Privacy Policy

This Privacy Policy (hereinafter "Privacy Policy") aims to inform users about the processing of personal data, considered as any information that allows the direct or indirect identification of a natural person (hereinafter "Personal Data" or "Data"), collected through the website www.sys-man.it (hereinafter "Website").

The "Data Controller" is Sysman Progetti & Servizi Srl, with registered office at Via Benedetto Croce 62 A/1, 00142 Rome, email privacy@sys-man.it.

The Data Controller may amend or update this Privacy Policy in whole or in part, informing users of such changes. Amendments or updates will become binding as soon as they are published on the Website. Therefore, users are invited to periodically review the Privacy Policy. If the user does not accept any changes to the Privacy Policy, they must cease using the Website and may request the removal of their Personal Data from the Data Controller.

Personal Data Collected by the Website

The Data Controller collects the following categories of Personal Data:

Content and information voluntarily provided by the user

This includes Personal Data that the user voluntarily provides through the use of the Website, such as personal details, contact information, credentials to access services and/or products provided, personal interests, and preferences.

If the user decides not to provide Personal Data required for a contractual relationship, the Data Controller may be unable to provide, in whole and/or in part, the related services.

The user who communicates third-party Personal Data to the Data Controller is directly and solely responsible for its origin, collection, processing, communication, and/or disclosure.

Data and content automatically acquired during the use of the Website

These include:

• Technical data: The computer system and software procedures necessary for the operation of the Website may acquire, during normal operation, Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to identify specific individuals; however, it could, by its nature, identify users through processing and association with data held by third parties. This category includes IP addresses or domain names used by users connecting to the Website, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained, etc.
• Usage data: Personal Data may be collected relating to the user's use of the Website, such as pages visited, actions taken (e.g., clicks on links, downloads), features, and services used.
• Geolocation data: The Website may collect Personal Data about the user's location, including GNSS (Global Navigation Satellite System, such as GPS) data, as well as data identifying the nearest cell tower, Wi-Fi, and Bluetooth access points communicated when location-based products or features are enabled.

Personal Data collected through cookies or similar technologies

The Website uses cookies, web beacons, unique identifiers, and other similar technologies to collect Personal Data regarding pages, links visited, and other actions performed during the use of the Website. These data are stored to be communicated back to the website during the user's subsequent visit.

Users can read the complete Cookie Policy at the following link: https://www.sys-man.it/cookie-policy.

Purpose of Processing

The Personal Data collected may be used to fulfill contractual, pre-contractual, and/or legal obligations.

Personal Data may also be used to respond to user requests, provide assistance in case of issues, and monitor and analyze user behavior on the Website.

The Personal Data collected are communicated to Google Inc. as per its privacy policy, available at https://policies.google.com/privacy.

Methods of Processing Personal Data

The processing of Personal Data is carried out using paper, computer, and/or telematic tools, with organizational methods strictly related to the purposes indicated.

In some cases, individuals other than the Data Controller, involved in the organization of the Data Controller (such as administrative staff, commercial staff, system administrators, etc.) or external parties (such as IT companies, service providers, postal couriers, hosting providers, etc.) may have access to Personal Data. Where necessary, these individuals will be appointed as Data Processors by the Data Controller and will have access to users' Personal Data only when required and will be contractually obligated to maintain confidentiality and comply with applicable regulations.

The updated list of Data Processors can be requested by email at privacy@sys-man.it.

Transfer of Personal Data Outside the European Union

The Personal Data collected may be transferred to countries outside the European Union (EU) or the European Economic Area (EEA). In such cases, the Data Controller ensures that such transfers comply with applicable legal provisions, in particular through the adoption of standard contractual clauses approved by the European Commission or adequacy decisions issued by the European Commission itself, to ensure an adequate level of protection of Personal Data. Users can request further information or a copy of the guarantees adopted by contacting the Data Controller at privacy@sys-man.it.

Legal Basis for Processing

The user's Personal Data are processed in accordance with the following legal bases:

• User consent for one or more specific purposes;
• Processing is necessary for the execution of a contract with the user and/or for pre-contractual measures;
• Processing is necessary to comply with a legal obligation or an order received from an Authority to which the Data Controller is subject;
• Processing is necessary for the performance of a public interest task or for the exercise of official authority vested in the Data Controller;
• Processing is necessary for the legitimate interests pursued by the Data Controller or third parties, such as the adoption of security measures, fraud prevention, or internal and administrative management;
• Processing is necessary to protect the vital interests of the Data Controller or third parties.

It is always possible to request clarification from the Data Controller on the legal basis of each processing activity by contacting privacy@sys-man.it.

Location

Personal Data is processed at the operational headquarters of the Data Controller and any other place where parties involved in the processing are located. For more information, users may contact the Data Controller at privacy@sys-man.it or by postal address at Via Benedetto Croce 62 A/1, 00142 Rome.

Security of Processing

The processing of Personal Data is carried out using appropriate measures and tools to ensure the security and confidentiality of Personal Data, as the Data Controller has implemented suitable technical and organizational measures that demonstrably ensure processing is compliant with applicable law.

Retention Period of Data

Personal Data will be retained for the time necessary to achieve the purposes for which it was collected. For example, Personal Data will be retained for the entire duration of the contractual relationship with the user, if any, and for the time required to fulfill obligations inherent to and arising from the contract.

When the processing of Personal Data is based on user consent, the Data Controller may retain Personal Data until such consent is withdrawn.

Personal Data may be retained for a longer period to fulfill a legal obligation or an order from a public authority.

All Personal Data will be deleted or stored in a form that does not allow user identification within 30 days of the end of the retention period. Upon expiration of this period, it will no longer be possible to exercise rights of access, rectification, deletion, and portability of Personal Data.

Automated Decisions

The collected Data will not be subject to automated decision-making processes, including profiling, that may produce legal effects on the user or significantly affect them.

User Rights

Users can exercise specific rights regarding their Personal Data processed by the Data Controller. In particular, the user has the right to revoke their consent at any time, object to the processing of their Data, access their Data, monitor and request the correction of their Data, obtain a limitation of processing, request the deletion of their Personal Data, receive their Data or obtain its transfer to a different data controller, lodge a complaint with the data protection supervisory authority, or take legal action.

To exercise these rights, users can send a request to the contact details of the Data Controller provided in this document. These requests are free of charge and will be handled by the Data Controller as quickly as possible, and in any case within 30 days.