Search
Close this search box.
Search
Close this search box.

Privacy Policy

Information on the processing of personal data pursuant to Article 13 of Regulation (eu) 2016/679 of the European Parliament and of the Council of April 27, 2016 ("General Data Protection Regulation")

  1. FOREWORD

This information is prepared, pursuant to Article 13 of Regulation (EU) 2016/679 ("Regulation"), by Sipla S.r.l., owner of the trademark "Sipla" and distributor of the products marked by that trademark ("Sipla"), and is intended:

  1. to those who interact with this website by completing and submitting the contact form on the Site ("Contact Form") and/or by writing to the e-mail address published on the Site ("E-Mail") and/or by making use of the chat service offered by the Site and provided by the company Zendesk Inc, headquartered at 1019 Market Street, 6th Floor, San Francisco, California, 94103 (USA) ("Chat Service" or "Chat") and/or by making use of the chat bot service offered by the Site and provided by the company Hello Umi S.L headquartered in Spain at Carrer de Mallorca, 184, CP 08036, Barcelona (Spain) and Tax ID ESB98767551 ("Chat Bot Service" or "Chat Bot") and/or by making use of the chat service offered by the Site and provided by the company TAWK.TO Inc, a US corporation with its registered office at 187 East Warm Springs Rd, SB298, Las Vegas, Nevada, 89119 and its affiliate TAWK.TO Ltd, a company headquartered in the United Kingdom (UK) 71-75 Shelton Street, London, Greater London, WC2H 9JQ (dedicated location for processing personal data of EU data subjects) ("Chat Service" or "Chat") and/or by making use of the "Qualified Lead" Service offered by the Site and provided by OUTGROW, a U.S. company headquartered at 401 Park Ave, 10th Floor, New York 10016 ("Qualified Lead Service");
  2. to those who contact Sipla S.r.l. by calling the Dedicated Number, which can be found on the Site or in other media (e.g., television) ("Dedicated Number");
  3. to those who, having contacted Sipla S.r.l., either by calling the Dedicated Number or by completing and submitting the Contact Form or E-Mail, are called back by Sipla S.r.l., in order to provide them, in the course of one or more phone calls ("Phone Calls"), with the information requested in connection with Remail Products, to collect any interest of the same in making an appointment with the Remail Products consultant ("Remail Consultant") at their home and/or to schedule such appointment.
  1. IDENTITY AND CONTACT INFORMATION OF Sipla S.R.L AS DATA CONTROLLER.

The data controller is Sipla S.r.l, with registered office at Via Ferruccio Lamborghini, 120, 41121, Modena, Italy ("Sipla"), telephone 059 5801438, email: amministrazione@Sipla.it.

  1. TYPE OF DATA BEING PROCESSED

The data processed under this policy are:

  • the data provided by the user through the Site by filling in and sending the Contact Form (e.g., first name, e-mail address, telephone, province) or the E-Mail or Chat Service (e.g., first name, last name telephone number); or by using the Chat Bot Service (e.g., first name, last name telephone number); or by using the "Qualified Lead" Service.
  • data provided by the user and/or collected during the Telephone Calls (e.g., telephone number, last name, mailing address, information about whether a spouse exists, information about legal status (ownership/rental) and/or the type of housing, etc.).

It should also be noted that Sipla retains, within the terms of the law, the log files and IP addresses used when accessing the Site in order to prevent and ascertain possible fraud.

  1. PROCESSING OF DATA BY Sipla TO RESPOND TO DATA SUBJECT'S REQUESTS.

Sipla will process personal data provided by users for the following purposes:

  • To fulfill the user's request to be contacted or re-contacted for information about Sipla services;
  • Provide the information about those Products;
  • Gather any interest the user may have in making an appointment with the Sipla Consultant at their home and, if appropriate, schedule that appointment;
  • in the case of scheduling the appointment with the Sipla Consultant, allow the appointment to be made and the Sipla Consultant to provide the counseling;
  • For administrative-accounting purposes related to those purposes.

The legal basis for this processing is the execution of pre-contractual measures taken at the request of the data subject (Art. 6.1.b) of the Regulations) or, in the case of administrative-accounting purposes, the legal obligation, referred to in Art. 6.1.c) of the Regulations.

For this purpose, Sipla will process the user's data for the time strictly necessary for the performance of the individual processing activities (e.g., the data necessary for the setting and performance of the appointment with the Sipla Consultant will be processed until the making of that appointment), it being understood that: (i) the data of users, including the content of Chat conversations, Chat Bot and "Qualified Lead" Service forms, who, contacted or re-contacted by Sipla, on the basis of their requests, decide not to initiate the relationship with Sipla will be processed for the maximum period of six months after collection; (ii) the data conferred by users during the Chats or within the Chat Bot or within the forms of the "Qualified Lead" Service, including the content of the conversations, will be processed for the maximum period of seven days, in the event that you have not provided via the Chats or the Chat Bot or the forms of the "Qualified Lead" Service your contact information or have not expressed a willingness to be contacted or have not made via the Chats or the Chat Bot or the forms of the "Qualified Lead" Service a request for assistance, except for the processing provided for in Sections 10.1, 10.2, 10.3 and 10.4 of this policy (iii) once the maximum retention periods relating to the purpose in question have expired, Sipla may retain the data for the purposes and for the maximum retention periods referred to in Sections 6, 7 and 8 of this policy and/or, in any case, in the cases established by the Regulations and/or the law.

More Information

The provision of data for the purpose in question is optional: that is, there is no legal or contractual obligation to provide the data; however, since their processing is necessary to enable Sipla to fulfill the user's request to be contacted or re-contacted for information about Sipla services, provide the information about such Products, collect the user's possible interest in making an appointment with the Sipla Consultant at his or her home address and, if appropriate make such appointment and, if scheduled, allow the making of the same and the provision of the advice by the Sipla Consultant, any refusal by the user to provide such data will result in the user being unable to receive the requested information and/or make the appointment with the Sipla Consultant and/or take advantage of his/her advice.

  1. DATA PROCESSING BY Sipla FOR GENERIC MARKETING PURPOSES.

Subject to the user's express consent, Sipla will process the personal data provided by users in order for Sipla to send commercial communications, referring to its own and/or third parties' products and/or services, and to carry out market research, also aimed at assessing the degree of user satisfaction (customer satisfaction), by telephone, e-mail or other automated means (e.g.: applications) (so-called generic marketing purposes).

The legal basis for this processing is the express consent of the user (Art. 6.1(a) of the Regulations).

Users may express such consent by checking the appropriate box contained in the Contact Form and located next to the request for consent.

Users may revoke the consent given and/or object, at any time, to the processing of their data for marketing purposes:

  • by contacting Kreaai contact details given in Section 2 of this policy and, in particular, by emailing amministrazione@Sipla.it or calling 059 5801438;
  • via the appropriate link at the bottom of any e-mail with promotional content sent by Sipla.

Providing data for the purpose of generic marketing is optional: there is no legal or contractual obligation on you to provide such data for this purpose and/or to consent to the processing of your personal data for this purpose.

For marketing purposes, Sipla will process the user's data until consent is revoked and/or the right to object is exercised and, in any case, no later than 24 months from the collection of the data, reserving the right, before the expiration of this period, to ask the user to renew consent and/or update the data.

More information

Users are advised of the following:

  • for the purpose of generic marketing Sipla uses personal data initially collected for other purposes and, in particular, for the purpose of responding to inquiries from the data subject; such further processing is permitted, as it is based on the consent of the data subject;
  • revocation of consent does not affect the lawfulness of processing based on consent given before revocation;
  • opposition and/or revocation manifested through automated means of contact (e.g., e-mail) also extends to the sending of communications through traditional means (e.g., by telephone), without prejudice to the possibility for the interested party to exercise this right in part, i.e., by opposing, for example, only the sending of promotional communications carried out through automated means;
  • in the event that you object to the processing of your data for generic marketing purposes and/or revoke your consent to the processing for generic marketing purposes, your data will no longer be processed by Sipla for that purpose and will only be retained by Sipla if there is another legal basis (such as, for example, the establishment, exercise or defense of a legal or administrative right);
  • failure to disclose data for the purpose of generic marketing and/or failure to provide consent to such processing and/or revocation of such consent and/or exercise of the right to object does not have any consequence on the user's ability to obtain response to his/her requests.
  1. DATA PROCESSING BY Sipla FOR SERVICE/CUSTOMER CARE NAFLICS.

Sipla will process users' data for generic assistance and customer care activities and thus to respond to requests for information from users, by any means formulated (for example: through the Contact Form, by e-mail, by telephone or through the Chat services, Chat Bot and the forms of the "Qualified Lead" Service) or to respond to complaints, reports and disputes, including those referring to products marked with the "Sipla" brand.

The legal basis for this processing is the legitimate interest of Sipla (Art. 6.1.f) of the Regulations).

It is Sipla's legitimate interest to respond to users' requests for assistance and/or reports and/or disputes and/or complaints. This legitimate interest of Sipla also coincides with the legitimate interest of the users themselves who make the requests and/or reports and/or disputes and/or complaints in question and who, therefore, in the context of their relationship with Sipla, can be reasonably expected to expect that their personal data will be used by Sipla to provide them with feedback.

The legitimate interest of Sipla, thus identified, can therefore be considered to prevail over the fundamental rights and freedoms of the data subject, also because of these reasonable expectations and the relationship existing between the data subject and Sipla as well as in view of the nature of the data processed and the coincident interest of the data subjects themselves.

The user has, in any case, the right to object at any time, for reasons related to his or her personal situation, to the processing of personal data concerning him or her for the purpose in question (i.e. assistance and customer care).

To exercise this right, the user may contact Sipla at the contact details indicated in Section 2 of this policy and, in particular, by writing to the e-mail address amministrazione@Sipla.it or by calling 059 5801538.

More information

In case of exercising the right to object to the processing of data for the purpose of assistance/customer care, Sipla shall refrain from further processing of users' personal data for that purpose, unless it proves the existence of compelling legitimate grounds for processing that override the interests and rights and freedoms of the data subject or for the establishment, exercise or defense of a legal claim.

The provision of personal data for the purpose in question is optional: that is, there is no legal and/or contractual obligation to provide the data; however, given the purpose of the processing, failure to provide the data and/or exercise the right to object may make it impossible to respond to users' requests and/or reports and/or complaints and/or objections, if the response to such requests involves the processing of the user's personal data.

For this purpose, Sipla will process the user's data for the time necessary to carry out the requested activities and, therefore, specifically, for the time necessary to provide the information requested by the user or to respond to complaints and/or reports and/or disputes submitted by the user.

  1. DATA PROCESSING BY Sipla TO ENABLE THE EXERCISE OF RIGHTS.

Sipla will process user data for the purpose of:

  • To respond to requests to exercise rights arising from the pre-contractual or contractual relationship with Sipla;
  • To carry out activities that prove necessary as a consequence of exercising such rights;
  • Receive and acknowledge requests to exercise personal data protection rights under the Regulations and carry out all consequent activities.

The legal basis for this processing is the fulfillment of legal obligations to which Sipla is subject (Art. 6.1.c) of the Regulations).

The provision of data for this purpose is compulsory, because their processing is necessary to allow Sipla to fulfill legal obligations as well as the user to exercise the rights that the law or the relationship with Sipla give him. Any refusal to provide data for this purpose will make it impossible for the user to exercise these rights.

For this purpose, Sipla will process the data until the expiration of the legal terms provided for the exercise of the right (prescription and/or forfeiture period) or, in the case of the exercise of these rights, for the time necessary to manage and close the file; in the case of the exercise of the rights provided for by the Regulations, the data will be processed until the data controller certifies that it has fulfilled the request or until the fulfillment itself, whichever occurs last.

  1. PROCESSING OF DATA BY Sipla FOR PURPOSES OF ACCURACY, EXERCISE OR DEFENSE OF A RIGHT.

Sipla will process user data for the purpose of establishing, exercising, or defending a right in all relevant venues.

The legal basis for this processing is the legitimate interest of the data controller (Art. 6.1(f) of the Regulations).

It constitutes the legitimate interest of the data controller to pursue remedies to ensure compliance with its contractual and/or pre-contractual rights or to demonstrate that it has fulfilled its obligations arising from the relationship, including pre-contractual, with the data subject or imposed on the data controller by law. This legitimate interest is, in turn, grounded in the constitutionally protected right to defense. It can therefore be considered to prevail over the fundamental rights and freedoms of the data subject, also because of the data subject's reasonable expectations.

The user has, in any case, the right to object, at any time, for reasons related to his or her personal situation, to the processing of personal data concerning him or her for the purpose in question (i.e. defense of a right/justice purposes).

To exercise this right, the user may contact Sipla at the contact details indicated in section 2 of this policy and, in particular, by writing to the e-mail address amministrazione@Sipla.it or by calling 059 5810438

More information

The user is advised that, in particular, Sipla will retain and possibly use the data:

  1. to prove that they have responded to the request for information on Sipla services /or assistance made by the data subject and/or that they have made appointments with the Sipla Consultant requested by the data subject and/or that such appointments have been carried out through the Sipla Consultant and/or to initiate or respond to actions relating to the pre-contractual or contractual relationship with the data subject before any administrative and/or jurisdictional authority and/or to protect their rights in the preparatory stages of the judgment and/or proceedings; for this purpose, the data will be kept for 5 years, as the case may be, from the last response to the data subject's request or from the setting of the appointment with the Sipla Consultant or the making of such appointment;
  2. to prove that you have consented to the exercise of your rights under the Regulations and/or the law and that you have carried out what the law requires in this regard;
  3. To prove that they have responded to users' complaints and/or reports and/or grievances;
  4. in the case of the exercise of rights provided by law in relation to the pre-contractual or contractual relationship with the interested party, the data will be kept for 5 years, starting from the closure of the file or from the execution of the action that defines it; the closure of the file means the last correspondence relating to the exercise of the right in question;
  5. in the case of the exercise of rights provided by law in relation to the pre-contractual relationship with the interested party, the data will be kept for 5 years, starting from the closure of the file or the performance of the action that defines it; the closure of the file means the last correspondence relating to the exercise of the right in question;
  6. in the case of complaints and/or reports and/or disputes, the data will be kept for three years after the closure of the case, which is to be understood as the last correspondence on the matter.

It is also reported that:

  • the provision of data for this purpose is optional: there is no legal or contractual obligation for the data subject to provide data for this purpose;
  • for the purpose in question, data collected initially for a different purpose are used, the further processing of which is permitted insofar as it is based on the legitimate interest of the data controller, given the compatibility of this further purpose with the initial purpose of the collection, taking into account also the fact that, insofar as the processing is necessary for the establishment, exercise and defense of a right, the data controller is, likewise, exempt from the obligation to erase, by express provision of the Regulations;
  • in the case of exercising the right to object, in fact, the data controller shall refrain from further processing personal data, unless the data controller demonstrates the existence of compelling legitimate grounds for processing that override the interests, fundamental rights and freedoms of the data subject or for the establishment, exercise or defense of a legal claim.
  1. PROCESSING BY Sipla OF HEALTH-RELATED DATA.

For the submission of the Contact Form and/or in general for the request and/or provision of information about Remail Products, including through the use of the Chats or the Chat Bot or the forms of the "Qualified Lead" Service, and/or for the setting of the appointment with the Remail Consultant, Sipla does not require the provision of health-related data. Indeed, it is expressly prohibited for the data subject to provide health-related data through the Chats, the Chat Bot or through the forms of the "Qualified Lead" Service.

Notwithstanding this prohibition, it may happen, however, that given the type of products marked "Remail" or the type of request by users, Sipla may process data that, according to Article 4.15) of the Regulations, may be considered as "data relating to health," insofar as from them the state of health of a natural person may be inferred, even indirectly, or information relating to the state of health of a natural person may be inferred.

Such data will be processed only for the purpose of executing the user's request and only and exclusively with the explicit and specific consent of the data subject, which will be requested from the user once the user's request containing such data has been received and prior to further processing of the same, without prejudice to the prohibition of providing health-related data via the Chats, the Chat Bot or the forms of the "Qualified Lead" Service.

The legal basis for this processing is the explicit consent of the data subject (Art. 9.2(a) of the Regulations).

The provision of health-related data is optional: there is no legal or contractual obligation on the user to provide such data. Providing consent to the processing of such data is also optional. However, given the purpose of the processing (i.e. to enable the response to the requests of the data subject and/or the exercise of rights by the data subject), in the case of failure to provide such data and/or failure to provide consent to the processing of data relating to health, the user will not be able to obtain a response to the request, including the exercise of a right, made. In the case of failure to provide consent to the processing of health-related data, any health-related data that may have already been voluntarily provided by the data subject will be immediately deleted. Please note that it is not permitted to give health-related data through the Chats, the Chat Bot or through the forms of the "Qualified Lead" Service.

More information

It is reported that:

  • health-related data may not be submitted through the Chats, the Chat Bot, or through the "Qualified Lead" Service;
  • the consent given will be effective only in relation to the specific request made by the data subject and the health-related data contained in it and/or related to it;
  • in the event that you make a new request containing and/or involving the processing of health-related data, your consent to the processing of such data will be sought from you again, it being understood that the consent given in connection with a request may be revoked at any time without affecting the lawfulness of the processing based on the consent given prior to revocation.

The user may revoke consent by contacting Sipla at the contact details indicated in section 2 of this policy and, in particular, by writing to the e-mail address aministrazione@Sipla.it or by calling 059 5801438.

Sipla will process the data in question for the time necessary to handle the request made by the data subject and, therefore, with the maximum retention times indicated in Sections 4, 6, 7 and 8 of this information notice, without prejudice to the additional retention periods permitted by law or the Regulations. Any health-related data provided will not be processed for marketing purposes.

10.1 DATA PROCESSING BY Sipla FOR PURPOSES OF COMMUNICATION TO ZENDESK INC.

Subject to the user's express consent, Sipla will disclose personal data provided by users through Chat, including the content of conversations, to Zendesk Inc. located at 1019 Market Street, 6th Floor, San Francisco, California, 94103 (USA), to enable it to analyze users' use of Chat in order to develop and improve the Chat Service

The legal basis for this processing is the express consent of the user (Art. 6.1(a) of the Regulations).

Users may express such consent by selection of the "I Agree" button found in the pop-up that opens on the Site when the user clicks on the Chat widget called "Use Chat" ("Pop Up").

The user may revoke the consent given at any time by contacting Sipla at the contact details indicated in section 2 of this policy and, in particular, by writing to the e-mail address amministrazione@Sipla.it or by calling 059 5801438.

The provision of data for the purpose in question is optional: there is no legal or contractual obligation on the user to provide such data for this purpose and/or to give consent to the processing of his/her personal data for this purpose. Failure to provide data and/or consent for the purpose in question, however, will result in your inability to use the Chat Service. In order to be able to develop and improve the Chat Service, it is necessary, in fact, to analyze users' use of Chat. Thus, the use of the Chat involves the disclosure to Zendesk Inc. of personal data provided through the Chat, including the content of the conversations. In the event that the user does not wish his or her data to be disclosed to Zendesk Inc. the user, therefore, should refrain from using the Chat Service. In the event that the user has clicked on the Chat widget, he/she may express his/her refusal to consent to the disclosure of data to Zendesk Inc, by clicking on the "Refusal" button, present in the Pop Up. The user may, however, request information or assistance by calling 059 5801438 or writing to amministrazione@Sipla.it, or ask to be contacted by filling out the contact form found on the Site and to which the user is redirected through the link in the Pop Up. Sipla thus offers two equivalent information and assistance services: one, the Chat Service, which requires the consent of the data subject, and another, the service provided as a result of requests received through the Contact Form or E-mail or by telephone, which does not require the consent of the data subject. Failure to provide consent to the communication of data to Zendesk Inc. therefore has no impact on the data subject's ability to receive information and/or assistance from Sipla: in fact, the user who does not provide consent to such communication cannot request and/or obtain information and/or assistance through the Chat but can request and/or obtain information and/or assistance through the Contact Form and/or E-mail and/or telephone.

For this purpose, Sipla will process the user's data for as long as it is strictly necessary for communication to Zendesk Inc. and, in any case, until consent is revoked.

More information

Users are advised of the following:

  • for the purpose of communication to Zendesk Inc, Sipla uses personal data initially collected for other purposes and, specifically, for the purpose of responding to requests from the data subject; such further processing is permitted, as it is based on the consent of the data subject;
  • revocation of consent does not affect the lawfulness of processing based on consent given before revocation;
  • in the event that you revoke your consent to the processing for the purpose of communication to Zendesk Inc.: (i) your data will no longer be processed by Sipla for that purpose and will be retained by Sipla only if another legal basis exists (such as, for example, the establishment, exercise or defense of a right in judicial or administrative proceedings or the purposes referred to in Sections 4 or, respectively, 6 above); (ii) Sipla will notify Zendesk Inc. the revocation of consent as well as the possible exercise by the data subject of the other rights set forth in Articles 15 to 22 of the Regulations, if such exercise is made against Sipla, as the source of the data;
  • the data, once disclosed to Zendesk Inc. with the consent of the data subject, will be processed by Zendesk Inc. as an autonomous data controller, based on Zendesk Inc.'s privacy policy.

10.2 DATA PROCESSING BY Sipla FOR COMMUNICATION PURPOSES TO HELLO UMI S.L (LANDBOT.IO - CHAT BOT SERVICE).

To improve the browsing experience on the site Sipla makes use of a chat bot. By opening the chat bot the user confirms that he/she adheres to the information expressed in this privacy policy. The chat bot is operated with landbot.io by the company Hello Umi S.L based in Spain at Carrer de Mallorca, 184, CP 08036, Barcelona (Spain) and Tax ID ESB98767551

The legal basis for this processing is the express consent of the user (Art. 6.1(a) of the Regulations).

The user will be able to express such consent by selecting the "check box" within the Chat Bot Service that opens on the Site when the user clicks on the Chat Bot widget named " Do you want to turn your tub into a shower and request a free online quote Now?"

The user may revoke the consent given at any time by contacting Sipla at the contact details indicated in section 2 of this policy and, in particular, by writing to the e-mail address amministrazione@Sipla.it or by calling 059 5801438.

The provision of data for the purpose in question is optional: there is no legal or contractual obligation on the user to provide such data for this purpose and/or to give consent to the processing of his/her personal data for this purpose. Failure to provide data and/or consent for the purpose in question, however, will result in your inability to use the Chat Bot Service. In order to be able to develop and improve the Chat Bot Service, it is necessary, in fact, to analyze users' use of the Chat. Therefore, the use of the Chat Bot involves the disclosure to Hello Umi S.L of personal data provided through the Chat Bot Service, including the content of conversations. In the event that the user does not wish his or her data to be disclosed to Hello Umi S.L, the user, therefore, should refrain from using the Chat Bot Service. In the event that the user has clicked on the Chat Bot widget, he/she may express his/her refusal to give consent to the communication of his/her data to Hello Umi S.L, by clicking on the "No, I don't care" button on the Chat Bot Form. The user may, however, request information or assistance by calling 059 5801438 or writing to the e-mail address amministrazione@Sipla.it, or ask to be contacted by filling out the contact form found on the Site and to which the user is redirected through the link in the Pop Up. Sipla thus offers two equivalent information and assistance services: one, the Chat Service, which requires the consent of the data subject, and another, the service provided as a result of requests received via the Contact Form or E-mail or by telephone, which does not require the consent of the data subject. Failure to give consent to the communication of data to Hello Umi S.L, therefore, has no impact on the data subject's ability to receive information and/or assistance from Sipla: a user who does not give consent to such communication, in fact, cannot request and/or obtain information and/or assistance through the Chat Bot but can request and/or obtain information and/or assistance through the Contact Form and/or E-mail and/or telephone.

For the purpose in question, Sipla will process the user's data for the time strictly necessary for communication to Hello Umi S.L. and, in any case, until consent is revoked.

More information

Users are advised of the following:

  • for the purpose of communication to Hello Umi S.L, Sipla uses personal data initially collected for other purposes and, in particular, for the purpose of responding to requests from the data subject; such further processing is permitted, as it is based on the consent of the data subject;
  • revocation of consent does not affect the lawfulness of processing based on consent given before revocation;
  • in the event that you revoke your consent to the processing for the purpose of communication to Hello Umi S.L: (i) your data will no longer be processed by Sipla for that purpose and will be retained by Sipla only in the event that there is another legal basis (such as, for example, the establishment, exercise or defense of a right in judicial or administrative proceedings or the purposes referred to in sections 4 or, respectively, 6 above); (ii) Sipla will communicate to Hello Umi S.L the revocation of consent as well as any exercise by the data subject of the other rights set forth in Articles 15 to 22 of the Regulations, if such exercise is made against Sipla, as the source of the data;
  • the data, once disclosed to Hello Umi S.L, subject to the consent of the data subject, will be processed by Hello Umi S.L as an autonomous owner, based on the privacy policy of Hello Umi S.L.

10.3 DATA PROCESSING BY Sipla FOR COMMUNICATION PURPOSES TO TAWK.TO.

Subject to the user's express consent, Sipla will disclose personal data provided by users through Chat, including the content of conversations, to TAWK.TO Inc. a U.S. company with registered office at 187 East Warm Springs Rd, SB298, Las Vegas, Nevada, 89119 and its affiliate TAWK.TO Ltd, a company headquartered in the United Kingdom (UK) 71-75 Shelton Street, London, Greater London, WC2H 9JQ (dedicated location for processing personal data of EU data subjects), to enable it to analyze users' use of chat in order to develop and improve the Chat Service

The legal basis for this processing is the express consent of the user (Art. 6.1(a) of the Regulations).

Users will be able to express such consent by selection of the pre-posted button found in the pop up that opens on the Site when the user clicks on the Chat widget named "Would you like assistance?" ("Pop Up").

The user may revoke the consent given at any time by contacting Sipla at the contact details indicated in section 2 of this policy and, in particular, by writing to the e-mail address amministrazione@Sipla.it or by calling 059 5801438.

The provision of data for the purpose in question is optional: there is no legal or contractual obligation on the user to provide such data for this purpose and/or to give consent to the processing of his/her personal data for this purpose. Failure to provide data and/or consent for the purpose in question, however, will result in your inability to use the Chat Service. In order to be able to develop and improve the Chat Service, it is necessary, in fact, to analyze users' use of Chat. Therefore, the use of the Chat involves the disclosure to TAWK.TO of personal data provided through the Chat, including the content of the conversations. In the event that the user does not wish his or her data to be disclosed to TAWK.TO, the user, therefore, should refrain from using the Chat Service. In the event that the user has clicked on the Chat widget, he/she may express his/her refusal to give consent to the disclosure of data to TAWK.TO by clicking on the "Refusal" button, present in the Pop Up. The user may, however, request information or assistance by calling 059 5801438 or writing to the e-mail address amministrazione@keaweb.it, or ask to be contacted by filling out the contact form found on the Site and to which the user is redirected through the link in the Pop Up. Sipla thus offers two equivalent information and assistance services: one, the Chat Service, which requires the consent of the data subject, and another, the service provided as a result of requests received through the Contact Form or E-mail or by telephone, which does not require the consent of the data subject. Failure to give consent to the communication of data to TAWK.TO, therefore, has no impact on the data subject's ability to receive information and/or assistance from Sipla: a user who does not give consent to such communication, in fact, cannot request and/or obtain information and/or assistance through Chat but can request and/or obtain information and/or assistance through the Contact Form and/or E-mail and/or telephone.

For the purpose in question, Sipla will process the user's data for the time strictly necessary for communication to TAWK.TO and, in any case, until consent is revoked.

More information

Users are advised of the following:

  • for the purpose of communication to TAWK.TO, Sipla uses personal data initially collected for other purposes and, in particular, in order to respond to requests from the data subject; such further processing is permitted, as it is based on the consent of the data subject;
  • revocation of consent does not affect the lawfulness of processing based on consent given before revocation;
  • in the event that you revoke your consent to the processing for the purpose of communication to TAWK.TO: (i) your data will no longer be processed by Sipla for that purpose and will be retained by Sipla only in the event that there is another legal basis (such as, for example, the establishment, exercise or defense of a right in judicial or administrative proceedings or the purposes referred to in sections 4 or, respectively, 6 above); (ii) Sipla will notify TAWK.TO the revocation of consent as well as the possible exercise by the data subject of the other rights referred to in Articles 15 to 22 of the Regulations, if such exercise is made against Sipla, as the source of the data;
  • data, once disclosed to TAWK.TO, subject to the consent of the data subject, will be processed by TAWK.TO as an autonomous data controller, based on TAWK.TO's privacy policy.

10.4 TRANSFER OF DATA BY Sipla FOR COMMUNICATION PURPOSES TO OUTGROW.

Subject to the user's express consent, Sipla will disclose personal data provided by users through the "Qualified Lead" Service forms, including the content of the forms, to OUTGROW, a U.S.-based company located at 401 Park Ave, 10th Floor, New York 10016, to enable it to analyze users' use of the System in order to develop and improve the "Qualified Lead" Service.

The legal basis for this processing is the express consent of the user (Art. 6.1(a) of the Regulations).

The user will be able to express such consent by selecting the pre-posted button found in the forms of the "Qualified Lead" Service that opens on the Site. The user can also find the dedicated consent button in the form of the "Qualified Lead" Service widget provided by Outgrow.

The user may revoke the consent given at any time by contacting Sipla at the contact details indicated in section 2 of this policy and, in particular, by writing to the e-mail address amministrazione@Sipla.it or by calling 059 5801438.

The provision of data for the purpose in question is optional: there is no legal or contractual obligation on the user to provide such data for this purpose and/or to give consent to the processing of his/her personal data for this purpose. Failure to provide data and/or consent for the purpose in question, however, will result in your inability to use the Qualified Lead Service. In order to be able to develop and improve the "Qualified Lead" Service, it is necessary, in fact, to analyze users' use of the forms. Thus, the use of the "Qualified Lead" Service involves the disclosure to OUTGROW of personal data provided through the forms, including the content of the conversations. In the event that the user does not wish his or her data to be disclosed to OUTGROW, the user, therefore, should refrain from using the "Qualified Lead" Service. In case the user has clicked on the widget of the Service, he/she may express his/her refusal to give consent to the disclosure of his/her data to OUTGROW by clicking on the "Refusal" button. The user may, however, request information or assistance by calling 059 5801438 or writing to the e-mail address amministrazione@Sipla.it, or ask to be contacted by filling out the contact form found on the Site and to which the user is redirected through the link in the Pop Up. Sipla thus offers two equivalent information and assistance services: one, the "Qualified Lead" Service, which requires the consent of the data subject, and another, the service provided as a result of requests received through the Contact Form or E-mail or by telephone, which does not require the consent of the data subject. Failure to provide consent to the communication of data to OUTGROW, therefore, has no impact on the data subject's ability to receive information and/or assistance from Sipla: in fact, a user who does not provide consent to such communication cannot request and/or obtain information and/or assistance through the "Qualified Lead" Service but can request and/or obtain information and/or assistance through the Contact Form and/or E-mail and/or telephone

For the purpose in question, Sipla will process the user's data for the time strictly necessary for communication to OUTGROW and, in any case, until consent is revoked.

More information

Users are advised of the following:

  • for the purpose of communication to OUTGROW, Sipla uses personal data initially collected for other purposes and, specifically, for the purpose of responding to requests from the data subject; such further processing is permitted, as it is based on the consent of the data subject;
  • for the purpose of communication to OUTGROW, Sipla uses personal data initially collected for other purposes and, specifically, for the purpose of responding to requests from the data subject; such further processing is permitted, as it is based on the consent of the data subject;
  • In case you withdraw your consent to the processing for the purpose of communication to OUTGROW: (i) your data will no longer be processed by Sipla for that purpose and will be retained by Sipla only in the event that another legal basis exists (such as, for example, the establishment, exercise or defense of a right in judicial or administrative proceedings or the purposes set forth in Sections 4 or, respectively, 6 above); (ii) Sipla will notify OUTGROW of the revocation of consent as well as of any exercise by the data subject of the other rights set forth in Articles 15 to 22 of the Regulations, if such exercise is made against Sipla as the source of the data;
  • data, once disclosed to OUTGROW, subject to the consent of the data subject, will be processed by OUTGROW as an autonomous data controller, based on OUTGROW's privacy policy.

10.5 TIKTOK FOR BUSINESS (LEAD GENERATION MODULES)

Sipla S.r.l. uses the "Lead Generation" service provided by TikTok Technology Limited based at 10 Earlsfort Terrace, Dublin, D02 T380, Ireland. For questions or complaints regarding the provision of the service or if you wish to get in touch with TikTok's Data Protection Officer, you can fill out the form at https://www.tiktok.com/legal/report/privacy.

The provision of this service is bound by the following privacy policy issued by TikTok: https://www.tiktok.com/legal/privacy-policy?lang=it-IT

The personal data collected through the electronic forms that TikTok makes available to Sipla S.r.l. by sharing them through the "Lead Generation" service are processed by the latter for marketing purposes and to follow up on requests from interested parties who have shown interest in Sipla S.r.l.'s advertising proposals.

  1. CATEGORIES OF PERSONS TO WHOM Sipla COMMUNICATES THE USER'S PERSONAL DATA (RECIPIENTS).

Personal data provided by the user may be disclosed by Sipla to the categories of recipients listed below, subject to the disclosure of data to:

- Zendesk Inc. subject to the consent of the data subject as outlined in section 10.1 of this policy

- Hello Umi S.L, subject to the consent of the data subject as stated in section 10.2 of this policy

- TAWK.TO, subject to the consent of the data subject as stated in section 10.3 of this policy.

- OUTGROW, subject to the consent of the data subject as stated in section 10.4 of this policy.

The persons to whom Sipla communicates data act as external data processors designated by Sipla by means of a special contract ("Data Processors") or as persons authorized to process personal data under the direct authority of Sipla ("Persons in Charge") or, in the case of third parties that the Data Processor uses, as "Sub-Processors", except in cases where the recipient acts as an autonomous data controller, as is the case, with reference to Zendesk Inc, Hello Umi S.L, TAWK.TO and OUTGROW in the case of the communication of data to them on the basis of the consent of the data subject, pursuant to the provisions of Sections 10.1, 10.2, 10.3 and 10.4 of this Policy.

More information

Users' personal data may be disclosed by Sipla to the following categories of recipients:

  1. To Remail Consultants;
  2. to companies, consultants or professionals that may be entrusted with the installation, maintenance, updating and, in general, the management of Sipla's hardware and software or that it uses for the provision of its services and, in particular to - AWS, as provider of the Cloud Computing Service and/or the third parties it uses; - Zendesk Inc, as provider of the Chat Service, and/or to third parties it uses; - Hello Umi S.L, as provider of the Chat Bot Service, and/or to third parties it uses; - TAWK.TO, as provider of the Chat Service, and/or to third parties it uses; - OUTGROW, as provider of the "Qualified Lead" Service, and/or to third parties it uses;
  3. to all those entities (including Public Authorities) that have access to personal data by virtue of regulatory or administrative measures;
  4. to all those public or private entities, individuals and/or legal entities (legal, administrative and tax consulting firms; judicial offices, etc.), if the communication is necessary or functional for the proper fulfillment of the obligations undertaken and/or obligations arising from the law.

The updated list of data processors and processors can be found at Sipla's headquarters

Personal data covered by this notice will not be disseminated.

For purposes of clarity, with reference to Zendesk Inc, provider of the Chat Service, acts: (i) as an autonomous data controller within the scope of the purposes set forth in section 10.1 of this policy, in the event that, with the consent of the data subject, Sipla communicates to it the personal data of the users who use the Chat, including the content of the conversations; (ii) as a Data Processor, appointed by Sipla, within the scope of the purposes set forth in sections 4 and 6 of this policy and with reference only to the data of the users who use the Chat.

For the sake of clarity, with reference to Hello Umi S.L, it should be noted that Hello Umi S.L, provider of the Chat Bot Service, acts: (i) as an autonomous owner within the scope of the purposes set forth in section 10.2 of this policy, in the event that, subject to the consent of the data subject, Sipla communicates to it the personal data of the users who use the Chat Bot, including the content of the conversations; (ii) as a Data Processor, appointed by Sipla, within the scope of the purposes set forth in Sections 4 and 6 of this policy and with reference only to the data of the users who use the Chat Bot.

For the sake of clarity, with reference to TAWK.TO, it should be noted that TAWK.TO, provider of the Chat Service, acts: (i) as an autonomous data controller within the scope of the purposes set forth in Section 10.3 of this policy, in the event that, subject to the consent of the data subject, Sipla communicates to it the personal data of the users who use the Chat, including the content of the conversations; (ii) as a Data Processor, appointed by Sipla, within the scope of the purposes set forth in Sections 4 and 6 of this policy and with reference only to the data of the users who use the Chat.

For the sake of clarity, with reference to OUTGROW, it should be noted that OUTGROW, provider of the "Qualified Lead" Service, acts: (i) as an autonomous data controller within the scope of the purposes set forth in Section 10.4 of this policy, in the event that, subject to the consent of the data subject, Sipla communicates to it the personal data of the users who use the forms of the "Qualified Lead" Service, including the content of the conversations; (ii) as a Data Processor, appointed by Sipla, within the scope of the purposes set forth in Sections 4 and 6 of this policy and with reference only to the data of the users who use the forms of the "Qualified Lead" Service.

  1. TRANSFER TO THIRD COUNTRIES

Users' personal data are transferred by Sipla to the following third countries: U.S.A.

The transfer is made on the basis of the European Commission's adequacy decisions and the subsequent authorization orders of the Data Protection Supervisor and on the basis of the standard contractual clauses between data controller and data processor.

More information

In particular, the following should be noted:

  • personal data covered by this policy are stored in the cloud on servers of Amazon Web Service Inc. a U.S. corporation headquartered at 410 Terry Ave North Seattle, WA 98109-5210, US ("AWS"); they are stored on AWS servers located in Frankfurt, Germany, or Dublin, Ireland;
  • the Chat Service is provided by Zendesk Inc. a company incorporated under U.S. law with its registered office at 1019 Market Street, 6th Floor, San Francisco, California, 94103 (USA) resulting in the transfer to the U.S. of the data of users using the Chat and possible further transfer of such data outside the territory of the USA as well;
  • The Chat Service is provided by TAWK.TO Inc, headquartered at 187 East Warm Springs Rd, SB298, Las Vegas, Nevada, 89119 (USA) and its affiliate TAWK.TO Ltd headquartered in the United Kingdom (UK) 71-75 Shelton Street, London, Greater London, WC2H 9JQ (dedicated location for processing personal data of EU data subjects) resulting in possible transfer to the USA of data of users using the Chat and possible further transfer of such data outside the territory of the USA as well;
  • The "Qualified Lead" Service is provided by OUTGROW, headquartered at 401 Park Ave, 10th Floor, New York 10016 with possible consequent transfer to the U.S. of data of users using the "Qualified Lead" Service forms and possible further transfer of such data outside the territory of the U.S. as well;

The transfer of data to the U.S.A. (and any transfer of data outside the U.S.) takes place on the basis of "Commission Implementing Decision (EU) 2016/2295 of July 12, 2016 (pursuant to Directive 95/46/EC of the European Parliament and of the Council, on the adequacy of the protection offered by the EU-U.S. Privacy-Shield regime" [notified under C(2016)4176] and the resulting "Authorization for the transfer of data abroad through the agreement called "E.U. - U.S. Privacy-Shield" issued by the Data Protection Authority on 27.10.2016, being both AWS, Zendesk Inc, TAWK.TO and OUTGROW enrolled in the Privacy Shield; in addition, in the contracts of AWS, Zendesk Inc, TAWK.TO and OUTGROW are also included the standard contractual clauses set forth in the "Commission Decision of February 5, 2010 on standard contractual clauses for the transfer of personal data to controllers established in third countries pursuant to Directive 95/46/EC of the European Parliament and of the Council" [notified under C(2010)/87/EU] and then on the basis of the ensuing "Authorization of transfers to third countries by means of the standard contractual clauses referred to in Commission Decision 2010/87/EU in the case of an importer established in a third country" issued by the Data Protection Supervisor in orders dated May 27, 2010 and November 15, 2012.

  1. RIGHT OF OBJECTION

The data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her carried out for the purposes referred to in Sections 6 and 8 of this policy and having as a legal basis the legitimate interest of the data controller.

In the event that the data are processed for direct marketing purposes (and thus in the case of processing for the purpose referred to in Section 5 of this policy), the data subject also has the right to object at any time to the processing of personal data concerning him or her carried out for such purposes.

The data subject may exercise the right to object by contacting Sipla at the contact details indicated in section 2 of this policy and, in particular, by writing to the e-mail address amministrazione@Sipla.it or by calling 059 5801438.

More information

If the right to object is exercised, the data controller shall refrain from further processing personal data, unless the data controller demonstrates the existence of compelling legitimate grounds for processing that override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of a legal claim.

If the data subject objects to processing for direct marketing purposes, the personal data are no longer processed for that purpose.

  1. RIGHT OF ACCESS

The data subject has the right to obtain from the data controller (and, therefore, from Sipla confirmation as to whether or not personal data concerning him or her are being processed and, if so, to obtain access to the personal data and information specified below.

The interested party may exercise the right of access by contacting Sipla at the contact details indicated in section 2 of this policy and, in particular, by writing to the e-mail address amministrazione@Sipla.it or by calling 059 5801438.

More information

In the case of exercising the right of access, the user may obtain access to personal data and the following information:

  1. the purposes of processing;
  2. the categories of personal data in question;
  3. 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;
  4. when possible, the intended retention period of personal data or, if not possible, the criteria used to determine this period;
  5. 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 the processing of personal data concerning him or her or to object to their processing;
  6. The right to file a complaint with a supervisory authority;
  7. where the data are not collected from the data subject, all available information about their origin;
  8. the existence of any automated decision-making process, including profiling, which produces legal effects concerning the data subject or significantly affects the data subject in a similar way, and at least in such cases, meaningful information about the logic used, as well as the importance and expected consequences of such processing for the data subject;

Where personal data are transferred to a third country or to an international organization, the data subject has the right to be informed of the existence of adequate safeguards relating to the transfer, pursuant to Article 46 of the Regulation.

The data controller shall provide a copy of the personal data being processed. If additional copies are requested by the data subject, the data controller may charge a reasonable fee based on administrative costs. If the data subject makes the request by electronic means, and unless otherwise specified by the data subject, the information shall be provided in a commonly used electronic format.

  1. RIGHT OF RECTIFICATION

The data subject has the right to obtain from the data controller (and thus from Sipla) the rectification of personal data concerning him/her without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, including by providing a supplementary declaration.

The interested party may exercise the right of rectification by contacting Sipla at the contact details indicated in Section 2 of this policy and, in particular, by writing to the e-mail address amministrazione@Sipla.it or by calling 059 5801438.

  1. RIGHT OF CANCELLATION

The data subject has the right to obtain from the data controller (and thus from Sipla) the erasure of personal data concerning him or her without undue delay, and the data controller has the obligation to erase the personal data without undue delay, if one of the following reasons exists:

  1. personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. the data subject withdraws the consent on which the processing is based (and, therefore, in cases of withdrawal of consent to processing for the purposes set out in Section 5 of this policy), if there is no other legal basis for the processing;
  3. the data subject objects to processing based on the legitimate interest of the data controller for reasons related to his or her particular situation (and, therefore, in the cases of objecting to processing for the purposes set out in Sections 6 and 8 of this policy) and there is no overriding legitimate reason or objects to the processing of his or her personal data for direct marketing purposes including profiling insofar as it is related to such direct marketing (please note that the data referred to in this policy are not processed for profiling purposes for marketing purposes, but only for generic marketing purposes, as stated in Section 5 of this policy);
  4. Personal data are processed unlawfully;
  5. personal data must be deleted in order to comply with a legal obligation under Union or Member State law to which the data controller is subject.

The data subject may exercise the right of cancellation by contacting Sipla at the contact details indicated in Section 2 of this policy and, in particular, by writing to the e-mail address amministrazione@Sipla.it or by calling 059 5801438.

More information

Where a data controller has made personal data public and is obliged to erase it, taking into account available technology and implementation costs, it shall take reasonable measures, including technical measures, to inform data controllers who are processing personal data of the data subject's request to erase any link, copy or reproduction of his or her personal data.

The right to erasure does not apply to the extent that the processing is necessary:

  1. for the exercise of the right to freedom of expression and information;
  2. for the performance of a legal obligation under the law of the Union or the Member State to which the holder is subject or for the performance of a task carried out in the public interest or in the exercise of public authority;
  3. For reasons of public interest in the public health sector;
  4. for the purposes of archiving in the public interest, scientific or historical research, or statistical purposes, insofar as the right of erasure is likely to render impossible or seriously prejudice the achievement of the objectives of such processing;
  5. for the establishment, exercise or defense of a right in court.
  1. RIGHT TO LIMITATION OF PROCESSING

The data subject has the right to obtain from the data controller (and thus from Sipla) the restriction of processing when one of the following cases occurs:

  1. the data subject disputes the accuracy of personal data for the period of time necessary for the data controller to verify the accuracy of such personal data;
  2. processing is unlawful and the data subject objects to the deletion of personal data and instead requests that their use be restricted;
  3. although the data controller no longer needs it for the purposes of processing, the personal data is necessary for the data subject to establish, exercise or defend a right in court;
  4. the data subject has objected to the processing in cases where the processing is based on the legitimate interest of the data controller, for reasons related to his or her particular situation (and, therefore, in the case of an objection to the processing of data for the purposes referred to in Sections 6 and 8 of this policy), pending verification as to whether the data controller's legitimate reasons prevail over those of the data subject.

The data subject may exercise the right to limitation by contacting Sipla at the contact details indicated in Section 2 of this policy and, in particular, by writing to the e-mail address amministrazione@Sipla.it or by calling 059 5801438.

More information

If the processing is restricted, the personal data subject to the restriction shall be processed, except for storage, only with the consent of the data subject or for the establishment, exercise or defense of a legal claim or to protect the rights of another natural or legal person or for reasons of substantial public interest of the Union or a member state.

A data subject who has obtained the restriction of processing shall be informed by the data controller before the restriction is lifted.

  1. TIME AND MANNER OF RESPONSE IN CASE OF EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY

The data controller shall provide the data subject with information about the actions taken in relation to a request to exercise the rights recognized by Articles 15 to 22 of the Regulation (i.e., right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability, right to object) and referred to in Sections 13, 14, 15, 16, and 17 of this notice ("Rights of the Data Subject"), without undue delay and, in any case, within one month of receipt of the request. This deadline may be extended by two months, if necessary, taking into account the complexity and number of requests. The data controller shall inform the data subject of such extension, and of the reasons for the delay, within one month of receipt of the request. If the data subject makes the request by electronic means, the information shall be provided, where possible, by electronic means, unless otherwise specified by the data subject.

More information

If the data controller fails to comply with the data subject's request, the data controller shall inform the data subject without delay, and at the latest, within one month of receipt of the request, of the reasons for non-compliance and of the possibility of lodging a complaint with a supervisory authority and seeking judicial remedy.

Communications in response to the exercise of the Data Subject's Rights and actions taken are free of charge. If the data subject's requests are manifestly unfounded or excessive, particularly because of their repetitive nature, the data controller may:

  1. Charge a reasonable fee, taking into account the administrative costs incurred in providing the communications or taking the requested action;
  2. Refuse to comply with the request.

When the data controller has reasonable doubt about the identity of the natural person making the request regarding the Data Subject's Rights, it may request additional information necessary to confirm the identity of the data subject.

  1. RIGHT TO FILE A COMPLAINT WITH A SUPERVISORY AUTHORITY

Without prejudice to any other administrative or judicial remedy, a data subject who considers that processing concerning him or her is in violation of the Regulation has the right to lodge a complaint with a supervisory authority, namely in the Member State where he or she normally resides, works, or of the place where the alleged violation occurred. The supervisory authority to which the complaint is made shall inform the complainant of the status or outcome of the complaint, including the possibility of a judicial remedy.