1. Types of details collected, purposes and legal basis for the processing operations
The information technology systems and software procedures that enable the functionality of the www.savarnet.com site acquire, during their normal utilisation, certain personal details the transmission of which is implicit in the use of internet communication protocols. This category of details includes the IP addresses or domain names of the computers used to access the site, the MAC (Media Access Control) addresses, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the user’s information technology environment. These data are used for the sole purposes of compiling anonymous statistical information on the use of the site and to check its correct functionality, and are deleted immediately after processing. The data may be used to ascertain liability in the event of cybercrimes that cause damage to the site. The legal basis that legitimises the processing of personal details for this purpose is set out in the circumstances described by Article 6, section 1, letter b) of EU Regulation No. 679/2016 – i.e. to allow the user to make use of the requested service. The same details may also be used to ensure compliance with legal obligations or requests on the part of the judicial authorities. The legal basis that legitimises the processing of personal details for this purpose is set out in the circumstances described by Article 6, section 1, letter c) of EU Regulation No. 679/2016 – i.e. the extent to which the processing operations are necessary to comply with a legal obligation to which the Data Controller is subject.
Details that you supply voluntarily
Following the voluntary sending of email messages to the email addresses found on the site, Savar may process your email address (as the sender), and any additional personal details contained in the message, in order to respond, again by email, to the requests you have submitted. The legal basis that legitimises the processing of personal details for this purpose is set out in the circumstances described by Article 6, section 1, letter b) of EU Regulation No. 679/2016 – i.e. to allow the user to make use of the requested service. The same details may also be used to ensure compliance with legal obligations or requests on the part of the judicial authorities. The legal basis that legitimises the processing of personal details for this purpose is set out in the circumstances described by Article 6, section 1, letter c) of EU Regulation No. 679/2016 – i.e. the extent to which the processing operations are necessary to comply with a legal obligation to which the Data Controller is subject.
As the Data Subject, you are asked not to enter or send via the instruments provided on the site any “specific data”, “biometric data”, “genetic data”, “data on health” or “data on crimes or criminal convictions” as defined by the current legislation.
Any such details, if supplied by you, as the Data Subject, shall be immediately deleted.
2. Period of data storage
Any personal details of yours that are collected and processed as a result of you browsing the www.savarnet.com site shall be stored for the entire period of delivery of the service and shall be, in any case, deleted or rendered anonymous within 7 days. Any personal details that you send of your own volition through the instruments on the site shall be deleted after the requested service has been delivered or a response has been provided, and in any case within the maximum term of 15 days from the completion of said operations, with the exception of those details that are necessary to ensure compliance with fiscal, accounting and administrative regulations, or to comply with other legal obligations, and to document the operations carried out.
3. Methods of processing
Any personal details collected shall be processed, retained and analysed using electronic tools and shall be stored both in electronic format and in hard copy, organised into databases, and on any other appropriate type of media.
Specific security measures are implemented to prevent the loss, illegal or unfair use of the data, or unauthorised access to them.
The processing of your personal details carried out by Savar does not involve any automated decision-making processes.
4. Communication of the personal details
The communication of the browsing data is required in order to supply the requested service (browsing of the site) and is, therefore, compulsory for that purpose: failure/refusal on your part to disclose your personal details shall make it impossible for Savar to allow you to browse the www.savarnet.com site. The disclosure of your details for other purposes is optional: failure/refusal to disclose your details for said other purposes shall not have consequences for you, but may make it impossible to provide you with the requested responses.
5. Parties to which your personal details may be communicated
Any personal details of yours that have been collected shall not be disclosed indiscriminately, but may be communicated to those parties that have the right to access your personal details to ensure compliance with legal and secondary and/or EU regulations, and to the Data Controller’s own personnel, and also to companies, associations or professional firms that provide services and operations on behalf of the Data Controller, operating as Processing Managers, to ensure compliance with legal obligations, and for every other organisational and/or administrative requirement that is necessary to provide the requested services.
The names of the additional parties to which your personal details may be disclosed, operating as Processing Managers, are shown in an up-to-date list that can be requested from Savar (using the details indicated at Point 9).
6. Transfer of details outside the European Union or to international organisations
Savar shall not transfer your personal details, collected through the www.savarnet.com site and the tools contained therein, to countries situated outside the European Union or to international organisations.
7. Links to third-party sites or services
This informative statement is applicable only to the processing operations carried out on personal details through this site or the instruments set aside for that purpose by the site, but it is not applicable to other sites that you may consult through links on this site; the managers of said linked sites operate as independent Data Controllers, responsible for the relevant processing operations. You are, therefore, invited to read carefully, before accessing the services of third parties, their privacy statements.
8. Your rights as the Data Subject
In relation to the aforementioned processing operations carried out on your personal details, you are entitled to exercise at all times those rights set out by EU Regulation No. 679/2016 (GDPR), including, for example, the right to be informed as to:
- the origin of any personal data held that concerns you
- the purposes and methods of the processing operations
- the logic applied in the case of processing operations carried out using electronic instruments
- the identification of the Data Controller, the Data Managers and the designated representative.
As the Data Subject, you have the right to obtain:
- access to the data, and their updating, correction or (where in your interest) completion
- the deletion, transformation into anonymous form or blocking of access to any data processed in breach of the law
- the limitation of the processing of those details that concern you, or to request that the Data Controller or the Data Manager reduce the purposes and/or methods for/with which your details are being processed.
You can also request a copy of your details in a standard format (the so-called “Right to data portability”).
As the Data Subject, you also have the right to oppose, at any time and at no cost, wholly or partially:
- for legitimate reasons, the processing of your personal details, even if the processing operations are still relevant to the purpose for which the details were collected in the first place
- the processing of your personal details carried out pursuant to Article 6, Paragraph 1 of the GDPR, Letters e. (“processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”) or f. (“processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party”) including profiling on the basis of these provisions
- the processing of your personal details for the purposes of sending advertising or direct sales material or for the completion of market research or commercial communications (direct marketing), including any relevant profiling operations.
You have the right to withdraw your consent for the processing operations when that consent is based on the circumstances described by Article 6, Paragraph 1, Letter a. (when “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”), or by Article 9, Paragraph 2, Letter a. (when “the data subject has given explicit consent to the processing of those personal data for one or more specified purposes”) of EU Regulation No. 679/2016, at any time and without prejudice to the legitimacy of the processing operations, based on the consent granted prior to its withdrawal.
Should you consider the processing operations to have been carried out in breach of current legislation, you have the right to submit a complaint to the regulatory authority, specifically in the Member State in which you habitually reside or work, or the Member State where the alleged breach has taken place. The Italian data-protection body can be contacted using the contact details on its own website
9. Data Controller – Contact details
The Data Controller is Savar S.r.l., with its registered offices at No. 24, Via Silvio Pellico, 24040 Stezzano (Bergamo), Italy, Italian VAT Registration No. 00704960160, in the person of its pro tempore legal representative. The company can also be contacted at the following email addresses email@example.com
, the latter being the company’s “certified e-mail” address.
To exercise the rights listed above, you may submit a request to that end by writing to the following email address: firstname.lastname@example.org
Savar reserves the right to update this statement on the processing of personal details.