllers” or as “processors”.
The data provided may be transferred to countries belonging to the European Union and to countries outside the EU, in order to comply with the aforementioned purposes. The data will be transferred according to Article 44 - General principle for the transfer; Article 45 - Transfer on the basis of an adequacy decision; Article 46 - Transfer subject to adequate guarantees, specifically the data will be transferred:
- to third countries or international organizations for which the Commission has intervened with an adequacy assessment (Article 45 of the EU Reg. 2016/679)
- towards third countries or international organizations that have provided adequate guarantees and in which the person concerned has rights to action and effective remembrance (article 46 EU Reg. 2016/679, also with contractual clauses and the other provisions referred to in Article 46 (3))
- towards third countries or international organizations on the basis of exceptions in specific situations (Article 49 of the EU Reg. 2016/679).

7. DATA SUBJECT RIGHTS

Within the limits and conditions provided for by law, the controller shall be obligated to respond to the data subject’s requests regarding their personal data.
During the period in which Sprinta processes your data, as a data subject, you may at any time exercise the following rights:
a) Right of access - you have the right to obtain confirmation as to whether or not a processing concerning your Data exists, as well as the right to receive any information relating to the same processing, and if so, to obtain access to your personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly if recipients in third countries or international organizations;
- when possible, the intended retention period of the personal data or, if not possible, the criteria used to determine this period;
- the existence of the data subject's right to request from the data controller the rectification or erasure of personal data or the restriction of processing of personal data concerning him or her or to object to the processing of personal data concerning him or her
- the right to lodge a complaint with a supervisory authority;
- where the data are not collected from the data subject, all available information about their origin;
- the existence of an automated decision-making process, including profiling;
b) Right to rectification - you have the right to obtain the rectification of your Data in our possession, if it is incomplete or inaccurate;
c) Right to erasure (so called "right to be forgotten") - under certain circumstances, you have the right to obtain the deletion of your Data held within our records if it is not relevant to the management of the contractual relationship or necessary due to legal obligation;
d) Right to restriction of processing - under certain circumstances, you have the right to obtain the restriction of processing concerning your Data, if not relevant to the management of the contractual relationship or necessary for legal obligation;
e) Right to portability - you have the right to obtain the transfer of your Data in our possession in favor of a different data controller;
f) Right to object - you have the right to object to the processing of Data about you based on the lawful condition of legitimate interest or the performance of a task of public interest or the exercise of public authority, including profiling, unless there are legitimate grounds for the Controller to continue the processing that override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of a legal claim
g) Right to withdraw consent - You have the right to withdraw your consent to the processing of your Data at any time, without prejudice to the lawfulness of the processing based on your consent prior to withdrawal.

The above rights, including the cancellation of your data, may be exercised by sending an email to responsabileprivacy@sprinta.it or by contacting the DPO by sending an email to dpo@sprinta.it or by writing to Sprinta S.r.l., at its registered office located at corso Turati n.15/H, Torino, 10128.

To oppose the sending of sms, without prejudice to the possibility, for some types of text messages without a personalized sender, to respond directly to the received text message by entering the text "Unsubscribe" or "Stop," it is possible to send an email to the above address to obtain access to the data and the erasure.

With regard to communications received by e-mail, you are guaranteed the option of withdrawing your consent on a granular basis. In particular, you may withdraw only your consent to the use of tracking tools (pixels) while continuing to receive communications, or withdraw your consent entirely, objecting to receiving further messages. This right can easily be exercised through the dedicated link in the footer of every e-mail received, which will take you to an area dedicated to managing your consents.

You also have the right to file a complaint with the Supervisory Authority or appeal to the Judicial Authority - if Sprinta refuses to comply with your requests, the reasons for the refusal will be provided.

If applicable, you have the right to file a complaint by lodging a petition directly with the Privacy Guarantor (Garante per la protezione dei dati personali, Piazza Venezia, 11, 00187, Rome or your National Privacy Guarantor) or, alternatively, by lodging an appeal with the competent Judicial Authority.

You also have the option of registering, free of charge and at any time, your landline and/or mobile phone number or physical mail address, with the Public Register of Oppositions ("RPO"): https://registrodelleopposizioni.it/. Registration cancels all consents you have previously given to any Holder, solely with respect to telemarketing activities (operator or automated calls) and the sending of commercial communications by paper mail. On the other hand, sms or email marketing activities do not fall within the scope.

This version of the notice on personal data processing was updated on the 27/10/2026.

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