(Privacy Code – legislative decree 6.30.2003, no. 196 – Art. 13 – General Data Protection Regulation EU 679/2016 – Art. 13)

The company SPRINTRADE S.r.l., with registered office at 7, Via L. Respighi - 00197 Rome, Fiscal Code and VAT no. 08757631000 (hereinafter, “Controller”), as data controller, informs you pursuant to art. 13 Legislative Decree 6.30.2003 n. 196 (hereinafter, “Privacy Code”) and to art. 13 Regulation EU no. 2016/679 (hereinafter, “GDPR”) that your data will be processed in the following ways and for the following purposes:

1. Purpose of the data processing

The Controller processes all personal data, identifiers (e.g.: name, surname, business name, address, telephone number, e-mail, banking and paying references)  (hereinafter, “personal data” or “data”) communicated by you upon conclusion of contracts for the service of the Controller.

2. Scope of the data processing

Your personal data are processed:

  1. without your explicit consent (art. 24 point a), b), c) Privacy Code and art. 6 point b), e) GDPR), for the following Purposes of Service:  

    • finalising contracts for the services of the Controller;

    • fulfil pre-contractual, contractual and tax obligations arising from outstanding business relations with you;  

    • fulfilling obligations required by law, regulation, EU legislation or an order of the Authority (such as in the context of anti-money laundering);

    • exercise the rights of the Controller, such as the right of defence in any proceedings;

  2. Only upon your specific and unequivocal consent (art. 23 and 130 Privacy Code and art. 7 GDPR), for the following Marketing Purposes:  

    • send you by e-mail, mail and/or SMS and/or telephone communications, newsletters, commercial information and/or advertising material on products or services offered by the Controller and measurement of the satisfaction level on the quality of services

We inform you that if you are already customers and/or suppliers, we may send you commercial information relating to services and products by the Controller similar to those that you have already used, unless you disagree. (art. 130 point 4 Privacy Code).

3. Method of data processing

The processing of your personal data is carried out by means of the operations indicated in art. 4 Privacy Code and art. 4 n. 2) GDPR and specifically: collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is processed both on paper and electronically and/or by automated tools.  

The Controller will process personal data for the time necessary to fulfil the above purposes and in any case for no more than 10 years from the termination of the agreement as far as the Service Purposes are concerned and for no more than 2 years from the collection of data as far as the Marketing Purposes are concerned.

4. Collecting of personal data

In addition to personal data, collected during registration to the Controller’s platform, the website collects, for information purposes only, the following data transmitted to the server by the browser which are technically required for viewing our website and for ensuring stability and security (the relevant applicable provisions are Art. 6 paragraph 1 point f EU standard regulation no. 679 of 2016):

  • IP address

  • Date and time of your enquiry

  • Temporal time zone difference from Greenwich Mean Time (GMT)

  • Content of the enquiry (specific page)

  • Access status/http Status code

  • The amount of data transferred

  • Website issuing the enquiry

  • Browser

  • Operating system and related interface

  • Language and version of your browser software.

When you contact us by e-mail or via a contact form, the information you provide (your e-mail address, if applicable, your name and telephone number) will be stored by us in order to answer your questions. We delete data that emerges in this context after storage is no longer required, or limit processing if there are legal storage requirements.

If we use service providers affiliated with us for individual functions of our services or if we wish to use your data for advertising purposes, we will inform you specifically about the relevant procedures below. We also specify the criteria set for the data storage period.

5. Websites and services of third parties

Sprintrade.com embeds in its pages third-party services that may set and use its own cookies and/or similar technologies. The use of such cookies and similar technologies by such companies is disciplined by the privacy policies of such companies and not by this policy as Sprintrade.com is totally unrelated to the management of such tools and the processing of data deriving from them. You can identify registered Cookies to third parties at the following address: http://www.youronlinechoices.com/it. Below we provide a (non-exhaustive) list of some of the partner companies that may use cookies while visiting the Sprintrade.com network:

6. Use of cookies:

In addition to the above information, when you use our website this website uses cookies stored on your computer. Cookies are small text files stored on your hard drive in your browser and through which certain information is provided to the site that sets the cookie. Cookies cannot run programs or transfer viruses to your computer. They are designed to make the Internet a more user-friendly and effective tool overall.

You can configure your browser settings according to your needs and, for example, refuse the acceptance of third party cookies or all cookies. Please note that, in such a case, you may not be able to use all features of this website.

Our website uses cookies to identify the user for follow-up visits if the user has an account with us. If not, it is necessary to log in again on each visit.

Our website uses the following types of cookies, with the following purpose and functionality:

    1. Technical cookies

This type of cookie facilitates the correct functioning of specific sections of the Site. These cookies, always sent by our domain, are necessary to correctly visualise the site and in relation to the technical services offered, will therefore always be used and sent, unless the user modifies the settings on his browser (thus affecting the visualization of the pages of the site).

They fall into two categories, permanent and temporary:

      • Permanent cookies are automatically deleted after a specified period of time, which may vary depending on the cookies. You can delete cookies at any time in the security settings of your browser.

      • Temporary cookies are automatically deleted when you close your browser. This includes in particular session cookies. These store a so-called session ID, by means of which you can assign different browser enquiries to the common session. This will allow your computer to be recognised when you return to the website. Session cookies are deleted when you log out or close your browser.

In more detail, Sprintrade's technical cookies are:

      • asm_lang – Language for the frontend

      • sprintradecookie – if cookies are accepted or not

      • wkn – shopping cart

      • kpass / kname – login info

    1. Analytical cookies

Cookies in this category are used to collect information about your use of the website. Sprintrade.com will use this information for the sole purpose of anonymous statistical analysis in order to improve the use of the Website and to make the content more interesting and relevant to the preferences of users. This type of cookie collects anonymous data about the users' activity and how they arrived on the Website. Analytical cookies are sent by the Website itself or by third party domains.

    1. Third parties services analysis cookies

These cookies are used to collect information about the use of the Website anonymously, such as: pages visited, browsing time, origin of traffic, geographic origin, age, gender and interests for marketing campaigns. These cookies are sent by third party domains outside the Website.

    1. Cookies to integrate software products and features of third parties

This type of cookie integrates functionalities developed by third parties within the pages of the Website such as icons and preferences expressed in social networks for the purpose of sharing site content or for the use of third party software services (such as software to generate maps and other software providing additional services). These cookies are sent by third party domains and partner sites providing their functionality within the pages of the Website.

    1. Profiling cookies

These are the cookies needed to create user profiles in order to send advertising messages in line with the preferences expressed by the user within the pages of the Website. Sprintrade.com, in compliance with applicable law, is not required to ask for consent for technical and analytics cookies, as they are necessary to provide the services requested. For all other types of cookies, the User may give his/her consent by one or more of the following actions:

      • By setting up specific configurations of the browser or of the associated software used to browse the pages within the Website.

      • By modifying settings when using third-party services

Both these options may prevent you from using or viewing any portions of the Website. Sprintrade's profiling cookies are the following:

    • extgt: Cookie-Opt-Out/-In

    • udc_: own cookies AdServer

    • _rt/rtpgy: Retargeting

    • asm_lang: language

    • AdCl_: tracking data Action Tracking post-click

    • AdV_: tracking data Action Tracking Post-View

    • cust: Tracking Data Customer Journey

    • tgt: user profile data

    • ex: exclusions

7. How to disable cookies by configuring your browser:

  1. Chrome

    • Run the Chrome Browser

    • Click on the menu in the browser toolbar next to the URL input window for navigation

    • Select Settings

    • Click View Advanced Settings

    • In the “Privacy” section click on the “Content settings” button

    • In the “Cookies” section, you can modify the following cookie settings:

    • Allow data to be saved locally

    • Only modify local data until the browser is closed

    • Prevent websites from setting cookies

    • Block third party cookies and website data

    • Administering exceptions for certain websites

    • Deleting any or all cookies

  2. Mozilla Firefox

    • Run the Mozilla Firefox Browser

    • Click on the menu in the browser toolbar next to the URL input window for navigation

    • Select Options

    • Select the Privacy panel

    • Click Show Advanced Settings

    • In the “Privacy” section click on the “Content settings” button

    • In the “Tracking” section, you can change the following cookie settings:

    • Prompt websites not to do any tracking

    • Notify websites of acceptance to be tracked

    • Do not disclose any personal data tracking preferences

    • Go to “Use custom settings” select to accept third party cookies (always, from the most visited websites or ever) and to retain them for a certain time ( until their expiration, closure of Firefox or to ask each time

    • Removing individual saved cookies

  3. Internet Explorer

    • Click the Tools button and choose Internet Options

    • Click the Privacy tab and in the Settings section, change the slider to the action you want for cookies:

    • Block all cookies

    • Allow all cookies

    • Selecting which websites to obtain cookies: move the cursor to an intermediate location so that you do not block or allow all cookies, then click on Websites, enter a website in the Website Address box and then click Block or Allow

  4. Safari

    • Click on Safari, select Preferences and press on Privacy

    • In the Block Cookies section specify how Safari should accept cookies from websites.

    • To view which sites have stored cookies click on Details

  5. Safari iOS

    • Tap on Settings, and then on Safari

    • Tap on Block Cookies and choose between the following options: “Never”, “Third Party and Advertiser” or “Always”

    • To delete all cookies stored by Safari, tap on Settings, then on Safari and then on Delete Cookies and Data

  6. Opera

    • Click on Preferences then on Advanced and then on Cookies

    • Select one of the following options:

    • Accept all cookies

    • Accept cookies only from the website you visit: third party cookies that are sent by a domain other than the one you are visiting will be rejected

    • Never accept cookies: all cookies will never be saved

8. Access to data

Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):

  • to employees and collaborators of the Controller in Italy and abroad, in their capacity as persons in charge and/or internal data processors and/or system administrators;  

  • to third companies or other parties ( for example, bank institutes, professional studios, consultants, software companies..., etc.) performing outsourcing activities on behalf of the Controller, in their role of external data processing responsible.  

9. Communication of data

Without the need for an explicit consent (ex art. 24 points a), b), d) Privacy Code and art. 6 points b) and c) GDPR), the Controller can communicate your data for the purposes referred to in art. 24. 2.A) to any judicial authorities as well as to those persons to whom the communication is mandatory by law in order to carry out the aforesaid purposes. These subjects will process the data in their role as autonomous data controllers.

Your data will not be disclosed.

10. Transfer of data  

Personal data are stored on servers located within the European Union. In any case, it remains understood that the Controller, should it be necessary, will have the right to move the servers also outside the EU. In this case, the Controller hereby states that the data transferred outside the EU will be carried out in compliance with the applicable legal provisions, subject to the subscription of the standard contractual clauses established by the European Commission.

11. Nature of data provision and consequences of refusal to answer

The submission of data for the purposes referred to in art. 2.A) is mandatory. Without them, we will not be able to guarantee you the Services of art. 2.A).

The submission of data for the purposes referred to in art. 2.B) is optional. You may therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you may not receive newsletters, commercial information and advertising materials relating to the Services offered by the Controller. In any case, you will continue to be entitled to the Services referred to in art. 2.A).

12. Rights of the data subject

In your role as data subject, you have the rights stated under art. 7 Privacy Code and art. 15 GDPR and specifically the rights of:  

  1. obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet recorded, and their communication in intelligible form;  

  2. obtain information on: a) the source of the personal data; b) the purposes and methods of processing; c) the criteria applied in the case of processing carried out with the aid of electronic instruments; d) the identification data of the controller, data processors and any designated representative appointed in compliance with Article. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may acquire them in their role as designated representative in the territory of the State, managers or agents;  

  3. obtain: a) updating, rectification or, where this is in his/her interest, integration of the data; b) cancellation, transformation into anonymous format or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) certification to the effect that the operations as per points a) and b) have been notified, as also related to their contents, to the subjects to whom the data were communicated or shared, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right to be protected;  

  4. oppose, in whole or in part: a) for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of collection; b) the processing of personal data concerning you for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial information, through the use of automated calling systems without the intervention of an operator by e-mail and / or by traditional marketing means by telephone and / or mail. Please note that the right of opposition of the data subject, set out in point b) above, for purposes of direct marketing through automated means extends to traditional ones and that it remains however the possibility for the data subject to exercise the right of opposition even if only in part. Consequently, the data subject may choose to receive only communications by traditional means or only automated communications or neither of the above.

Where applicable, he also has the rights under Articles 16-21 GDPR (Right of rectification, right to be forgotten, right to limit processing, right to data portability, right to oppose), as well as the right to complain to the Regulatory Authority.

13. How to exercise such rights

You can exercise your rights at any time by sending:

- an email to the address [email protected] or to our mailing address SPRINTRADE S.r.l., with registered address at 7, Via L. Respighi - 00197 Rome.

14. Controller, processor and persons in charge

The controller of the processing is SPRINTRADE S.r.l., with registered office at 7, Via L. Respighi - 00197 Rome.

The updated list of the responsible persons and persons in charge of the processing is kept at the registered office of the data Controller.