Privacy policy
Pursuant to a policy of transparency and fairness, in compliance with current regulations and with particular reference to EU Regulation 2016/679 (hereinafter the “Privacy Regulation“) and, where applicable, Legislative Decree 30 June 2003 no. 196 (hereinafter the “Privacy Code“), the company Habacus S.r.l. (hereinafter the “Company“), as the independent data controller, provides you with information regarding the processing of personal data you provide when using the services available on the website www.habacus.com (hereinafter the “Website”).
This privacy policy governs the processing of personal data you have provided and/or will provide for the provision of the services you have requested. Therefore, any third-party website or application to which you may be redirected is excluded.
- DATA CONTROLLER AND DATA PROTECTION OFFICER
The data controller is Habacus S.r.l., Via Cappuccio 14, 20123, Milan (MI), tax code and VAT number 04906910262 (“HABACUS”).
The Data Protection Officer (DPO) appointed by HABACUS is LCA SERVIZI S.R.L., who can be reached at the following address: Via della Moscova 18, 20121, Milan, email: dpo@lcalex.it, or at the certified email address: lcaservizi@pec.lcaservizi.it. - PERSONAL DATA
“Personal Data” means any information capable of identifying, directly or indirectly, a natural person, in this case, you who are using the service (the “Data”). Your Data that will be collected and processed by Habacus are specified in the table in paragraph 3 below. - PURPOSE OF THE PROCESSING AND LEGAL BASIS
Your Data referred to in the points may be processed by HABACUS solely for the following purposes:
| Purpose | Data | Legal basis |
|---|---|---|
| (a) Use of the student loan comparison service | Identification data; Contact data; Data relating to your academic background and career | The data will be collected by Habacus on the basis of the execution of pre-contractual and contractual measures, to provide services primarily related to the presentation and comparison of student loans and the forwarding, to the lending institutions with which HABACUS has entered into commercial agreements, of the expressions of interest expressed by users of the Site for such products. In particular, the data will be processed: To provide the credit brokerage services offered by HABACUS to users of the Site, including assistance to users who have sent a request to collaborate with credit institutions (with which HABACUS has entered into commercial agreements) and to connect users with such credit institutions. To provide credit institutions (with which HABACUS has entered into commercial agreements) with the information necessary to provide the services you have requested. For free, no-obligation telephone and/or instant messaging assistance from an operator, to provide useful information to identify one or more financing products that may be of interest to the user; To provide assistance, by telephone and/or instant messaging, to users regarding requests for connection with lending institutions. |
| (b) Third-party marketing For marketing purposes, commercial information, direct offers, market research, or customer satisfaction surveys relating to products and services offered by companies and promoting entities with which HABACUS collaborates, and to whom the Data will be transferred for the achievement of this purpose. | Identification data; Contact data; Data relating to your academic background and career | Processing will be carried out exclusively on the basis of the specific consent expressly provided by the interested party for this purpose by checking the appropriate box at the bottom of this notice. |
| (c) Exercise and/or defense of rights in court For the purpose of exercising one’s right to legal defense in the context of potential disputes that maya rise with students or before administrative and judicial authorities. | Identification data; Contact data; Data relating to your academic background and career | The processing will be carried out within the framework of the relationship between HABACUS and the students, based on HABACUS’s legitimate interest. This legitimate interest, in all cases, does not imply any prejudice to the rights and freedoms of the data subjects as it is inherent in constitutionally guaranteed rights or, in any case, in the legitimate expectations of HABACUS that do not prejudice the rights and freedoms of the students. |
| (d) Statistical analysis for system improvement and user experience personalization. For data analysis and statistics purposes relating to account information, spending categories, and student consumption statistics, for internal analysis purposes and to develop/improve HABACUS systems. | Identification data; Contact data; Data relating to your academic background and career | The processing will be carried out within the framework of the relationship between HABACUS and the students, based on HABACUS’s legitimate interest. This legitimate interest, in all cases, does not imply any prejudice to the rights and freedoms of the data subjects, as the statistical analyses are conducted on anonymous and/or aggregated data, and such processing is inherent to HABACUS’s legitimate expectations and does not prejudice the rights and freedoms of the students. |
| (e) Response to your support requests To fulfill the requests you make through the use of a Chat. | Identification data, Contact data, Data provided voluntarily in the context of using the chat. | Your Data will be processed to fulfill the contractual obligations arising from the contracts entered into with the interested party and/or to implement pre-contractual measures adopted at the request of the interested party. |
4. NECESSITY OF PROVIDING YOUR PERSONAL DATA
Providing your data is strictly necessary to allow you to use the student loan comparison service. We inform you, however, that with regard to the processing of your data for the purposes set out in Article 3, points c) and d), you may object at any time, for reasons related to your situation. In addition, consent to the processing of your data for the purposes set out in Article 3, points b) above is entirely optional; and failure to consent to one or both of these processing operations will only make it impossible for HABACUS to send you commercial proposals and offers, conduct market research, etc. (point b).
5. PROCESSING METHODS, DATA RECIPIENTS AND TRANSFERS OUTSIDE THE EU
Your Data will be processed using manual and electronic means by HABACUS personnel and collaborators designated as authorized data processors and/or by persons expressly appointed as data controllers, to whom HABACUS has provided detailed operating instructions, particularly regarding the adoption of appropriate technical and organizational security measures, or by persons operating independently as separate data controllers. The list of any data controllers is constantly updated and available at HABACUS headquarters.
Your Data may be transferred for the purposes set out in Article 3 above to third-party collaborators of HABACUS, persons providing services and/or assisting HABACUS in fulfilling the purposes specified in this policy, and competent authorities for compliance with legal obligations and/or provisions of public bodies upon request. Where you have given your consent, for the purposes set out in Article 3, point b), above, your Data may be transferred to companies and sponsoring entities with which HABACUS collaborates. The complete list of recipients of your data is kept at the HABACUS headquarters and is available upon your request, which can be forwarded to the contact details indicated in Article 7.
6. STORAGE PERIOD
Without prejudice to your rights under Article 7, your Data collected and processed by HABACUS will be retained for the time necessary to achieve the purposes for which it was collected and processed. In particular:
- • with reference to the purposes set out in Article 3, point a) above – for the time strictly necessary to perform the services requested by you;
- • with reference to the purposes set out in Article 3, point b) above – until you withdraw your consent;
- • with reference to the purposes set out in Article 3, point d) above – for a period no longer than necessary to carry out the internal analysis and, in any case, no longer than the statute of limitations for non-contractual liability of 5 years from data acquisition;
- • with reference to the purposes set out in Article 3, point e) above – for the time strictly necessary to manage and resolve your support requests.
It is understood that the Data Controller will have the right to retain Your Data, in whole or in part, for a further period, to the extent required by specific legal provisions or in order to exercise or defend a right in a proceeding against You.
7. USER RIGHTS AND CONTACT DETAILS
In relation to the processing of your data by HABACUS, we inform you that you may at any time exercise the rights recognized by the GDPR and other applicable laws regarding the processing of personal data, including, by way of example, the right to:
- • be informed of the existence of processing of your data and request a copy thereof, as well as further information relating to the processing;
- • request a structured copy, in a commonly used and machine-readable format, of the data you have provided, and, where technically possible, request its transmission to a third-party data controller;
- • request HABACUS to correct incomplete, inaccurate, or out-of-date information;
- • in the cases provided for by Art. 17 of the GDPR, request HABACUS to delete certain information concerning you;
- • in the cases provided for by Art. 18 of the GDPR, request HABACUS to restrict the processing of your data;
- • if the processing is based on your consent, the right to withdraw such consent, it being understood that the withdrawal will not affect the lawfulness of the processing previously carried out;
- • lodge a complaint with a supervisory authority (for example, the Italian Data Protection Authority) if you believe that the processing of your data violates the GDPR or other laws regarding the protection of personal data.
To exercise your rights, you can contact HABACUS informally at one of the following addresses, or at the Data Protection Officer indicated in Article 1:
- • by email, to infoprivacy@habacus.com;
- • by registered mail, to HABACUS s.r.l., Via Cappuccio 14, 20123, Milan (MI).
You can also send requests for clarification regarding this policy (e.g., regarding the recipients of your data) to the same addresses.