PRIVACY POLICY

REASONS FOR THE‘INFORMATIVE

This privacy policy (the”Privacy Policy“) contains important information about personal data that is collected by visiting this Web Site, and describes how such data is used. This notice is supplementary to any other information that may be received in other circumstances.

 This document contains important information on the following:

  1. PROCESSING OF PERSONAL DATA 
  2. PERSONAL DATA COLLECTED 
  3. PURPOSE OF PERSONAL DATA PROCESSING
    4. COMMUNICATION OF PERSONAL DATA
  4. PROTECTION OF CHILDREN’S PRIVACY 
  5. STORAGE, ACCESSIBILITY AND TRANSFER OF PERSONAL DATA 
  6. SECURITY AND CONFIDENTIALITY OF PERSONAL DATA
  7. RIGHTS OF ACCESS TO PERSONAL DATA-MANAGEMENT CHOICES 
  8. DATA RETENTION 
  9. COOKIE POLICY AND SIMILAR PROCESSES
    11. LINKS, ADVERTISERS, SPONSORS AND ADVERTISING
  10. DATA CONTROLLER – COMPANY CONTACTS 
  11. UPDATES TO THIS POLICY – COMMUNICATIONS

 

ACCEPTANCE

By visiting the Website, using its services or interacting with the Company, you confirm that you have read and understand this Privacy Policy and that you agree that the Company will collect, use, store, transmit and disclose personal data collected through the Website in accordance with this Privacy Policy. The Company may require you to provide your consent (e.g., by checking a box) where it deems it appropriate to safeguard your rights or where required by applicable law. If you do not agree to the terms of this Privacy Policy, please do not visit this Web Site and do not otherwise use this Web Site or submit personal data to it, or do not provide your consent when such an option is offered to you under applicable regulations.


  1. PROCESSING OF PERSONAL DATA

In this Privacy Policy, the term “Personal Data” is used with reference to any information that allows the Company to identify you (or a third party whose data you provide), directly or indirectly, including any information related to the purchase of goods or services, or that you choose to disclose to or share with the Company, or third parties, while using the Websites. Personal data will be processed in accordance with the General Data Protection Regulation (EU) 2016/679 ” Reg. (EU) 2016/679 ” and of LEGISLATIVE DECREE 101/2018. The Company reserves the right to perform additional data processing where required by law or as part of criminal or other investigations or proceedings.


  1. PERSONAL DATA COLLECTED
  1. Data source.

The Company collects personal data from the user only where the user voluntarily provides information, for example:

  • In case of information request through the contact form on the site;
  • In the case of sending your resume;
  • In the case of e-mail, SMS and other electronic messages;
  • In the case of a request to join the mailing list for marketing purposes.
  1. If you provide the Company with personal data of third parties (e.g., family members, other customers or potential customers), you should ensure that such third parties are informed and have authorized the use of their data as described in this Privacy Policy.

 

  1. The Company may collect and use different types of personal data depending on the specific purposes pursued and described below:
  • personal information, such as first name, last name, gender, age/date of birth, country of origin, and other personal information that current regulations allow to be collected;
  • contact information, such as address, email address, telephone number, cell phone number, fax number, if any, and other contact information that current regulations allow to be collected;
  • data related to their utilities.

 

  1. PURPOSE OF PERSONAL DATA PROCESSING

Depending on the specific circumstances under which the interaction between the user and the Company took place, personal data will be used for the specific purposes for which the data was voluntarily provided.

Personal data provided by the user or collected when the user requests a specific service, i.e., personal, contact information and data strictly necessary to fulfill the request, will be used for:

    1. To provide the requested services (e.g., assisting you, responding to a question or contact request you may have submitted, including through the contact form);
    2. Manage newsletter subscription where the user has given specific consent.
    3. Personal data must be provided for the above purposes, and refusal would make it impossible to complete the request.
    4. Except where otherwise required to comply with applicable local regulations, the processing of data for these purposes may be carried out without requiring your consent, as necessary to fulfill your request.
  • Personal data provided by the user during visits to the Web Site or interaction with the Company, i.e., personal and contact information, may be entered into a centralized DataBase to offer promotions, discounts and other personalized services and to send newsletters, other marketing and sales communications about products and services and invitations to events on the Company’s brands, surveys and research, market analysis, invitations to contests, sweepstakes or promotions and other user initiatives (“marketing“). The Company may use traditional means of contact (regular mail and telephone) and/or digital and automated means (e-mail, SMS, MMS, telephone and other digital channels, e.g., social media).  

Entry of data into the DataBase is optional and free of charge (as it is based on consent that the user may choose to give) and can only occur where personal data are provided for the marketing purposes mentioned in Section 3.2. Users may unsubscribe or withdraw their consent at any time (see Section 8 below). In any case, refusal to provide personal data for this purpose does not prevent you from using the Company’s services, but the Company will not be able to inform you of the marketing initiatives and events described above.

  

  1. COMMUNICATION OF PERSONAL DATA

The Company shares your personal data with its related companies, distributors and affiliates, including those located in other countries, and with other companies that provide services on its behalf (as further detailed below), under its direction or that of third parties. These companies and organizations will only receive the personal data necessary to perform the services and will not be allowed to use it for any other purpose.

  1. (a) Disclosure of personal data to data controllers

When you subscribe to the newsletter or use the Company’s online contact services, your personal information may be shared with selected third parties who provide services to the provider.

Your personal data may be shared with third parties to monitor and analyze Website activity, host Website content, provide technical and organizational services functional to the aforementioned purposes, maintain the customer database, provide marketing assistance and manage emails, market analysis, surveys, contests, prize initiatives or promotions. These third parties may have access to or store or process your personal data in order to provide such services on behalf of the Company in Italy, in the country where the user is located or abroad. The Company’s service providers are not authorized to use personal data for purposes other than the provision of contracted services.

 

  1. (b) Dissemination of personal data

In the event of estate or corporate transactions (e.g., mergers or acquisitions, corporate restructuring, or liquidation), customer data will likely be one of the transferred assets and may be shared with legal successors to the extent permitted by law based on the Company’s legitimate interest. Personal data will remain subject to the pre-existing privacy policy, except where the user decides otherwise.

The Company may also disclose your personal data to third parties

  • Where required by EU or member state legislation;
  • In case of legal proceedings;
  • in response to a request from law enforcement that is based on legitimate grounds;
  • to protect the rights, privacy, safety, or property of the Company or the public.

In addition, to the extent permitted by law, the Company may disclose your personal information to third parties in the event of complaints regarding your use of the Web Site, where deemed necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or where the Company, in its sole discretion, believes that your use of the Web Site is inconsistent with the terms of the Web Site.

The full list of designated data controllers and third parties to whom data are disclosed can be obtained using our contact information below (item 12).

  1. PROTECTION OF CHILDREN’S PRIVACY

This Web Site is intended for a general audience; however, its services are intended for people 18 years of age and older. The Company does not knowingly solicit, collect, use, or disclose personal data provided by persons under the age of 18 online. If the Company learns that it has personally collected data from a minor, it will delete it.

In case you are not of the required age, please do not proceed and ask an adult (i.e. your parents or guardian) to perform the necessary procedures.

 

  1. STORAGE, ACCESSIBILITY AND TRANSFER OF PERSONAL DATA

The processing of personal data collected through the Websites is done primarily using electronic or web-based means, including web analytics services hosted by servers of selected providers of the Company operating within the European Union. The processing of personal data may also be performed using paper-based means. In both cases, personal data, are entered into the centralized and secured database by the Company located in Italy and managed by the Data Protection Controller.

 

Access to personal data will be allowed only to authorized personnel, depending on the actual need to know such information and using multi-level access control tools. Such personnel have pledged to comply with confidentiality obligations and have been expressly designated as data processors, as required by current law.  In particular, where the‘user has given his or her consent to the processing of his or her personal data for Marketing purposes, the relevant data may be read, modified and updated by the Company’s sales and marketing personnel. The staff, has received special training and is bound by confidentiality obligations. The Company may use it to collect, use and disclose data according to its instructions.

 

If the Company needs to transfer personal data abroad in order to pursue the purposes set forth in this Privacy Policy, including where the personal data legislation differs from that applicable in the country where the user is located, the Company will take steps to ensure that such communications take place in accordance with European data protection standards or other local standards used in the country where the data is collected, so that the user’s data remains secure and confidential.


  1. SECURITY AND CONFIDENTIALITY OF PERSONAL DATA

The Company has implemented appropriate measures to protect your personal information from accidental loss and unauthorized access, use, modification and disclosure. Password controls are also used in the operation of this Web Site. Although the Company has implemented the above security measures for the Web Site, the user should be aware that 100% security cannot be guaranteed. Therefore, you provide your personal information at your own risk and, to the fullest extent permitted by applicable law, the Company will not be liable in any way for its disclosure due to errors, omissions, or unauthorized actions of third parties during or after its transmission to the Company. The Company recommends that the user:

  • Periodically update software to protect data transmission over networks (e.g., anti-virus software) and check that the electronic communication service provider has adopted suitable means for securing data transmission over networks (e.g., firewalls and junk mail filters);

 

In the unlikely event that the Company believes that the security of your personal information in its possession or under its control has been or may have been compromised, the Company will notify you in the manner prescribed by applicable law, using the methods prescribed by it (by providing the Company with your email address, you consent to receive such communications electronically through that email address).

 

  1. PERSONAL DATA ACCESS RIGHTS – MANAGING CHOICES
  2. (a) User rights

At any time and free of charge, you may access your data, receive your electronic personal data in a structured and commonly used machine-readable format and transmit it to another data controller (data portability), as well as have it corrected, updated, amended or deleted (subject to any applicable exceptions). The user may update the data provided to the Company by contacting the Company at the address provided below. Requests for deletion of data are subject to applicable legal and record-keeping obligations imposed on the Company.

If you believe there is a problem in the way your personal data is handled, you will have the right to file a complaint with your national data protection authority or any other EU or European Economic Area country.

To exercise these rights, the user may send a request by contacting the Company, by sending an email to the address [email protected] or a letter by regular mail to the address below (item 12). When contacting the Company, you should be sure to include your name, email address, mailing address and/or phone number(s) to be sure that the Company can properly handle your request.

 

  1. (b) Accuracy – Updating of personal data.

In order for the Company to better serve you, you are encouraged to check and update your personal information regularly. Users can access and modify their personal data by contacting the Company (see Section 12) for assistance in updating their personal data.

 

  1. (c) Management of choices related to direct marketing

Should the‘user wishes not to provide consent to the‘use of your data for Marketing purposes, you may send a simple request to the Company (see item 12) below or by selecting the appropriate link on the email you receive.

  1. (d) Management of choices related to profiling

Should the‘user wishes not to provide his/her consent for profiling purposes, he/she may send a simple request to the Company (see item 12) below.


  1. DATA RETENTION

Personal data will be retained for the duration of the business relationship and as long as necessary to pursue the purposes described in this Privacy Policy (e.g., where the user subscribes to a newsletter, for the duration of that subscription). After that period, the user’s personal data will be retained only to comply with legal obligations, i.e., to enable the Company to maintain evidence of their respective rights and obligations.

 

The personal data of the‘user that are processed for marketing purposes (Section 3.2) will be retained until consent to their processing for such purposes is withdrawn.


  1. COOKIE POLICY AND SIMILAR PROCESSES

For more general information about cookies and enabling and disabling them, see the Cookies and Advertising Management section of the Web Site at https://certaenergia.it/privacy-policy/


  1. LINKS, ADVERTISERS, SPONSORS AND ADVERTISING

This Web Site may contain links to websites of third parties. Where you choose to provide your personal information on such linked website(s), such information will be subject to the privacy policy and security policies of such linked website(s)-including websites administered and operated by the Company’s approved distributors, except for data collected there by the Company’s distributors for CRM purposes if the Company’s privacy policy is posted-and not to this Privacy Policy. Since the Company is not responsible for information submitted to or collected, used, disclosed, or otherwise subject to processing by third party websites, you should familiarize yourself with such other privacy policies.

The company reserves the right to publish the reviews received on social networks (Facebook, Instagram, Google, etc.).


  1. DATA CONTROLLER – DATA PROTECTION OFFICER – COMPANY CONTACTS

For the purposes of this Privacy Policy and the data processing described herein, it is specified that the term “Company” refers to Spada Media Group S.r.l., with registered office Via E. Marelli, 132 – 20099 – Sesto San Giovanni (MI), Italy. As controller and ultimate beneficiary, the Company is the data controller (as defined in Reg. (EU) 2016/679) of the data collected through the website.

 

If you have any comments or questions about this Privacy Policy and handle inquiries related to data processing, you can also contact the Company’s customer service department at the email address info@agenziaspada.com or by writing to the “Privacy Contact” at Via E. Marelli, 132 – 20099 Sesto San Giovanni (MI), Italy.

 

  1. UPDATES TO THIS POLICY – COMMUNICATIONS

The Company, at its discretion, reserves the right to change, modify, add or delete portions of this Privacy Policy at any time by posting the revised version on this page of the Web Site and updating the Last Modified Date” below. It is your responsibility to review the Privacy Policy from time to time to become aware of any changes that have been made. In some cases, the Company may provide additional notice regarding material changes to this Privacy Policy by posting a notice on the home page of this Web Site or, in the case of registered users, by sending an email notification or by placing a notice on their account page. By accepting such revised Privacy Policy by clicking the “agree” button in such notification email or in the notice posted on your account page (where required to comply with applicable regulations), by completing a purchase on the Web Site or in any store after the revised Privacy Policy is posted, or, otherwise, by using or submitting information to the Web Site after the revised Privacy Policy is posted, you agree to such revised Privacy Policy. Following the changes, where required by applicable law, your information will not be processed without your express consent.

LAST MODIFICATION

This policy is effective as of 16/05/2025