Privacy Information Notice

Sapio Produzione Idrogeno Ossigeno S.r.l., Tax Code no. 08804430158 and VAT no. 10803700151, with registered office at Via S. Maurilio 13, Milan (“Sapio”), is constantly committed to protecting the online privacy of the users of its website http://www.grupposapio.it/ (hereinafter, the “Website”). This document (the “Information Notice”) was drafted in order to allow you to understand how your Personal Data, as defined below, will be processed in the context of the use of the Website.

In general, any information or Personal Data that you provide to Sapio through the Website, or that is otherwise collected through the Website, in the context of the use of the services offered by Sapio (the “Services”), as defined in detail in Section 3 below, will be processed according to the internationally recognized principles of lawfulness, fairness, transparency, limitations of purpose and retention, data minimization, accuracy, integrity and confidentiality.

CONTENTS

  1. Data Controller and Data Protection Officer
  2. Personal Data subject to processing
    1. Browsing data
    2. Cookies
  3. Purpose of the processing
  4. Legal basis and whether the data processing is mandatory or optional
  5. Recipients of Personal Data
  6. Transfer of Personal Data
  7. Retention of Personal Data
  8. Rights of the Data Subject
  9. Amendments

 

  1. Data Controller and Data Protection Officer

Sapio, as identified at the beginning of the Information Notice, is the Data Controller for all Personal Data processed through the Website.

You can contact Sapio’s Data Protection Officer (“DPO”) at the following address: dpo@sapio.it

  1. Personal data subject to processing

We inform you that after you have browsed the Website, Sapio will process your Personal Data, which may consist of an online identifier or browsing preferences, i.e. information on how you use the Website, such as to identify you or make you identifiable (hereinafter simply “Personal Data”).

Your Personal Data may be collected simply by analysing your behaviour on the Website.

The Personal Data processed through the Website are as follows:

  1. Browsing data

The computer systems and software procedures used to operate this Website acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of internet communication protocols. This information is not collected in order to be associated with identified people, but it could, by its nature, allow the users to be identified through processing and associations with data held by third parties. This category of data includes IP addresses or domain names of computers used by persons who connect to the Website, the URI (Uniform Resource Identifiers) of requested resources, the time of request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding the operating system and computer environment of the user. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct operation, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain liability in the event of hypothetical computer crimes against the website or third parties: except for this possibility, the data on web contacts do not remain for more than seven days.

  1. Cookies

Definitions, characteristics and application of legislation

Cookies are small text files that the websites visited by the user send and record on their computer or mobile device, to be then re-transmitted to the same sites on the next visit. Thanks to cookies, a website remembers the user’s actions and preferences (such as, for example, login data, chosen language, font size, other display settings, etc.) so that they do not have to be reset when the user visits the website again or hops from one page of it to another. Cookies, then, are used to perform computer authentication, session monitoring and storage of information regarding the activities of users who access a website and may also contain a unique identification code that makes it possible to keep track of the user’s navigation within the website itself, for statistical or advertising purposes. While browsing a website, the user may also receive on their computer cookies from websites or web servers other than the one they are visiting (so-called “third party” cookies).

Some operations could not be performed without the use of cookies, which in some cases are therefore technically necessary for the website to function.

There are various types of cookies, depending on their characteristics and functions, and these may remain on the user’s computer for different periods of time, such as session cookies, which are automatically deleted when the browser is closed, and so-called persistent cookies, which remain on the user’s device until a pre-established expiration date.

Under applicable legislation, the user’s express consent is not always required for the use of cookies. In particular, “technical cookies”, i.e. those used for the sole purpose of transmitting a communication over an electronic communications network, or used to the extent strictly necessary to provide a service explicitly requested by the user, do not usually require such consent. In other words, these are cookies that are essential for the functioning of the website or necessary to perform activities requested by the user.

For “profiling cookies”, meanwhile — those aimed at creating user profiles and used for the purposes of sending advertising messages in line with the preferences expressed by the user in the context of surfing the net —, users’ prior consent is usually required under applicable legislation.

Types of cookies used by the Website and (de-)selection options

The Website uses the following cookies:

  • Technical navigation or session cookies, strictly necessary for the functioning of the Website or to allow you to take advantage of the content and services requested.
  • Functionality cookies, which are used to activate specific functions of the Website and a series of selected criteria (for example, language) in order to improve the service provided.
  • Anonymized analytical cookies, which allow users to understand how the Website is used. These cookies do not collect information about your identity or any Personal Data. The information is treated in an aggregate and anonymous form.

– Cookies on the Website

In detail, the proprietary cookies sent by Sapio through the Website are specified below:

 

Type of cookie and ownerTechnical name of cookiesOperation and purposeCookies and duration
POLYLANG

·       First party cookie

 

pll_languageAllows the Polylang plugin to record the language of the last page visited1 year
GOOGLE

·       Third party cookie

Technical

_gatAllows Google to throttle requests1 minute
GOOGLE

·       Third party cookie

Technical

caosLocalGaAnonymized Google Analytics cookie30 Days
GOOGLE

·       Third party cookie

Technical

caosLocalGa_gidAnonymized Google Analytics cookie24 hours

 

Cookie settings

Cookie settings

You can block or delete (in whole or in part) technical and functional cookies by means of the specific functions of your browser. However, we inform you that failing to authorize technical cookies could make it impossible to use the Website, view its contents and use the related services. Inhibiting functionality cookies could mean that some services or certain functions of the Website are not available or do not work properly, and you may be forced to modify or manually enter some information or preferences each time you visit the Website.

The choices made in relation to the Website’s cookies will in turn be recorded in a specific cookie. This cookie may, however, in some circumstances not work properly: in such cases, we recommend that you delete unwanted cookies and inhibit their use by means of the settings available in your browsers.

Your cookie preferences will be reset if you use different devices or browsers to access the Website.

How to view and modify cookies through the browser

You can authorize, block, or delete cookies (entirely or in part) by means of the specific functions of your browser. For more information on how to set cookie preferences through the browser, refer to the relevant instructions:

You can also manage your choices regarding third-party cookies using online platforms such as AdChoice.

ATTENTION: by disabling technical and/or functional cookies, the Website may not be usable, or some services or certain functions of the Website may not be available or may not work properly, and you may be forced to modify or manually enter some information or preferences each time you visit the Website.

  1. Purpose of the processing

Sapio will use your Personal Data, collected through the Website, for the following purposes:

  • to provide those Services that make it possible to browse the Website (“Provision of the Service”)
  • to fulfil legal obligations that require Sapio to collect and/or further process certain types of Personal Data (“Compliance”)
  • to prevent or identify any abuse in the use of the Website, or any fraudulent activity, and therefore allow Sapio to protect itself in court (“Abuse/Fraud”).
  1. Legal basis and whether the data processing is mandatory or optional

The legal basis for the processing of your Personal Data by Sapio, according to the purposes indicated in Section 3 above, are as follows:

  • Provision of the Service: processing for this purpose is necessary in order to provide you with the Services and, therefore, for performance of the contract entered into with you. Your Personal Data will be acquired automatically during normal browsing of the Website, as their transmission is implicit in the use of Internet communication protocols. If you wish Sapio not to process your Personal Data, please do not access or browse the Website.
  • Compliance: processing for this purpose is necessary for Sapio in order to fulfil possible legal obligations. When you provide Personal Data to Sapio, they shall be treated according to applicable legislation; this could involve their conservation and communication to the Authorities for accounting, tax or other obligations.
  • Abuse/Fraud: the information collected for this purpose will be used exclusively to prevent and/or identify any fraudulent activity or abuse in the use of the Website and therefore allows Sapio to protect itself in court.
  1. Recipients of Personal Data

Your Personal Data may be shared with the parties listed below (the “Recipients”):

  • subjects who typically act as data processors, namely: people, companies or professional firms that provide assistance and consultancy to Sapio in accounting, administrative, legal, tax, financial and credit recovery matters relating to the provision of the Services
  • subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers)
  • subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks)
  • persons authorized by Sapio to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. Sapio employees)
  • Sapio Group companies, for internal administrative purposes
  • subjects, bodies or authorities to whom it is mandatory to communicate your Personal Data for Compliance, Abuse or Fraud purposes, or by order of the authorities.
  1. Transfer of Personal Data

Some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. Sapio ensures that the processing of your Personal Data by these Recipients takes place in compliance with the applicable legislation. Transfers are in fact performed on the basis of suitable guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate. For further information, please write to dpo@sapio.it

  1. Retention of Personal Data

The Personal Data processed for the purpose of Providing the Services will be kept by Sapio for the time strictly necessary for the aforementioned purpose (e.g. to allow you to browse the Website). In any case, since such Personal Data are processed to provide you with the Services, Sapio may retain them for a longer period, in particular to the extent that this may be necessary in order to protect Sapio’s interests from possible complaints relating to the Services.

Personal Data processed for Compliance purposes will be kept by Sapio for the period required by specific legal obligations or by applicable legislation.

The Personal Data processed in order to prevent Abuse/Fraud will be kept by Sapio for the time strictly necessary for the aforementioned purpose and therefore for as long as Sapio is required to keep them to protect itself in court and to communicate said data to the competent Authorities.

  1. Rights of the Data Subject

You are entitled to ask Sapio at any time for:

  • access to your Personal Data, (or a copy of such Personal Data), as well as further information on the processing being carried out on them
  • the correction or updating of your Personal Data processed by Sapio, where they are incomplete or out of date
  • the deletion of your Personal Data from Sapio databases
  • the limitation of the processing of your Personal Data by Sapio
  • a copy of the Personal Data concerning you in a structured, commonly used and machine-readable format.

You may exercise your rights by writing to Sapio at the following address: gdpr@sapio.it.

In any case, you are always entitled to lodge a complaint with the competent Supervisory Authority if you believe that the processing of your Personal Data is contrary to legislation in force.

  1. Amendments

This privacy policy is effective from 27/10/2021 . Sapio reserves the right to amend or simply update its content, in part or completely, also due to changes in the applicable legislation. Sapio will inform you of such amendments as soon as they are introduced, and they will be binding as soon as they are published on the Website. Sapio therefore advises you to visit this section regularly, to ensure that you are aware of the most recent and updated version of the privacy policy, and may keep up to date with information on the data collected by Sapio and the use made of them by the latter.