Privacy and cookie policy

PRIVACY POLICY FOR THE WEBSITE WWW.SO-SMART.US

On this page, EOS Solutions Group explains how it handles data for the users who visit its website and the behaviour of the cookies its site installs.

This Privacy Policy is provided in compliance with article 13 of GDPR 2016/679 (General Data Protection Regulation, the European regulation on the protection of personal data), the Guidelines of the Garante Privacy of 10. June 2021, the Guidelines EDPB 5/2020 on consent, the ECJ Judgment 1 October 2019 C-673/17,  the general Act of the Garante Privacy [the Italian Data Protection Authority] on cookies no. 229 of 8 May 2014, the Working Document 02/2013 providing guidance on obtaining consent for cookies”, the opinion of WP 29 no. 4/2012 on cookie consent exemption, the Directive 2002/58/EC, the Recommendation no. 2/2001 by the Workgroup under article 29.

The following information applies only to the site www.so-smart.us; the data controller is not responsible for any data entered or cookies installed by other sites that may be consulted using links.

Information on the data controller and data protection officer

The data controller is EOS Solutions Group (to which the companies EOS SpA, EOS Solutions SpA, DOIT80 Srl, EOS Online SpA and Entity SpA belong), with legal offices at via Giuseppe di Vittorio 23, 39100 Bolzano (BZ). The data controller has also assigned a data protection officer (DPO), the company Effizient Srl, with offices at via Galvani 6/A, 39100 Bolzano (BZ).

To exercise your rights under the regulations, you can contact the data controller at his/her office or by calling 0471 319650 or sending an email to privacy@eos-solutions.it, or to the data protection officer by writing an email to dpo@eos-solutions.it

Purpose and legal basis for data processing

The EOS Solutions Group handles data provided by the user through the site for the following purposes:

a. fulfilment of obligations established by law, by regulations, or by community regulations
The provision of data for this purpose is mandatory and the legal basis for processing it is the fulfilment of a legal obligation to which the data controller is subject, as established by article 6, paragraph 1c of the GDPR. The processing of personal data for these purposes does not require the user's consent. The processed data will be kept for the time foreseen by the referenced legislation.

b. Statistical analysis on aggregate or anonymous data
This processing doesn't allow for the identification of the user, but simply wants to verify the adequacy of adopted web marketing campaigns and/or the correct functioning of the site, measuring user traffic generated. The processing of aggregate or anonymous data, which does not allow for the identification of the user, does not fall within the scope of the application of the law on the protection of personal data and therefore no consent is required for its processing.

c. Request for information, contact and support
The provision of the requested data is necessary to provide feedback to your request. The legal basis of the processing is indicated by Article 6 paragraph 1b of the GDPR, and it is the execution of a contract of which the interested party is party to or the execution of pre-contractual measures adopted at the request of the same, as well as by Article 6 paragraph 1f, and is the pursuit of a legitimate interest of the data controller or third parties. The data processed and relating to your request will be kept by us for one year.

d. Employment application
Submitting the requested data is necessary to provide feedback on your employment application to our facility. The legal basis of the treatment is indicated by Article 6 paragraph 1b of the GDPR and is the execution of a contract of which the interested party is part, or the execution of pre-contractual measures adopted at the request of the same, as well as by Article 6 paragraph 1f, and is the pursuit of a legitimate interest of the data controller or third parties. The data processed and related to your application will be kept by us for two years.

e. Newsletter
The provision of the data required to register for our newsletter and/or to send you communications and promotional materials is entirely optional and the legal basis for this treatment is the express consent of the data subject to the processing of his/her personal data. The data processed for promotional and marketing purposes will be kept by us until its revocation unless consent to its processing is renewed.

f. Profiling (creating profiles based on the user's preferences, habits and consumption choices)
The activity in question can be carried out by filling in dedicated questionnaires or by using online profiling technologies (trackers) or cookies. Providing the data required for profiling activities is optional and the legal basis for processing is the consent given by the data subject to the processing of his/her personal data. The data processed for the purposes of profiling will be processed until its revocation.

Processing methods, automated decision-making processes and data retention times

The processing of your data takes place electronically, although potential paper-based processing is not excluded. No automated decision-making processes are used to process your personal data.
Data collected through cookies will be kept for the period of time established by the individual cookie. Additionally, if profiling cookies are used by the site their function must be described, as required by the specific section.

Data communication (Recipients)

To guarantee the functioning of our website and the use of its content, we may rely on use third-party suppliers such as IT service providers, hosting companies, and communication companies. In addition, to guarantee the requested service, for example in the case of the purchase of products and the likes, we may also use additional third-party suppliers (postal couriers, etc.). The legal basis of the communication is the fulfilment of contractual and regulatory obligations, as well as the execution of pre-contractual measures adopted at your request. It is understood that we will only communicate to the Addressees the data necessary to be able to perform the service, preferring, where possible, the anonymization of the data. The information you provide will not be disclosed without your specific prior consent.

As for the use of third-party cookies, please refer to the specific section at the end of this document.

Transfer of data to third countries or international organizations

The data you have provided will not be transferred by us to third countries or international organizations outside the EU. The hosting of the site is within the European Community.

Rights of the interested party and complaints to the Privacy Guarantor

You have the right to request access to your data at any time, its modification, integration, or deletion, limitation or opposition to its processing, where legitimate reasons exist, as well as the portability of the aforementioned data to another Data controller. We will reply in writing to any requests within 30 days. You can revoke, at any time, consent given to this site, by contacting one of the addresses listed in this Privacy Policy.  You may also lodge a complaint with the National Control Authority, if you believe that your data has been illegitimately processed.

COOKIES ON OUR SITE

Navigation data

This website implicitly acquires, using Internet communications protocols, for and in the course of its normal operations, some personal data on the users who access the site, like IP address, domain names of the computers used for access, MAC addresses assigned by network and wireless card manufacturers, etc.

This information is not collected for the purpose of identifying users, but this could be done by associations and processing, including cross-referencing with third-party data; statistical information is obtained from this data on site usage and operations and further information in cases of establishing responsibility related to computer crimes.

What are cookies?

Cookies are small text strings that the websites visited by a user install on the user’s terminal; these strings are then re-transmitted to the site that installed them upon further visits by the user. When the user also receives cookies sent by other sites or web servers during site navigation, those cookies are called third-party cookies.

Cookies are installed for various purposes, possibly including the performance of computer authentications, navigation session monitoring, and language choice.

First-party cookies and third-party cookies

The cookies that are installed directly by EOS Solutions Group are called ‘First-party cookies’, and the cookies that are installed and acquired by a site other than the one the user is navigating are called ‘Third-party cookies’.

Third-party cookies may include social media buttons (or social media plug-ins), which allow the site to interact with the most popular social media sites, such as Facebook, Instagram, LinkedIn, Twitter, etc., or Google Analytics cookies, which are necessary to implement YouTube iframes, etc. As regards third-party cookies, it is the responsibility of the third parties installing those cookies to provide statements and information on the handling of the data collected.

Types of cookies

Technical cookies

These are normally installed directly by the site administrators and are cookies that allow communications between the site and the user. They can also be called “navigation cookies”, “session cookies”, “essential cookies” or “necessary cookies” and are designed to ensure normal navigation and use of the site and usually last as long as the site is being navigated.

As these cookies are necessary for the functioning of the site, it is not necessary to obtain prior consent for their installation on the users terminal.

Functionality cookies

These cookies provide the user with advanced functionalities and customizations, and they also remember the preferences indicated by the user during previous visits, or the user modifications performed during previous visits in order to customize the site. The cookies that fall under this category, for example, allow the user to choose a language or save the selected products in the cart.

Performance cookies

These “performance cookies” are also known as “analytical cookies”, and they provide an analysis of how the user uses the site in order to improve the navigation experience and resolve issues related to navigation.

These cookies, for example, allow counting visits and tracking traffic sources or the most viewed pages.

Profiling cookies

They can also be called “advertising cookies” and are used to track a user’s preference and offer him/her advertising messages based on those preferences.

First access banner

In the event cookies other than technical cookies are used, the Act of 8 May 2014 by the Garante Privacy  and the Guidelines of the Garante Privacy of 26 November 2020 require the site to provide a banner when a user first accesses the site (called a short notice) that summarises information on the processing methods the site uses for cookies. The banner must refer to the privacy policy in full and must provide a request for consent to the installation of the cookies, even by way of granular selection.

EOS Solutions Group has provided this banner. It has also provided a specific cookie that records the user’s choice regarding cookie installation for 180 days; this means that the user (once given the consent) will see the cookie only one time, and if he/she should later wish to change the choice made, he/she can do this from the link for the cookies management.