Privacy Policy

1. Data Controller

The Data Controller for personal data processing is:

Smart37 SRL
Piazza Monte Grappa, 6
21100 Varese, Italia
Phone: +39 03321730537
Email: info@smart37.com

2. Types of Data Collected

Among the Personal Data collected by this website, independently or through third parties, there are:

• Browsing data: IP address, browser type, operating system, pages visited, date and time of visit
• Voluntarily provided data: name, surname, email address, phone number, company name, messages sent through contact forms
• Cookies and similar technologies: technical cookies, analytics cookies, third-party cookies

3. Purpose of Processing

Personal data is collected for the following purposes:

• Service provision: responding to information requests, providing assistance, managing demo requests
• Commercial communications: with prior consent, sending newsletters and promotional communications about our services
• Analysis and improvement: anonymous statistical analysis to improve the website and services offered
• Legal obligations: fulfillment of obligations required by law, regulations, or EU legislation

4. Legal Basis for Processing

The processing of personal data is based on the following legal grounds:

• Consent: for sending commercial communications and newsletters
• Contract performance: for providing requested services
• Legitimate interest: for analysis and improvement of our services
• Legal obligation: for compliance with legal requirements

5. Processing Methods

Personal data is processed using computer and/or electronic tools, with organizational and logical methods strictly related to the stated purposes.

In addition to the Data Controller, in some cases, other parties involved in the organization of this website may have access to the data (administrative, commercial, marketing, legal personnel, system administrators) or external parties (such as third-party technical service providers, postal carriers, hosting providers, IT companies, communication agencies).

6. Data Retention Period

Personal data will be retained for the time necessary to achieve the purposes for which they were collected, specifically:

• Contact data: for the time necessary to handle the request and for the following 24 months
• Marketing data: until consent is withdrawn
• Browsing data: for a maximum of 12 months
• Contractual data: for 10 years from the end of the contractual relationship

7. Data Subject Rights

Pursuant to Articles 15-22 of EU Regulation 2016/679 (GDPR), the data subject has the right to:

• Access: obtain confirmation of the existence of personal data and access their content
• Rectification: obtain correction of inaccurate data or completion of incomplete data
• Erasure: obtain deletion of data in cases provided by law
• Restriction: obtain restriction of processing in cases provided by law
• Portability: receive data in a structured format and transfer them to another controller
• Objection: object to processing for legitimate reasons
• Withdrawal of consent: withdraw consent at any time

To exercise these rights, please contact us at: privacy@smart37.com

The data subject also has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali).

8. WhatsApp Business Chat Privacy Notice

This website uses the WhatsApp Business chat service to provide user assistance. Below is specific information regarding the processing of personal data provided through this channel, pursuant to Articles 13 and 14 of EU Regulation 2016/679 ("GDPR").

8.1 Subject of Processing

The Data Controller processes your personal data, understood as common identifying contact data (phone number, any name or surname or nickname entered in your WhatsApp profile), as well as any other personal data voluntarily entered by you in the text of messages sent via chat.

8.2 Purpose and Legal Basis

Personal data collected through WhatsApp Business is necessary for:

• The functioning of the chat platform
• Providing personalized assistance
• Responding to user information requests

The legal basis for processing is the explicit consent of the data subject, expressed through the voluntary initialization of the WhatsApp chat, which constitutes a free expression of consent through an unambiguous positive action (Art. 4, point 11 and Art. 6 paragraph 1 letter a. of the GDPR).

Important note: The Data Controller does not use contact data collected through WhatsApp for marketing purposes, sending newsletters, or automatic registration to reserved areas of the website.

8.3 Processing Methods and Data Processors

Data may be made accessible to:

• Employees and collaborators of the Data Controller as persons authorized to process data and/or internal system administrators
• Third-party companies or other entities (e.g., WhatsApp platform, IT consultants) that perform activities on behalf of the Data Controller as data processors

For the data processing methods by the WhatsApp Business platform, as Data Processor, please refer to the "WhatsApp Business Data Processing Terms".

8.4 Automated Decision-Making Processes

The Data Controller does not adopt any automated decision-making process, including profiling, regarding data collected through WhatsApp Business.

8.5 WhatsApp Data Transfer

Personal data collected through WhatsApp Business may be transferred, including for archiving and storage purposes, both to European Union countries and to third countries. The Data Controller ensures that extra-EU data transfers will be carried out in compliance with applicable legal provisions. For specific details, please refer to the WhatsApp Business Data Transfer Appendix.

8.6 Duration of Processing

The Data Controller will process personal data for the time strictly necessary to fulfill the purposes for which they were collected. Upon withdrawal of consent or request for deletion (which can be activated directly through an explicit request via chat or through the methods described in this privacy notice), the data will be promptly deleted from the Data Controller's WhatsApp Business chat. Withdrawal of consent does not affect the lawfulness of processing based on consent given before the withdrawal.

8.7 Optional Nature of Data Provision

Providing data through WhatsApp is optional. The user may decide not to provide any data or subsequently deny the possibility of processing data already provided by withdrawing consent. In such cases, it will not be possible to receive information or assistance through the Data Controller's WhatsApp Business Chat.

9. Cookie Policy

This website uses cookies to improve the browsing experience. The cookies used are:

• Technical cookies: necessary for the functioning of the website
• Analytics cookies: used to collect aggregated information about website usage
• Third-party cookies: installed by external services (e.g., Google Analytics, social media)

Users can manage cookie preferences through browser settings.

10. Data Transfer

Personal data is primarily processed within the European Union. Should it be necessary to transfer data to third countries, this will be done in compliance with the safeguards provided by the GDPR, including the Standard Contractual Clauses approved by the European Commission.

11. Data Security

Smart37 SRL adopts appropriate technical and organizational security measures to protect personal data from unauthorized access, loss, destruction, or unauthorized disclosure. These measures include:

• Encryption of data in transit (HTTPS/SSL)
• Role-based access controls
• Regular data backups
• Staff training on data protection

12. Changes to Privacy Policy

Smart37 SRL reserves the right to modify this Privacy Policy at any time. Changes will be published on this page with an indication of the last update date. We recommend periodically consulting this page.

13. Contact Information

For any questions or requests regarding the processing of personal data, please contact us:

Smart37 SRL
Email: privacy@smart37.com
Phone: +39 0332 1730 600
Address: Piazza Monte Grappa, 6 - 21100 Varese, Italia