The protection of your privacy is of great importance to us. sobu Ltd therefore carries out its activities in compliance with the applicable statutory regulations for data protection. In this document, we will explain what information we collect and how and for what purpose we use it.
1. Types of Data collected
2. Mode and place of processing the Data
3. The purposes of processing
4. Facebook permissions asked by sobu Ltd
5. Detailed information on the processing of Personal Data
6. Further information about Personal Data
7. The rights of Users
8. Additional information about Data collection and processing
9. Owner and Data Controller
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of sobu Ltd (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
The Owner may process Personal Data relating to Users if one of the following applies:
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of
Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Access to third-party accounts, Data transfer outside the EU, Heat mapping and session recording, Hosting and backend infrastructure, Managing contacts and sending messages, Registration and authentication, SPAM protection and Analytics.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
sobu Ltd may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it. This service allows sobu Ltd to connect with the User’s account on the Facebook social network, provided by Facebook Inc.
The permissions asked are the following:
Personal Data is collected for the following purposes and using the following services:
Access to third-party accounts
This type of service allows sobu Ltd to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically but require explicit authorization by the User.
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyse web traffic and keep track of User behaviour. Some of these services may record sessions and make them available for later visual playback.
This type of service has the purpose of hosting Data and files that enable sobu Ltd to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of sobu Ltd. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
This type of service allows interaction with social networks or other external platforms directly from the pages of sobu Ltd. The interaction and information obtained through sobu Ltd. are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
By registering or authenticating, Users allow sobu Ltd to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, sobu Ltd will be able to access some Data, stored by these third-party services, for registration or identification purposes.
This type of service analyses the traffic of sobu Ltd, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
sobu Ltd may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.
sobu Ltd may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users’ preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of sobu Ltd or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
For operation and maintenance purposes, sobu Ltd and any third-party services may collect files that record interaction with sobu Ltd (System logs) use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
sobu Ltd does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.
Personal Data (or Data) – Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data – Information collected automatically through sobu Ltd (or third-party services employed in sobu Ltd), which can include: the IP addresses or domain names of the computers utilized by the Users who use sobu Ltd, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User – The individual using sobu Ltd who, unless otherwise specified, coincides with the Data Subject.
Data Subject – The natural person to whom the Personal Data refers.
Data Controller (or Owner) – The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of sobu Ltd. The Data Controller, unless otherwise specified, is the Owner of sobu Ltd.
sobu Ltd (or this Application) – The means by which the Personal Data of the User is collected and processed.
Service – The service provided by sobu Ltd as described in the relative terms (if available) and on this site/application.
European Union (or EU) – Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies – Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
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