Information Concerning Personal Data Processing

Slamp S.p.A. (legal offices located on No. 12/14 Via Vaccareccia, Pomezia, Rome, 00071), herein referred to as Slamp S.p.A., is constantly working to conform to the GDPR 2016/679 regarding their users personal data. This document will help you familiarize yourself with their personal data protection policies and how your personal information is managed while you are using our services. It also permits you to express informed consent when providing your personal information in parts of the website that require it, as well as how that information is treated. slamp.com, herein referred to as the site, has areas requesting personal data that are published in accordance with art. 13 of EU Regulation 2016/679, that must be visualized before providing the data. Your information and data, provided or collected during the registration of Slamp’s varying services, will be treated according to the Regulation and privacy obligations undertaken by Slamp S.p.A.
According to the Regulation, Slamp S.p.A.’s treatment of data will be marked by lawfulness, correctness, transparency, limitation and retention of purpose, data minimization, accuracy, integrity and confidentiality.

1- Processing Purposes

Our intended treatments, with explicit consent where necessary, meet the following purposes:

1. provide requested services and the subsequent operational, technical and administrative management of that service and established relationship as well as communications relating to said relationship’s progress;
2. consent to navigate and consult Slamp S.p.A.’s websites;
3. respond to requests for information or assistance received via email, telephone, or form;
4. fulfill legal, financial and/or tax obligations;
5. send direct sales offers for previously, explicitly authorized services via email;
6. f. conduct studies, research and gather market statistics; send advertisements, information, sales information, and surveys to better services (Customer Satisfaction) via email or text message, and/or telephone operator, and/or using the Site’s official pages and social media channels, all with previous explicit consent;
7. g. make personalized sales offers based on previous purchases or previous navigation of the Site; if you previously searched for certain products on the Site, you will receive offers concerning those products. This type of analysis typically uses purchase data relating to both individuals and legal entities and correlating decisions are not only based on automatic treatment.

2- The Legal Basis and Mandatory or Optional Nature of Processing

The legal base of Personal Data processing, as referred to in the GDPR’s section 1 (a)(b)(c) and art. 6.1.b, is necessary for contracted services. Processing consent for these purposes is optional, but may inhibit the activation or requested services.
Section 1(d) represents the legitimate processing of Personal Data pursuant to art. 6.1.c of the Regulation. Once personal data has been provided, processing may be necessary to comply with the legal obligations Slamp S.p.A. is subject to.
Sections 1 (e)(f) represents processing for Marketing purposes pursuant to art. 6.1.c of the Regulation. Providing personal data for these purposes is fully optional and will not inhibit the use of any services.
Section 1(g) represents email marketing based on previously purchased products or services, and has legal basis pursuant to 6.1.f of the Regulation. With Slamp’s legitimate interest in promoting its products and services, the user can expect reasonable processing, to which he can oppose at any time. You can oppose the processing of your personal data for marketing purposes, as stated by Sections 3(e)(f)(g), by using the mechanism in the sales email’s footer, or by writing directly to privacy@slamp.it

3- Data Controller and Data Protection Officer (DPO)

Slamp’s data controller is defined above.
The Controller possesses the specific knowledge and skills required by the GDPR’s art. 37, par. 5; Forensic analyst Andrea Russo, herein referred to as the DPO, has been designated this role for Slamp S.p.A. The DPO is available to provide any information concerning Slamp S.p.A.’s personal data processing, including a list of those who process the data. To contact the DPO, write and email to: dpo@andrea-russo.eu

4- Types of Personal Data processed

Personal data processing signifies any operation or set of operations performed with or without the use of automated processes, including the collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of sharing, comparison or interconnection, limitation, cancellation or destruction, to personal data or sets of personal data.
We would like to inform you that personal data -also based on your decisions on how you use our services- is defined by an identifier such as name, email address, an identification number, location data, an online identifier, purchases made, and other suitable identifiable data, depending on the type of service requested ( hereinafter only “Personal Data”). The Site processes the following data in particular:

1. Navigational Data

   During normal function, the computer system and software used to operate the Site acquire Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not intended to identify interested parties, but by nature through the elaboration and association of third parties, could identify users. IP addresses, domain names of computers connecting to the Site, URI (Uniform Resource Identifier) addresses of requested resources, time of request, method used to submitting request to the server, size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters related to the operating system and the user’s computer environment. This data is used for the sole purpose of obtaining anonymous statistical information on Site use and customers’ sites, to check function, to identify anomalies and / or abuse; it is deleted immediately after processing.

2. Data voluntarily provided by the user

   When using certain services, like registering for a newsletter, data processing may be carried out by a third party when you provide personal information to the service provider. In respect to this, you become the independent data controller, assuming all the legal obligations and responsibilities.
   In this sense, you forgo any dispute, claim, request for damage compensation, etc. should your Personal Data be violated by third parties processing it while using Slamp’s services. In every case, when you provide or process data through third parties while using services, assuming all related liability, this hypothetical treatment is based on a suitable legal basis (for example, the consent of the interested party) pursuant to art. 6 of the Regulation, legitimizing the processing of the information in question.

5- Cookies

Please refer to our Cookie Policy for further information.

6- Recipients of Personal Data

Your personal data may be, for the purposes outlined in section 1 above, shared with:

1. a. subjects typically serving as data controllers, that is:
   1. professionals or companies that provide assistance and advice to Slamp S.p.A.’s accounting, administrative, legal, tax, financial and debt collection departments regarding Services;
   2. subjects who perform technical maintenance (including network equipment and electronic communications network maintenance);
2. b. professionals, groups and authorities who must communicate their personal data in accordance with legal or authoritative orders (for example, criminal investigations, or if Slamp S.p.A. is required by law to provide telephone logs);
3. c. subjects delegated by Slamp S.p.A. to perform activities tightly connected to Services, committed to confidentiality or with the appropriate legal obligation of confidentiality, such as Slamp S.p.A.’s employees and collaborators;

The complete list of data handlers can be obtained by request by writing privacy@slamp.it.

7- Transfer of Personal Data

Slamp S.p.A. does not share any personal data with recipients outside the European Economic Area.

8- Retention Period

Obligatory contractual and financial data is kept until the conclusion of the financial sales interaction. In any case, Slamp S.p.A. will process Personal Data up to the time allowed by Italian law to protect its interests when providing services.
For the purposes named in sections 3 (e)(f)(g), your Personal Data will be retained until you expressly revoke your consent. Slamp S.p.A. will retain your Personal Data up to the time allowed by Italian law to protect its interests (Art. 2947(1)(3) c.c.). For further information concerning data retainment periods and the criterium used to determine these time periods, please contact the DPO.

9- User Rights

Pursuant to European Regulation 679/2016 (GDPR) and national legislation, the interested party may, in accordance with the procedures and within the limits established by current legislation, exercise the following rights:

• request confirmation that their personal data has been registered;
• understand the origins of registration;
• receive information concerning the logic, use and purpose of the proc;
• request an update, rectification, integration, cancellation, transformation into anonymous user, block data processed in violation of the law, including that no longer in use for original purposes;
• in cases of consent-based processing, receive the data they provided in a structured and readable form by a data processor and in a format commonly used by an electronic device;
• in cases of consent-based processing, receive the data they provided in a structured and readable form by a data processor and in a format commonly used by an electronic device;
• the right to file a complaint with the Supervisory Authority.

To assert your rights, please write to privacy@slamp.it

10- Modifications

This Privacy Policy is valid as of May 25, 2018. Slamp S.p.A. reserves the right to modify or simply update its content, partially or completely, also based upon variations of the applied regulation. The moment that these modifications are substantial and could have a relevant effect on users, Slamp S.p.A. will be sure to update them.