PRIVACY POLICY
Statement provided in accordance with Art.13 of the
ITALIAN PERSONAL DATA PROTECTION CODE (Legislative Decree no. 196 of 30 June 2003)


This is a translated version of the Privacy Policy in the English language, provided for your convenience. Please note that in the event of any conflict between the Italian language version and a translated version, the Italian language version will control.
Pursuant to the Articles 13 and 23 of Legislative Decree 196/2003 and subsequent amendments (“Personal Data Protection Code”), we inform you that Wellness & Wireless Srl (“W&W”) shall be the Data Controller of both your Personal and Sensitive Data (as defined in Art. 4) relating to supercompensation optimization service “Super-op”.
All the relevant data processing will be based on principles of fairness, legality, transparency and protection of your privacy and your rights. The individuals inside W&W who will process your data have been assigned the duty of doing so, with the obligation to follow the written instructions that we have specifically given them.
Personal Data collected during the registration process include:

  • Personal details and residence information;
  • Contact information;
  • Details on the type and frequency of sports training.

Sensitive Data collected during registration process include:

  • Height;
  • Weight;

To use the service, you have to disclose a on a daily basis some biometric data (maximum and minimum blood pressure and heart rate) and self-assessment information about the intensity and amount of sports training of your previous day, that we collect and store.

INFORMATION ON THE DATA CONTROLLER
The Data Controller is Wellness & Wireless Srl, Tax Code and VAT number 02525180358, with registered office in Reggio Emilia (Italy) at Via G. Degani 1, tel: +39 0522 924 701, email: info@wellnessandwireless.com.

DATA PROCESSING PURPOSE
The information you provide is for purposes strictly connected with and instrumental to the supply of the service. As an example and not limited to, your personal data may be disclosed to W&W employees and its legal and tax consultants, banks, shipping couriers, and – for the sole purpose of providing the service – to other companies.
The provision of personal data for such purposes is indispensable for the provision of the Service.
The personal and sensitive data gathered during the registration and during your use of the service are necessary for the assessment of your present status of predisposition to sport training, and are therefore indispensable for the provision of the Service. Sensitive data collected may be disclosed to W&W employees, consultants and specialists (e.g. doctors or trainers) and only to analyze and/or deal with problems, questions or concerns relating to the best possible support of the customer. These consultants and/or specialists shall process your data in compliance with the minimum security measures under Annex B to the Data Protection Code.
The use of your personal data for promotional, advertising and marketing purposes, and for statistical analysis aimed at determining the level of customer satisfaction will only happen subject to your consent. Always only subject to your consent, your personal data may also be communicated to other companies, which may use them for the same reasons mentioned above.

DATA PROCESSING METODOLOGYData processing will be carried out through the use of tools and procedures that guarantee data security and confidentiality. The personnel will use only the tools specifically designated for the purpose. The staff responsible for the administrative and organizational management of W&W may have the need to access the stored the data; they have been given specific guidelines about that, and instructed to maintain secrecy.

PLACE OF DATA STORAGE
Your data collected during the registration process and service delivery are archived and stored on servers owned by Aruba Spa through their “Cloud Hosting” service; currently these servers are located in Arezzo, Italy.
In this regard, W&W has signed a contract with Aruba Spa, which under its sole responsibility has adopted and continuously updates all security measures imposed by the Data Protection Code to ensure the security and confidentiality of stored data.
Therefore, by accepting this Privacy Policy, and by giving consent to the processing of data, you explicitly authorize W&W to use these servers for the acquisition and data retention purposes described above.

NATURE OF THE CONFERRING OF PERSONAL DATA AND THE CONSEQUENCES OF A REFUSAL TO REPLY
The consent to the processing of data is voluntary and free. However, pursuant to the Article 23 of Legislative Decree 196/2003, “… Processing of personal data by private entities or profit-seeking public bodies shall only be allowed if the data subject gives his/her express consent… The data subject’s consent shall only be deemed to be effective if it is given freely and specifically with regard to a clearly identified processing operation, if it is documented in writing, and if the data subject has been provided with the information referred to in Section 13. Consent shall be given in writing if the processing concerns sensitive data… “. Therefore, for the above reasons, W&W can deliver its services if and only if consent to data processing is given. Consent to the processing of your data will be asked during the registration process; please be informed that failure to provide the required data and consent will prevent the delivery of the service.

COMMUNICATION AND DISSEMINATION
Personal data and, where strictly necessary, also sensitive data may be disclosed by W&W in respect of the law and of your will, to the following subjects:
– Specialist Advisers who collaborate with W&W to provide the service;
– Individuals who need to access data for purposes ancillary to the relationship between the Customer and W&W, to the extent necessary to carry out auxiliary tasks or the provision of goods and services (example: IT support);
– Public and privatesubjects, that can access the data in accordance with provisions of law, within the limits set by these rules (e.g. police authorities, judicial authorities);
– Our consultants (e.g. law and accounting firms), to the extent necessary to carry out their duties
The possibility of disclosure of personal data and, where strictly necessary, also sensitive data to the subjects listed above is necessary to provide the service, and therefore W&W can deliver its services if and only if consent to data disclosure is given.
Neither personal nor sensitive data may be publicly disseminated.

INFORMATION ABOUT DATA PROCESSORS
The Data Controller has appointed Data Processors.An updated Data Processor name list, as well as an updated list of people that can access the data,are kept at the company’s headquarters in Via G.Degani 1, 42124 Reggio Emilia.

DATA SUBJECT’S RIGHTS
Please also note that at all time, by an informal request to the Data Controller or Processor, you can exercise your rights under Section 7 Legislative Decree. n. 196/2003 as amended, which for your convenience you can read hereafter.

Section 7
(Right to Access Personal Data and Other Rights)

  1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
  2. A data subject shall have the right to be informed
    a) of the source of the personal data;
    b) of the purposes and methods of the processing;
    c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
    d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
    e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
  3. A data subject shall have the right to obtain
    a) updating, rectification or, where interested therein, integration of the data;
    b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
    c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
  4. A data subject shall have the right to object, in whole or in part,
    a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
    b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

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