Privacy Statement for the use of the website www.socialsurf.eu

Socialsurf S.r.l., with registered office in Italy, at Corso Botta 18, 10015 Ivrea (TO), VAT no. 01157770072, as data controller (hereinafter, “Data Controller”), informs you pursuant the EU Regulation no. 679/2016 (“GDPR”) and the legislation, even national, on personal data protection from time applicable (“Privacy Legislation”) that your personal data shall be processed according to the following modalities and for the following purposes:

1. Object of the Processing

The Data Controller processes the personal data (hereinafter “Data” or “Personal Data”) communicated by you while browsing on the website of the Data Controller www.socialsurf.eu (hereinafter “Site”) and/or in case of forwarding an online contact request to the Data Controller: 

• identifying and non-sensitive/particular data (e.g., name, surname, email address, telephone number, IP address, etc.);
• your preferences and interests (e.g,, browsing data on the Website, IP address, devices and connectivities used), also by means of cookies or similar technologies. 

2. Purposes and legal bases of the processing

Your Personal Data are processed for the following Purposes and legal bases: 

1. without your prior consent, for Contractual Purposes: 

A.1) the execution of the contract or the fulfillment of pre-contractual obligations, in particular::

• manage a contact request of yours that is received by means of channels at your disposal, such as e-mail contacts available on the site.

A.2) the pursuit of a legitimate interest of the Data Controller, in particular:

• Analyze cookies, as indicated in the COOKIE Policy, resulting from your use of the Website;
• manage and maintain the Website; 
• prevent or discover fraudulent activities or harmful abuses for the Site; 
• exercise the rights of the Data Controller, such as the right to defence in court; 

1. only with your prior consent, for Marketing Purposes indicated below:

• inform you by sending brochures by means of regular letters, emails, notice and newsletter of the initiatives and commercial offers of the Data Controller. 

3. Modalities of Data Processing

The processing of your Data is carried out, electronically, by means of data collection, registration, update, organization, storage, consultation, elaboration, amendment, selection, retrieval, comparison, usage, interconnection, blockage, communication, erasure and destruction operations.

4. Data Storage

The Data Controller shall process the Personal Data for a duration that is necessary to fulfil the above purposes and anyway for no longer than 5 years after the collection for Contractual Purposes and for no longer than 2 years after the collection for Marketing Purposes. 

5. Access to Data

Your Data may be made accessible for the purposes mentioned above to:

• employees and/or collaborators of the Data Controller, as persons in charge of the processing and/or internal Data Processors and/or system administrators;
• third companies or other subjects (e.g., IT service providers, suppliers, credit institutes, professional firms, etc.) carrying out outsourcing activities on behalf of the Data Controller as external Data Processors.

6. Data Communication

Your Data may be communicated, even without your prior consent, for the above-mentioned purposes and upon their request, to control bodies, police or judiciary bodies, that will process them in their quality of independent Data Controllers for institutional purposes and/or pursuant to the law during investigations and controls. Moreover, your Data may be communicated to third parties (for example, partners, independent contractors, agents, etc.) that will process them as independent Data Controllers to carry out activities that are instrumental to the above purposes.

7. Data Transfer

Data are not disseminated nor transferred to extra-EU countries. 

8. Nature of the Data provision and consequences of a refusal to answer

The provision of Data for Contractual Purposes is mandatory. If you decide not to provide your Data, we will not be able to reply to your request.  

The provision of Data for Marketing Purposes is voluntary. You should decide not to provide your Data or to deny the possibility of processing data that you already provided at a later time: in that case, you will not be able to receive commercial communications and brochures any longer, but you will be entitled to benefit from the services of the Website.

9. Data Subject’s Rights

The Data Controller informs you that you, as Data Subject, if allowed by the law, have the right to:

• obtain confirmation over the existence or inexistence of Personal Data relating to you, even if not yet registered, and their communication in a comprehensible way;
• obtain the indication and, if necessary, the copy of the: a) source and category of the Personal Data; b) logic applied in case the processing is performed by means of electronic instruments; c) purposes and modalities of the processing; d) identification references of the Data Controller and the Data Processors; e) subjects or categories of subjects to whom Personal Data may be communicated or who may come to know, in particular if recipients are extra-EU countries or international organizations; e) period for which the Personal Data will be stored, or if that is not possible, the criteria used to determine that period; f) existence of an automated decision-making process and, in this case, information about the logic involved, the significance and consequences for the data subject; g) existence of adequate safeguards in case of transfer of Personal Data to an extra-EU country or international organization;
• exercise the right to withdraw consent at any time, easily, without impediment, by using, if possible, the same channels required to provide consent;
• obtain, without undue delay, the update and the rectification or, whether you are interested, the integration of incomplete Data;
• obtain the erasure, the transformation into anonymous form or blocking of the Data: a) processed in breach of the law; b) no longer necessary in relation to the purposes for which the Data have been collected or subsequently processed; c) if you withdraw consent on which the processing is based and  there is no other legal ground for the processing; d) if you object to the processing and there are no overriding legitimate grounds for the processing; e) in compliance with a legal obligation; f) referred to children. The Data Controller may refuse to erase them when the processing is necessary: a) to exercise the right of freedom of expression and information; b) in compliance with a legal obligation, for the performance of a task carried out in the public interest or in the exercise of official authority; c) for reasons of public interest; d) to achieve purposes in the public interest, scientific or historical research purposes or statistical purposes; e) for making legal claims;
• obtain the restriction of processing when: a) the accuracy of the Personal Data is contested; b) the processing is unlawful and the data subject opposes the erasure of the Personal Data; c) Data are required by you for your exercising of  legal claims; d) pending verification whether the legitimate grounds of the controller override those of the data subject;
• receive the Personal Data concerning you in a structured, commonly used and machine-readable format and transmit those data to another controller without hindrance from the controller to which the personal data have been provided, if the processing is carried out by automated means;
• oppose, in whole or in part: a) for lawful grounds to the processing of Personal Data regarding you, even if pertaining the purpose of Data collection; b) to the processing of Personal Data that relates to you for the purpose of sending advertising material or of direct sale or for market researches or commercial communication, by means of automated call systems without the intervention of an operator, e-mail and/or traditional marketing methods by telephone and/or paper mail.
• submit a data protection complaint to the competent supervisory authority.

In the cases mentioned above, if necessary, the Data Controller shall communicate any exercise of your rights to each third party to whom the Personal Data are communicated, except for specific cases (for example, if this proves impossible or involves disproportionate effort).

10. Modalities of Exercise of Rights

You shall be able to exercise your rights anytime: 

• by sending a registered letter with return receipt to the address of the Data Controller; 
• by sending an email to ivrea@socialsurf.eu;
• by calling the following skype number skype:tanobonfi?call.

11. Data Controller and Data Processor 

The Data Controller is: 

• Socialsurf S.r.l., with registered office at Corso Botta 18, 10015 Ivrea.

The appointed Data Protection Officer is:

• Mr. Gaetano Bonfissuto

The updated list of Data Processors is kept at the office of the Data Controller.

Ivrea May 24 2018

Socialsurf S.r.l.