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Privacy Policy

 

This privacy policy describes the processing of personal data concerning users, visitors and interacting subjects (collectively, the “Users”) with Habacus s.r.l.’s website (https://www.habacus.com: the “Website”) and/or further web and social network pages (such as Instagram® and Facebook®). Habacus s.r.l. may modify this privacy statement in accordance with future improvements or modifications of the Website or the provided services. In case of substantial changes, Habacus s.r.l. will publish a notice on the Website to draw the Users’ attention to the changes and collect, if necessary, any request to exercise the rights recognized by the applicable laws on the protection of personal data.

1. DATA CONTROLLER The data controller is Habacus s.r.l., with registered seat in Milan, Via Filippo Sassetti, 32, Copernico Isola Fintech, 20124, tax code and VAT code no. 04906910262 (“HABACUS” or “Data Controller”).

2. COLLECTED DATA 2.1 Personal data provided by Users Personal data collected through the Website are provided by the Users by filling-in the form made available on the Website, in particular: Section “Contact Us Now”. In the section “Contact us now” or by sending HABACUS a request to the addressed indicated on the Website, and within the context of lead generation activities realized by HABACUS on social networks and/or other media, the User will provide his personal identification and contact data (e.g. name and surname, e-mail address), data included in the communications and requests sent to HABACUS, as well as all further data necessary to reply and follow up on Users’ requests.Account registration form By submitting your account registration request to the Website and filling in the data collection form in the “Registration” section, you will provide your personal, identification and contact data, such as your name and surname, e-mail address and, if required, the name of your organisation and your role.Users are invited to provide HABACUS with up to date and relevant data, limited to what is necessary in relation to the purposes for which they are processed. Any unnecessary data will be immediately deleted or anonymized. 2.2 Web browsing information data Each time the Users access the Website, the systems automatically register and analyze the access data (like the provider’s IP address, information on the used browser, pages visited, date, time and duration of each visit). The information is automatically collected by the Website and does not require any action by Users.The Website collects only anonymous and aggregated data, which cannot lead to the identification of Users. The information collected merely allows to detect and resolve any technical problems.

3. PURPOSE OF THE PROCESSING Users’ personal data (the “Data”) shall be processed for the following purposes. 3.1 Follow up Users’ requests The Data shall be processed:- To respond and follow up on the requests that Users may send to HABACUS through the form in the “Contact Us Now” section of the Website or to the contact details available on the Website;- To allow the registration of the User’s account to the Website and to verify, through a validation flow, the validity of the registered e-mails.The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract.§The provision of Data for the above-mentioned purposes is necessary for the correct management and execution of the User’s requests. Any partial or total refusal to provide Data for such purposes will make it impossible for the Data Controller to fulfil such requests. 3.2 Sending commercial, informative and survey material The Data will be processed in order to keep Users constantly updated on the activities, services, products and promotions of HABACUS by sending communications and information materials, as well as to obtain feedback and opinions by Users on it’s activities, services, products and promotions by sending questionnaires and surveys.The sending of communications, information material and questionnaires and surveys will be carried out through automatic messages, e-mail and/or telephone, depending on the contact data provided by the Users from time to time. The legal basis for the processing is the legitimate interest of HABACUS: (i) to provide information to the Users interested in the activity carried out by the Data Controller, which have provided – in accordance with the collection methods adopted from time to time by HABACUS (lead campaigns, forms, etc.) – their Data in order to receive updates; and (ii) to improve HABACUS’ offer to the Users, through the analysis of the “customer satisfaction” that emerges from the interactions of the Users.Such legitimate interest, in light of the spontaneous release of the Data by the User in the context of the collection activities organized by HABACUS and aimed at promoting the activities of the latter, does not prejudice the rights and freedoms of the Users.

4. MODALITIES OF PROCESSING AND RECIPIENTS OF DATA The Data shall be processed by means of manual and digital tools by HABACUS’ employees and collaborators and/or by companies specifically appointed as data processors, to which HABACUS has given detailed instructions, with specific regard to the implementation of appropriate technical and organizational security measures.The complete list of the recipients of Data is stored at the data controller’s office and is available upon request, to be sent to the addresses set out in following point 6.

5. PERIOD OF STORAGE The Data collected and processed by HABACUS, for the purpose set out in point 3.1 above, may be stored and processed in a form that allows the identification of the User for the period necessary to achieve the purposes of processing and, in particular:- in the case of filling in the “Contact Us Now” form for a period of 12 (twelve) months from the last contact made- in the case of filling in the ” Registration ” form until the User deletes his/her personal account from the Website and, in any case, for the entire duration of the contractual relationship with the Data Controller, as well as for the time necessary to (i) fulfil statutory and/or legal obligations and (ii) ensure the judicial protection of the Data Controller’s rights, in accordance with the relevant limitation periods.The Data collected and processed by HABACUS, for the purpose set out in point 3.2 above, may be stored and processed in a form that allows the identification of the User for the period necessary to achieve the purposes of processing and, in particular, up to 18 months from the collection, after which HABACUS will ascertain the continued interest of the User in receiving the above mentioned communications referred to in the point 3.2.

6. USER’S RIGHTS AND CONTACT DETAILS At any time and to the extent applicable the User can: (I) obtain access to his / her personal data; (II) obtain the rectification or cancellation or, where applicable, the limitation on their processing; (III) lodge a complaint with a supervisory authority or with the relevant judicial authority. The requests concerning the exercise of the above rights shall be sent to the following addresses:– by e-mail, to: info@habacus.com;– by registered letter, to: Habacus s.r.l., Via Filippo Sassetti, 32, Copernico Isola Fintech, 20124, Milan.or to the Data Protection Officer’s contact details, set out in point 8 below.To the same addresses above, the Users shall send also the requests concerning the recipients of Data, as well as the clarifications’ requests regarding this privacy statement.

7. LINKS TO OTHER WEBSITES This privacy statement is provided exclusively in relation to the Data collected through the Website and with reference to the purposes identified in point 3., and not for any other websites accessed and / or accessible through links and / or widgets (e.g. social networks): these other websites will process the Data as independent data controllers and in accordance with their respective privacy statements. The Users are recommended to read them.

8. DATA PROTECTION OFFICER The Data Protection Officer (DPO) appointed by HABACUS is LCA SERVIZI S.R.L., which can be reached at the following address: via della Moscova, 18, 20121, Milan; email: dpo@lcalex.it; certified mail: lcaservizi@pec.lcaservizi.it.