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Privacy Policy

This Privacy Policy is intended to describe the purposes and methods through which SPS srl, as Data Controller, collects and processes personal data relating to the user who interacts with the website and with the different services offered by the same.

The information contained in this Privacy Policy is provided pursuant to art. 13 of the EU Regulation of 27 April 2016 n. 679, as well as the Provisions issued by the Guarantor Authority for the protection of personal data and Guidelines of the European authorities.

Information about data processing is provided only for the Site and for the processing carried out by the Company and does not extend to processing carried out by third parties through other sites that may be consulted by the User via links. With respect to said further treatments, the Company assumes no responsibility, the User having to refer to the individual Privacy Policies of third-party sites.


1) Holder and place of treatment


The Data Controller is the company SPS srl, with headquarters in Via Antonio Zanolini 36 A/B, Bologna, Italy.

The data are mainly processed at the headquarters of the Data Controller, by the technical personnel of the Company appointed in charge of processing, within the territory of the European Union and, in relation to the services entrusted or offered by third parties, also outside the State Italian and/or outside the European Union. In the event of transfer of data to countries that do not have standards of protection equal to the Italian one, the Company undertakes to adopt  the necessary measures for this transfer.

2) Methods of data processing

The Company processes the User's data by adopting all the appropriate security measures aimed at preventing unauthorized access, as well as the disclosure, modification or destruction of unauthorized data. The treatment is carried out with both manual and IT and/or telematic tools, with organizational methods and with logics strictly correlated and limited to the purposes indicated.


3) Purpose of the data processing and legal basis of the processing


The Company, through the Website, may process the User's data for the following purposes:


Registration on the Site. The Company allows its Users to register on the Site by entering a username and email address to receive newsletters on the Company's products and services and to access restricted areas of the site. The legal basis of the processing is represented by the execution of a request from the User himself, and any refusal to provide personal data will make it impossible for the Company to manage and execute the User's requests.

Purpose of collecting "Work with us" applications. The Company offers the User the opportunity to send their application to work in the Company via email through the "Work with us" section of the Website. To this end, the Company will acquire and use the information provided by the User through the spontaneous submission of the CV for the exclusive purposes of selection and management of applications. In any case, the User is invited not to include data of a sensitive nature in his CV (e.g. relating to the state of health, political opinions, sex life, etc.), except those strictly necessary pursuant to the law for the purposes CV selection and evaluation (e.g. belonging to protected categories). The legal basis of the processing is represented by the execution of a request by the User to evaluate his professional profile with respect to job positions at the Company, and any refusal to provide personal data will make it impossible for the Company to manage and execute User requests

Contact the Company.The Company offers the User the possibility to  send communications to the Company via email, requests, questions and information on its activities, initiatives and services. In this regard, the personal data provided by the User (e.g. email address, any telephone number and/or other information spontaneously provided to the User) will be processed by the Company to take charge, correctly manage and respond to the User's communication . The legal basis of the processing is represented by the execution of the service expressly requested by the User, and any refusal to provide personal data will make it impossible for the Company to manage and respond to the communication or request for information.

Marketing activities.The User's data may be used for the Company's marketing activities relating to the products and/or services offered, such as the sending via e-mail messages of informative material and communications of a commercial nature on services, initiatives and/or offers of SPS srl. The legal basis of the processing is represented by the consent given by the User.

Pursuit of the legitimate interests of the Company.The User's data may also be used for the exercise of the Company's rights and legitimate interests, for example the right of defense in court, the management of complaints and disputes, any credit recovery, fraud prevention and/or illegal activities. In these cases, even if the provision of the User's personal data is not mandatory, it is still necessary as such data are closely connected and instrumental to the pursuit of such legitimate interests, which do not prevail over the User's fundamental rights and freedoms, and any refusal to provide them could make it impossible to provide the requested services (e.g. request information from the Company).

Fulfill legal obligations and/or applicable obligations.The Company may also use the personal data provided by the User or otherwise acquired during the User's interaction with the Site for purposes related to the execution of legal obligations, regulations, national and community regulations as well as deriving from provisions issued by authorities legitimized by the law, which represent the legal basis of the processing, without the need to obtain the prior consent of the User.

4) Categories of data being processed


The Company receives and collects, through the Site, information relating to the User who visits the pages of the Site and who uses the web services available on the same. In particular, the Company acquires and processes the following information.


4.1 Data collected through navigation and through cookies


When the User visits the Site, the latter collects some data such as the pages viewed, the links or buttons clicked by the User, the date and time of access, the User's IP address, the navigation browser and the operating system used (so-called "browsing data"). Navigation data could, by their very nature, allow the User to be identified also through processing and association with data held by third parties. However, the Company uses this data for the sole purpose of obtaining statistical and anonymous information on the use of the Site for purposes strictly related to its functioning. The navigation data could also be used to ascertain responsibility in the event of any computer crimes against the Site.

Secondly, in relation to the collection of User data through cookies and similar technologies, please visit theCookie Policy.


4.2 Data provided voluntarily by the User


The Company limits the collection of information voluntarily provided by the User to that necessary for the pursuit of the purposes described in paragraph 3 above and for the services expressly requested. Furthermore, the Company may collect and process further personal data, where they are provided voluntarily by the User as part of the services offered by the Site, for example in the event that the User contacts the Company to report disservices or malfunctions, exercise own rights on the processing of personal data, etc. These data will be processed by the Company solely for the purposes strictly related to the User's request. Failure to provide data may make it impossible to obtain the requested service.


5) Communication of data to third parties


The data provided by the User as well as those collected by the Site as part of the related services (e.g. IP address) will not be disclosed and may be communicated, for the purposes and methods illustrated in this Privacy Policy, to the categories of subjects indicated below:

  • companies, collaborators, consultants or freelancers that the Company uses to carry out tasks of a technical or organizational nature (such as, for example, IT service providers), or with which the Company collaborates, for the purpose of providing and functioning services, or for any communication activities;

  • persons, companies or professional firms that provide assistance and consultancy to the Company, with particular but not exclusive reference to accounting, administrative, legal, tax and financial matters;

  • subjects whose right to access the data is recognized by provisions of the law or by orders of the authorities.


The subjects belonging to the categories indicated above will use the data as independent data controllers in accordance with the law or as data processors duly appointed by the Company.


6) Data retention


The data are processed for the time necessary to carry out the activities indicated in paragraph 3 above, and are canceled when the purposes for which they were collected and processed cease to exist.

In particular, the Company will eliminate the personal data of the User who has requested information or sent communications by contacting the Company via the Site after 1 year from the provision of the same. Secondly, the Company will proceed to eliminate the personal data of the User who has sent his/her application for Company job positions after 1 year from the provision of the same, in the event that the candidate does not establish an employment/collaboration relationship with the society

Finally, in relation to the processing of data for marketing purposes, the data will be kept until the User expresses his opposition to the processing


7) User rights and contacts


The User can exercise, in the cases expressly provided for by law and where applicable, the rights provided for by the Regulation. In particular, the User has the right to:

  • obtain confirmation that your personal data is being processed and, in this case, to ask the data controller for access to information relating to the processing itself (e.g. purposes, categories of data processed, recipients or categories of recipients of the data , the retention period, etc.);

  • request the rectification of inaccurate or incomplete data;

  • ask the data controller to delete the data (personal data are no longer necessary with respect to the purposes for which they were collected, in the event of revocation of the consent on which the treatment is based, etc.);

  • request the limitation of the treatment (e.g. in the event of a dispute by the User on the accuracy of the data; if the treatment is unlawful and the same opposes the cancellation of personal data; if the data are necessary for the exercise or legal defense of a User's right, even if the owner no longer needs it; in the event of exercising the right to object, for the time necessary to verify the existence of legitimate reasons);

  • Receive personal data concerning him in a commonly used and readable format from an automatic device (e.g. pdf) and transmit them to another holder, or obtain direct transmission from one holder to another, if technically feasible (so-called data portability data).


The User also has the right to object in whole or in part, for legitimate reasons, to the processing of personal data concerning him.


These rights can be exercised directly by sending a communication to the following email

The exercise of the aforementioned rights can take place by sending a request to the e-mail

Finally, if the Customer believes that the processing of the data provided violates the legislation on the protection of personal data, he has the right to lodge a complaint with the Guarantor Authority for the protection of personal data (

8) Data Protection Officer (“DPO”)

The Company has identified and appointed a Data Protection Officer, the so-called "DPO", who can be reached by


9) Changes to the Privacy and Cookie Policy


The Company reserves the right to make changes to this Privacy Policy at any time, giving notice by publication on the Site. We invite the User to check these updates on the Site.

If the changes are particularly significant and/or have a significant impact on the User's rights, the Company may also communicate them to the User through a different method (for example by sending an email).


Privacy and Cookie Policy updated on 05/25/2018

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