INDEX

1. The "Owner" of the Treatment
2. Place of data processing
3. Processing methods
4. Categories of personal data processed
5. Use of the Site and purpose of the processing
6. Legal basis of the processing
7. Categories of recipients of personal data
8. Transfer of personal data
9. Retention period
10. Cookies
11. Rights of interested parties
12. Changes to this Privacy Policy

PRIVACY POLICY

With this Privacy Policy HUB2DATA S.r.l. intends to describe how the Site is managed with reference to the processing of the personal data of users who access it.

This is an information provided in accordance with the provisions of art. 13 of the EU Regulation on the protection of personal data n. 679/2016 (GDPR) and to all other laws applicable to all those who consult the website (the "Site"). 

1. The "owner" of the treatment and contact details

Following access and consultation of the Site, data relating to identified or identifiable persons may be processed.

The data controller of the personal data collected is HUB2DATA S.r.l. (“HUB2DATA”), with registered office in Corso Mazzini 3 Pavia (PV).

The user can contact the Data Controller at the aforementioned postal address or by means of the following telephone number or e-mail address: • privacy@hub2data.com

2. Place of data processing

The treatments connected to the data collected with reference to those who access the Site, are mainly carried out at the headquarters of HUB2DATA S.r.l., and in any case in compliance with the provisions of the GDPR and all other applicable laws.

Personal data are processed only by persons with adequate technical skills, employees or collaborators, specially trained and designated persons authorized to process and or by persons designated as data processors.

3. Processing methods

The data will be processed lawfully, fairly, in such a way as to guarantee its security and confidentiality, according to the provisions of the GDPR and all other applicable laws. Personal data will be processed with electronic or automated tools. 

4. Categories of personal data processed

• With reference to navigation data, the computer systems and software procedures used to operate this Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. This is information that is not collected to be associated with identified data subjects, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request the server and other parameters relating to the operating system and the user's IT environment.
• The optional and voluntary sending of e-mails to the addresses indicated on the Site or the completion of the appropriate contact form entails the acquisition of the user's personal data, as indicated therein, necessary to respond to their requests.
• In addition, on the Site there are particular "buttons" (called "social buttons / widgets") that depict the icons of social networks (eg: LinkedIn, etc.) and other web services (eg: Youtube). These buttons allow users who are browsing the Site to access the reference social networks with a "click". In this case, the social network and web services acquire data relating to the user, while the Data Controller will not share any navigation information or user data acquired through its site with social networks and web services accessible thanks to the social buttons. / widgets. These services release "third party cookies". Below are the links to the privacy policies of the most used social networks and the websites to which the buttons refer:
• • Linkedin button (Linkedin Corporation)
• The Linkedin button and social widgets are interaction services with the Linkedin social network, provided by LinkedIn Corporation.
• Personal data collected: Cookies and Usage data.
• Privacy Policy: https://www.linkedin.com/legal/privacy-policy

• YouTube Cookies

Youtube is a video content viewing service managed by Google Inc. that allows this Application to integrate such content within its pages https://policies.google.com/privacy

The User can find more information about the data collected directly or by third parties through cookies in the relevant Cookie Policy of the Site.

5. Use of the Site and purpose of the processing

User data may be processed for:

1. carrying out the operations that allow navigation between the pages of the Site. The Data Controller, like most of the owners of web pages, needs to proceed with the processing of the personal data of users collected automatically or provided by them through navigation or the use of the Site to allow the latter to use and operate it. This Privacy Policy, therefore, refers exclusively to the Site and does not also concern other sites, pages or online services that can be reached via hypertext links that may be published within it;
2. carrying out the operations strictly necessary in order to proceed with the provision of services or to meet, if necessary, requests by the user through the appropriate contact form on the home page of the Site.
3. statistical processing of aggregate data in relation to the performance of the Site;

6. Legal basis of the processing

The processing of the user's personal data will be carried out on the basis of one or more of the following conditions of legitimacy. In particular, the treatments carried out for the purposes referred to in:

letters a. and b. mentioned above, have as their legal basis the need to execute requests for the provision of a service or response to a user request. This processing is, therefore, strictly necessary and connected to a pre-contractual phase at the request of the interested party and / or contractual or functional to respond to a specific request from the user pursuant to art. 6 par. 1 letter b) of the GDPR. In this regard, the personal data collected from time to time through the Site are necessary. If the user does not intend to provide them, it will not be possible to provide the service or follow up on requests;

letter c. cited above, has as a proportionate and necessary legal basis the legitimate interest of the owner pursuant to art. 6 par. 1 letter f) of the GDPR, consisting in improving performance and verifying the correct functioning of the Site. In this regard, we also invite you to consult the Cookie Policy of the Site. 

7. Categories of recipients of personal data

The Data Controller, for the same purposes as this Privacy Policy and / or in any case for purposes strictly functional to the services provided by the Site, may communicate the user's data to subjects who will act as data processors pursuant to art. 28 of the GDPR that will perform or provide specific services such as:

• Hosting and back end infrastructure

This type of service has the function of hosting data and files that allow the Site to function and process the data in order to allow the user to use it.

• Site Administration (administrative, commercial, legal, system administrators).
• Statistics

The services contained in this section allow the Owner to monitor and analyze traffic data on the Site. The Owner uses this service in order to perform aggregate analyzes on its users anonymously and, thus, improve the performance of the Site. All services statistics are used by the Data Controller through an integration that makes the user's IP address anonymous, including:

Google Analytics with anonymized IP is a free statistical service provided by Google Inc.

Personal Data collected: Cookies and Usage Data.

Privacy Policy https://policies.google.com/privacy?hl=it - Opt Out google.com/settings/ads/onweb/optout.

The user can always request an updated list of data processors from the Data Controller.

8. Transfer of personal data

Generally, the data of users of the Site will not be transferred outside the European Union. However, it is possible that this transfer takes place on the basis of the single service provided by HUB2DATA or as a result of the functions implemented on the site (eg: social button, connection to third party sites). For each service requested by the customer of HUB2DATA, a specific information will be provided with the details of the states where (possibly) the data will be transferred, as well as the possibility for the user to verify the information of the third party data controllers. In any case, with respect to the services provided by HUB2DATA, should personal data be transferred outside the European Union, the transfer will be carried out in compliance with the provisions of the GDPR and all other applicable laws with adequate guarantees in matter of protection of personal data. 

9. Retention period

For each service or initiative requested by the HUB2DATA customer, a specific information will be provided (where applicable) with details of the retention period of personal data or the criteria used to determine this period.

HUB2DATA processes and stores navigation data for the time required by the purposes for which they were collected. Therefore:

• the data collected for purposes instrumental to the execution of a contract between the Owner and the user will be kept until the execution of this contract / request is completed and for the processing time or duration of the same.
• Furthermore, the Data Controller may be obliged to keep personal data for a longer period in compliance with a legal obligation or to keep them on the basis of their legitimate interest for any management of disputes or pre-litigation in progress.

With regard to navigation data, the Data Controller will delete such data after 12 months following the last online interaction with respect to the communications of the Data Controller or with the contents published on the Site of which the Data Controller has direct evidence of this interaction (eg: click, opening , reply).

10. Cookies

For details on the use of cookies on this site, please refer to the Cookie Privacy Policy. 

11. Rights of interested parties

We inform you that, pursuant to art. 15 - 22 of the GDPR, the user may exercise the following rights, including: obtaining access to his personal data and information pursuant to art. 15 of the GDPR, request its correction or cancellation or the limitation and / or integration of the processing. It also has the right to object to the processing, as well as the right to request its portability in the cases referred to in art. 20 and 21 of the GDPR. In addition, the user, at any time, may revoke the consent given, specifying that the revocation of the consent does not affect the lawfulness of the processing carried out until the revocation.

In such cases, you can exercise your rights by contacting the Data Controller at the following contact details: • privacy@hub2data.com

The interested party can also lodge a complaint with the Guarantor for the Protection of Personal Data, by following the instructions at the following link: http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524

Responsible for data protection

For any questions regarding the processing of your personal data, you can contact the Data Protection Officer using the following contact details:

email: privacy@hub2data.com; pec: hub2data@pec.it

 12. Changes to this Privacy Policy

The Owner reserves the right to make changes to this Privacy Policy at any time by informing users on this page and, if possible, on the Site. Please therefore consult this page regularly, referring to the date of the last modification indicated at the bottom.