Section 1 – Data Protection Policy

In order to properly comply with the provisions of the law, pursuant to Art. 13 of the General Data Protection Regulation – Regulation (EU) 2016/679 (hereinafter also referred to as GDPR) we would like to inform you, as the User/Interested party, about our data collection and its use.

Data Controller

The Data Controller is Hubrise S.r.l., which is responsible for the correct processing of your personal data (hereinafter also referred to as “Data Controller” or “Hubrise”).
You may contact the Controller for any information or requests at the following addresses:

• Registered office: Via Adua n. 33, 13855 Valdengo (BI) – Italia
• E-mail: info@hubrise.it
• PEC (Certified Electronic e-mail): getaline@legalmail.it

Data Protection Officer

The Data Controller has appointed its own Data Protection Officer (hereinafter also referred to as “DPO”), who can be contacted at dpo@bonprixitalia.it or by writing to the postal address via Adua n. 33, 13855 Valdengo (BI) – Italy.

Purpose of processing, types of data processed, legal basis and data retention period

The personal data processed by Hubrise are either provided directly by the User/Interested party or collected automatically via the website www.hubrise.it.

1. I) The data processed by Hubrise and provided directly by the User/Interested party within the site are:
   a. Personal data spontaneously provided by the User/Interested party within the site through the contact form.
   The provision of data marked with an asterisk (*) within the contact form (such as: name, surname, e-mail address, etc.) is mandatory and in the event of failure to do so it will not be possible to forward your requests. These data will be processed in compliance with the guarantees of confidentiality and the security measures provided for by the regulations in force, also with the aid of electronic instruments directly and/or through third parties, for the purpose of processing contact requests and for the execution of pre-contractual measures ex art. 6, par. 1, lett. b) of the GDPR. Personal data will not be retained beyond the time strictly necessary to fulfil these purposes and in any case not beyond the legal retention period envisaged by law (10 years from collection).
   b. Personal data spontaneously provided by the User/Interested party within the site via the Newsletter subscription form.
   Should the User/Interested party wish to receive the Hubrise newsletter, by filling in the appropriate subscription form, the provision of the e-mail address is compulsory and in the event of failure to do so it will not be possible to proceed with subscription. This data will be processed in compliance with the guarantees of confidentiality and security measures provided for by current legislation, including with the aid of electronic instruments directly and/or through third parties, for marketing purposes. The legal basis for the processing is the consent of the User/Interested party pursuant to Art. 6, par. 1., lett. a) of the GDPR. Personal data will be stored until the User/Interested party withdraws his/her consent. The revocation of consent can be done at any time via the appropriate link at the bottom of each newsletter or by writing to privacy@hubrise.it.
2. The data relating to the User/Interested party collected automatically by the Hubrise website during navigation are:
   all information automatically collected through the website, also by third party applications integrated in the website, including, for example, IP addresses or domain names of the computers used by the User/Interested party connecting with this website, URI/URL (Uniform Resource Identifier/Locator) notation addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server response (successful, error, etc.), the country of origin, the navigation language chosen, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User/Interested party’s IT environment.

Further information on the data automatically collected through the website and the period of retention of these data is provided in the Cookie Policy available in Section 2 below.

Information on the processing of personal data carried out through the social media platforms used by the Data Controller

Hubrise is present on Social Media platforms, which can also be reached via hypertext links published on the website. Regarding the processing of personal data carried out by the Social Media platforms used by Hubrise, please refer to the information provided by these through their respective privacy policies. Hubrise processes the personal data provided by the User/Interested party via the pages of the Social Media platforms solely for the purpose of managing interactions with users (comments, public posts, etc.) and to process contact requests from the User/Interested party in compliance with the regulations in force.

Data recipients

personal data shall be processed exclusively by authorised personnel and may come to the attention of parties expressly appointed as Data Processors by Hubrise for the performance of certain services (e.g. consultants and/or companies that assist the Data Controller in terms of information technology and management of communication networks; companies providing marketing services; etc.). The updated list of Data Processors is always available at the Data Controller’s head office.

Transfer of data abroad

data provided directly by the User/Interested party and/or collected automatically through this website, may be transferred to a country other than the one in which the User/Interested party is located, including outside the European Economic Area. In this case, Hubrise ensures that the processing of said personal data is carried out in compliance with European Regulation 679/2016, in accordance with the principles set out in Article 45 of the GDPR (existence of an adequacy decision by the European Commission) or, in the absence of such a decision, in compliance with Article 46 of the GDPR relating to transfer in the presence of adequate safeguards or in compliance with Article 49 of the GDPR.

Rights of data subjects

the User/Interested party has the right to obtain from the Data Controller:

a) access to one’s own personal data (Art. 15 GDPR), i.e. confirmation as to whether or not one’s personal data are being processed;

b) rectification of inaccurate personal data or supplementation of incomplete personal data (Art. 16 of the GDPR);

c) the deletion of personal data under the conditions set out in Article 17 of the GDPR;

d) the restriction of the processing of data under the conditions set out in Article 18 of the GDPR;

e) the portability of one’s own personal data in a structured, commonly used and machine-readable format (Art. 20 of the GDPR).

Furthermore, the User/Interested party has the possibility to exercise the right to object, on legitimate grounds, to the processing of his/her personal data (Art. 21 EU Regulation). In particular, the User/Interested party has the right to object to the processing of one’s own personal data carried out for direct marketing purposes, including profiling related to this.

The aforementioned rights may be exercised at any time by sending a request to privacy@hubrise.it

In the event of a breach of the law by the Data Controller, the User/Interested party also has the right to lodge a complaint with the Italian authority (Garante per la Protezione dei Dati Personali), as the authority responsible for monitoring processing in the Italian State.

Section 2 – Cookie Policy

What are cookies?

Cookies are small text strings that the sites visited by the user send to his terminal (usually to the browser), where they are stored and then retransmitted to the same sites the next time the same user visits. While browsing a site, the user may also receive cookies on his terminal equipment that are sent by different sites or web servers (so-called “third parties”), on which some elements (e.g. images, maps, sounds, specific links to pages of other domains) present on the site he is visiting may reside.

Cookies may remain in the system for the duration of a session (i.e. until the browser that the user is using for surfing is closed) or for long periods and may contain a unique identification code.

What are cookies used for?

Some cookies are used to perform computer authentication, session tracking and store specific information about users accessing a web page.
These cookies, so-called technical cookies, are often useful because they can make surfing and using the web faster and quicker, for instance they intervene when a website automatically recognises the language usually used by the user.

A particular type of cookie, called analytical cookies, is used by website operators to collect information on the number of users and how they visit the site in order to compile general statistics on the service and its use.

Other cookies may instead be used to monitor and profile users while they are browsing, studying their movements and website consultation habits, also for the purpose of sending targeted and personalised service advertisements (so-called profiling cookies). This happens because those web spaces are designed to recognise the PC or other device used by users to connect to the web (e.g. smartphone/tablet), and possibly address “profiled” promotional messages to them based on their searches and use of the Internet.

It can also happen that a web page contains cookies coming from other sites and contained in various elements hosted on the page itself (such as advertising banners, images, videos, etc.), such cookies are so-called third-party cookies, which are usually used for profiling purposes. Thus, the cookies that the user downloads onto his or her PC, smartphone and tablet can also be read by other parties, other than those who manage the website visited.

Use of cookies while surfing www.hubrise.it

In its management of cookies, the hubrise.it website complies with provision no. 231/2021 of the Garante per la protezione dei dati personali “Linee Guida cookies e altri strumenti di tracciamento”.

The legislation on cookies stipulates that only technical cookies and analytical cookies, which are equated with technical cookies under certain conditions set out in the legislation, can be stored on the users’ device, without the need for his or her consent. For all other types of cookies, users’ consent is required.

You can always set your browser so that it does not store cookies, but deactivating them may affect your experience of using and navigating the website in the case of technical cookies necessary for the website to function. It is necessary to follow the steps indicated by the browser used to deactivate cookies directly from the same.

The www.hubrise.it website uses only technical cookies that make navigation and use of the site faster and safer and facilitate certain procedures (e.g. automatic recognition of the language usually used by the User/Interested party while browsing).

Below is a list of the cookies used on this site and their relative duration: