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SMARTGYRO S.R.L. (the “Company”), in connection with the provision of the products and services (the “Service”) to customers (the “Customers”) residing in the European Economic Area (the “EEA”, and the countries that are members of the EEA are individually or collectively referred to as “EEA member countries”), for the purpose of complying with the EU General Data Protection Regulation (the “GDPR”) and to appropriately process the personal data of the Customers residing in the EEA, hereby establishes this “Privacy Policy” (this “Privacy Policy”).


1. Processing Personal data

(1) Definitions

  • Personal data” means any data relating to an identified or identifiable natural person, including, without limitation, name, address, date of birth, telephone number, e-mail address and user IDs of Customer residing in the EEA.
  • Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • Controller” means a legal person, etc. which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processor” means a legal person, etc. which processes personal data on behalf of the Controller.


(2) Types of personal data to be collected

The Company will collect the following types of personal data concerning Customers in connection with the Service:

  • (a) e.g. name, address, etc.
  • (b) phone number, fax number, etc.
  • (c) e-mail address etc.


(3) Purposes of use of personal data

The Company will process the Customer’ personal data for the following purposes:
(b) to respond to inquiries and requests from Customers;
If the Company is to process the Customer’ personal data for purposes other than the above, the Company will notify Customers in advance such new purposes of use and other matters as required by applicable laws.
By manifesting their intention to consent to this Privacy Policy, Customers will be deemed to have consented to the processing of their personal data by the Company within the scope of the above purposes of use, and the Company will process the Customers’ personal data based on such Customers’ consent; provided, however, that Customers may withdraw such consent at any time, which such withdrawal shall not affect any legitimate processing performed pursuant to the consent prior to the withdrawal. The Company may also process the Customers’ personal data within the scope of the above purposes of use under a legal basis permitted by GDPR (e.g. performance of a contract, compliance with a legal obligation, legitimate interests).
The Company may require Customers to provide their personal data in connection with the provision of the Services. In such case, if certain Customers do not provide its personal data, the Company may be unable to provide the Services.


(4) Retention Period

The Company will retain the Customers’ personal data to the extent the Company requires such data for achieving the purposes of use specified in 1.(3) above, and will promptly delete the same when such data is no longer necessary.


(5) Third Party Transfer

The Company may provide the Customers’ personal data to third parties such as the subsidiaries and affiliates of the Company, dealers, retailers, cloud vendors and contractors of the Company, to implement the purposes of use specified above. Such third parties which the Company may provide Customers’ personal data include those located in countries outside the EEA (including, without limitation, Japan), and the Customers are deemed to have consented to the following matters by consenting to this Privacy Policy:

  • (a) Certain countries outside the EEA may not be furnished with the same level of data protection laws as the EEA, thus part of the rights granted to Customers within the EEA may not be available;
  • (b) Customers’ personal data may be provided and processed for the purposes specified in 1.(3) above; and
  • (c) Customers’ personal data may be provided to third parties located in a country outside the EEA.

In addition to the above, if the Company is to transfer the Customers’ personal data to a third party located in a country outside the EEA, the Company will ensure that adequate measures are taken concerning the protection of the Customers’ personal data such as by executing standard contract clauses based on the GDPR.


(6) Disclosure, Correction, and other Procedures concerning the Personal Data
The Customers are entitled with the rights to access to, request for correction, request for deletion, request to limit the processing, object to the processing, and request for data portability, with regards to the personal data retained by the Company pursuant to the provisions of relevant laws and regulations. Such requests shall be attended to the contact point set forth in “5. Contact” as per below.
The Company may refuse the Customers’ request if the Company deems that there is no basis for such request or if the request is deemed excessive.
The Customers may file objections to the data protection authorities having jurisdiction over the location of the Customers’ domicile with regards to the processing of their personal data by the Company.


(7) Unsubscribing from direct marketing
If Customers wish to unsubscribe from the Company’s direct marketing, such Customers should contact the contact point set forth in “5. Contact” below.


(8) Usage of Access Log Information and Cookies
Our website uses cookies for the purpose of improving the website itself.
For further information, please refer to our Cookie Policy.


(9) Social Media Features
The Company’s site may also include social media or lead generation features, such as Facebook buttons and widgets, such as the “share this” button. These features may collect the Customer’s IP address, which page the Customers are visiting on the Company’s site and may set a cookie to enable the feature to function properly. Social media and lead generation features and widgets may be hosted by a third party. The Customer’s interactions with these features and widgets are governed by the privacy policy of the Company providing it.


2. Safety Management Measures

In order to protect the personal data from unauthorized access and loss etc., taking into account the type of personal data, the degree of sensitivity and the degree of affect to the Customers including economic influence and mental harm in case the personal data is unlawfully infringed, the Company has comprehensively evaluated and judged the risks of personal data infringement, and has implemented necessary and appropriate personal, organizational and technical safety management measures in accordance with such the risk of personal data infringement, and further, will review such safety management measures as necessary, set up the process for taking corrective actions, and constantly make effort to improve its security.
The Company will make effort to appropriately manage personal data by restricting the entry of outsiders into the offices where the processing of personal data takes place, conducting educational awareness raising activities targeting all officers and employees involved in the protection of personal data, and appointing managers in charge for each division which processes personal data.
If the Company, in its role as a Controller, contracts a Processor, the Company shall select a Processor which is capable of implementing appropriate technical and organizational measures and shall manage such Processor in an appropriate manner.
Pursuant to the GDPR, the Company shall prepare records of the processing of personal data.


3. Continuous Improvement

The Company shall continuously review and revise its efforts regarding the processing of personal data in order to correspond with changes in the GDPR, processing methods and the environment.


4. Amendment to this Privacy Policy

The Company may amend this Privacy Policy at any time. The Company shall determine the effective date of the amendment and inform the Customers prior to such effective date. The Customers who continue to use the Service on the effective date or thereafter shall be deemed to have consented to the amended Privacy Policy.


5. Contact

The Company’s contact point regarding this Privacy Policy is as shown below. Any questions or concerns regarding this Privacy Policy or the processing of personal data by the Company, or any requests concerning access, correction, deletion, limitation of processing or data portability of the personal data shall be attended to this contact point:

Via Privata O.T.O. 11
19136 La Spezia (SP)

VAT n.  IT 01401260110



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