OUR POLICY CONCERNING THE CORPORATE PRIVACY

This privacy policy explains how our company uses the personal data which are provided to us directly. The
following information are only available for the https://www.systemgroupmarine.com/it/ site and not for
third-party websites accessible through hyperlinks included inside the Website.

WHO IS THE OWNER OF THE PERSONAL DATA PROCESSING?

The owner of the processing is FUTURA S.P.A. placed in Belforte all’Isauro (PU), Via Mattei, N. 15, e-mail:
futura@tubi.net . The company is part of the group called “System Group”.

WHICH ARE THE PERSONAL DATA WE COLLECT?

When we talk about “personal data”, we refer to the subject data that fill out specific forms (ex.
registration to the website or to an event/webinar), or visit the website.

Personal data includes name, e-mail address, telephone number, the company, the address, the place,
postcode, the district and other information that are inside the message.

We process data that are provided intentionally by the user, through filling forms placed in some sections
of the Website or through the sending of messages to e-mail addresses you can find in the Website, in
order to provide services offered through the Website.

IT systems and software processes in charge of the website collect (during a normal service) some personal
data that are transmitted automatically by using the Internet communication protocols. This data category
might include: IP addresses or domain names of computers and devices used by users, URI/URL addresses
(Uniform Resource identifier/Locator) of requested resources, request hour, method used for making the
request to the server, file dimension obtained as response, numeric code that shows the status of the
response gave by the server (successful, error, etc.), and other parameters related to the operating system
and the user computing environment. For further information please refer to the cookies policy of this
website.

HOW AND WHY WE USE YOUR PERSONAL DATA?

Personal data provided by the user will be processed for the following purposes:
A. To allow the website navigation.

In this case, data processing is essential in order to achieve the legitimate interest of the
processing’s owner, but at some conditions: the interests or rights and the fundamental freedom of
the subject that require personal data protection, do not have to overcome. Reasonable
expectations of the subject have to be taken into account because they are based on his/her
relationship with the processing owner.

In this case the processing of your personal data is necessary in order to execute an agreement.
B. Answer to your requests and manage them in order to answer to your requests of information,
quotation, or requests concerning information, quotation or any type of request inside the
message. One of our coordinator will contact you in order to encounter the requests or arrange a
meeting.

In these situations, processing of your personal data is essential in order to carry out precontractual measures.

C. Update service through sending of communications on services and products similar to those
already purchased, at the e-mail box you provided us when you registered to our services.
You can always decide to refuse data processing for this purpose by exercising the rights through
communications received by e-mail, by showing processing unsubscription or objection to the
processing, or by using the functionality for unsubscription on every communication.
In this case our legitimate interest is to send you those communications (known as soft spam), as
required by GDPR n. 47.

D. Newsletter subscription in order to send you regular informative communications through e-mail.

E. Marketing.

E.1 In order to keep you update on news and commercial offers concerning our products, services
and third-parties, to conduct market researches or other type of commercial activities and
customer satisfaction both through communication channels (like phone call from an operator) and
through automatic communication tools like e-mails, chats, messages (like SMS and other types of
instant messaging) and other tools of remote communication.

E.2 In order to share your personal data with other companies of the group and/or trading partners
belonging to our sales network, for the sending of marketing communications and other type of
commercial activities like those specified in E.1.
Processing of your data for newsletter subscription and marketing purposes is not imperative. In
these cases your data could be processed only after your explicit permission (entirely optional),
revocable at any time without consequences.

HOW LONG DO WE KEEP YOUR DATA?

Processed data will be kept for a limited period of time. At the end of this period, data will be deleted or
made anonymous. Storage period is different depending on processing purposes, in particular:
• Personal data processed for allowing the web browsing are kept up to the end of the browsing
session. For further information please take a look at the cookie policy of this website;
• Concerning the sending of communications for services or products similar to those already
purchased, data will be kept for 24 months starting from the last contact or the last feedback
received regarding the contacts maintained. In any case, data will be kept until the unsubscription
to the service;
• Those data provided through the messages sent by e-mail or obtained through the filling of the
contact forms that are on the website will be kept for the time required to provide an answer;
• Concerning the marketing and the newsletter, your data will be processed until the unsubscription
to the service or for a period of time not exceeding 24 months starting from the date the
agreement is provided which means renewed.

PROCESSING METHOD

Personal data are processed with automatic tools for a period of time that is required for achieving the
purposes the data have been collected for. Specific safety measures have been put in place in order to
prevent the data loss, illegal or incorrect use and non-authorized access.

TO WHOM YOUR DATA ARE DISCLOSED?

Your personal data are disclosed to:

– Collaborators and employees specifically authorised and trained by the Owner as part of his/her
specific skills and tasks;
– Providers of services offered through the Website or connected to its functioning that act in the
role of processing managers (ex. hosting and newsletter web service);
– HB Servizi S.r.L. as processing manager, in order to accomplish services of secretary, marketing and
communication with particular attention to answer requests coming from users, the organization
and development of marketing activities and campaigns;
– Third-party companies or consultants in charge of installation, maintenance, updates and, in
general, management of website’s hardware and software;
– Other companies of the group and/or trading partners belonging to our sales network (only if you
give us your permission) in order to send newsletters, marketing communications and other
commercial activities (like those mentioned in the F letter).
Other than the above cases, the personal data will not be communicated, spread, gave or transferred to
third-parties for illicit purposes or not connected to the above aims. In any case, the personal data will not
be released without giving the appropriate policy to the subjects and without having their permission, if
requested by the Law.
It is without prejudice the possible data communication upon request of the Judicial Authority or Public
Safety, following the methods and cases required by the law.

TRANSFER OF YOUR DATA IN THIRD-PARTIES COUNTRIES

Your personal data could be transfer abroad, even in extra EU countries, only after the verification of
standard contractual terms approved by European Commission (GDPR art. 46), or binding rules for the
company (GDPR art. 47), or, without the previous terms and rules, on the basis of one of the exemption
measures according to GDPR art. 49.

YOUR RIGHTS REGARDING DATA PROTECTION

Our company wants to be sure you are entirely aware of all your rights regarding data protection. Every
single user has the following rights:
Access right – You have the right to ask our company for copies of your personal data. We could charge you
a small fee for this service.
Rectification right – You have the right to ask our company to correct every information you consider
inaccurate. You also have the right to ask our company to complete the information you consider
incomplete.

Cancellation right – you have the right to ask our company to delete your personal data.
Processing restriction right – you have the right to ask our company to restrict the processing of your
personal data in accordance with the hypothesis specified in GDPR art. 18.
Right to oppose to the processing – you have the right to oppose to the processing of your personal data
from our company for marketing and profiling purposes.
Data portability right – you have the right to ask our company to transfer the data we collected to another
company or directly to you, in accordance with the hypothesis referenced by the GDPR art. 20.
If you make a request we can respond to you within one month. If you would like to exercise one of these
rights, we kindly ask you to contact us at the following e-mail privacy.systemgroup@tubi.net.

HOW CAN YOU GET IN TOUCH WITH US?

If you have any question concerning our privacy policy, the personal data we keep or if you like to exercise
one of your data protection rights, please contact us.
Write at the following e-mail privacy.systemgroup@tubi.net

HOW CAN YOU CONTACT THE RELEVANT AUTHORITY?

If you would like to refer a complaint or if you think that our company has not addressed your worry in a
satisfactory way, you can get in touch with the Supervisor Office by following the directions in the link
down below.
https://www.garanteprivacy.it/home/docweb/-/docweb-display/docweb/4535524

CHANGES IN OUR PRIVACY POLICY

Our company keeps under review your privacy policy and adds improvements on this website.