Privacy Policy

This Privacy Policy (hereinafter referred to as the “Privacy Policy”) is intended to inform users regarding the processing of personal data, defined as any information that allows for the direct or indirect identification of a natural person (hereinafter referred to as “Personal Data” or “Data”) collected through the website www.sys-man.it (hereinafter referred to as the “Website”).

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

The Data Controller reserves the right to modify or update this Privacy Policy, in whole or in part, by notifying users of such changes. Any modification or update shall be binding upon publication on the Website. Accordingly, users are encouraged to periodically review this Privacy Policy. Should a user not agree with any change to this Privacy Policy, they are obliged to cease their use of the Website and may request the Data Controller to delete their Personal Data.

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, access credentials for available services and/or products, as well as personal interests and preferences.

Should the user decide not to disclose Personal Data necessary for a contractual relationship, it will be impossible for the Data Controller to provide, in whole and/or in part, the relevant services.

The user who provides the Data Controller with Personal Data relating to third parties is solely and exclusively responsible for their origin, collection, processing, communication and/or disclosure.

• Data and information automatically collected during the use of the Website

Such information include:

• Technical Data: The IT system and software procedures supporting the Website may acquire Personal Data during their normal operation, the transmission of which is implicit in the use of Internet communication protocols. These information are not collected with the intention of associating them with specific individuals; however, by their nature, they may allow for the identification of users through processing and associations with data held by third parties. This category includes IP addresses or domain names used by users when connecting to the Website, URIs (Uniform Resource Identifiers) of the 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 regarding the user’s usage of the Website, such as visited pages, actions performed (e.g., clicks on links, downloads), and features and services utilized.
• Geolocation Data: The Website may collect Personal Data related to the user’s location, consisting of GNSS data (Global Navigation Satellite System, such as GPS), as well as data identifying the nearest repeater, Wi-Fi and Bluetooth access points, communicated when enabling location-based products or features.

• Personal Data collected via cookies or similar technologies

The Website employs cookies, web beacons, unique identifiers, and other similar technologies to collect Personal Data regarding the visited pages, clicked links, and other actions taken during the use of the Website. Such data is retained to be communicated to the same website upon the user’s subsequent visit.

Users may review the complete Cookie Policy at the following address: https://www.sys-man.it/cookie-policy.

Purposes of processing

The collected Personal Data may be used for the fulfillment of contractual, pre-contractual, and/or legal obligations.

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

The collected Personal Data are communicated to Google Inc. as outlined in 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-based, computer, and/or telematic tools, with organizational methods strictly related to the stated purposes.

In certain cases, individuals other than the Data Controller involved in the Data Controller’s organization (such as administrative staff, sales personnel, system administrators, etc.) or external parties (such as IT companies, service providers, postal couriers, hosting providers, etc.) may have access to Personal Data. These individuals, where necessary, will be appointed as Data Processors by the Data Controller and will only have access to Personal Data when required, and shall be contractually obliged to maintain confidentiality and to comply with applicable regulations.

An updated list of ata Processors can be requested via email at privacy@sys-man.it.

Transfer of Personal Data outside the European Union

The collected Personal Data may be transferred to countries located outside the European Union (EU) or the European Economic Area (EEA). In such cases, the Data Controller ensures that such transfers are conducted in accordance with applicable legal provisions, particularly 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 for Personal Data. Users may request further information or a copy of the adopted guarantees by contacting the Data Controller at the email address privacy@sys-man.it.

Legal basis for processing

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

• The user’s consent for one or more specific purposes;
• The processing is necessary for the performance of a contract with the user and/or for the execution of pre-contractual measures;
• The processing is necessary to fulfill a legal obligation or an order received from the Authority, to which the Data Controller is subject;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested by the Data Controller;
• The processing is necessary for the pursuit of legitimate interests of the Data Controller or third parties, such as implementing security measures, preventing fraud, or conducting internal and administrative management;
• The processing is necessary to safeguard vital interests of the Data Controller or third parties.

Users may always request the Data Controller to clarify the legal basis for each processing activity at privacy@sys-man.it.

Location

Personal Data are processed at the operational offices of the Data Controller and in any other location where the parties involved in the processing are located. For further information, users can contact the Data Controller at the email address privacy@sys-man.it or by postal mail at Via Benedetto Croce 62 A/1, 00142 Rome.

Security of processing

The processing of Personal Data is conducted through appropriate measures and tools to ensure the security and confidentiality of Personal Data, as the Data Controller has implemented appropriate technical and organizational measures to ensure, in a verifiable way, the compliance with applicable law.

Retention period for Data

Personal Data will be retained for the time necessary to achieve the purposes for which they were collected. For example, Personal Data will be retained for the entire duration of the contractual relationship with the user, if present, and for the time necessary to fulfill related obligations.

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

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

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

Automated decision-making

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

User Rights

Users may exercise specific rights regarding their Personal Data processed by the Data Controller. In particular, the users have the right to withdraw their consent at any time, object to the processing of their Data, access their Data, monitor and request rectification of their Data, obtain a restriction of processing, obtain the deletion of their Personal Data, receive their Data or obtain the transfer to a different data controller, lodge a complaint with the supervisory authority for personal data protection, or take legal action.

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