Privacy Policy

In accordance with Art. 13 of GDPR EU 2016/679, Sovil Srl. (hereinafter referred to as Sovil) as Data Controller, with registered office in Via Crescenzio, 82 00193 Rome, informs you about the use of your personal data, as a Data Subject, and your rights (Art. 7 of Legislative Decree 196/2003 and Art. 15 of GDPR EU 2016/679).

Personal Data that may be processed

Sovil may process the following Personal Data:

• Personal Data: name, address, other contact details (e.g., email address and telephone number), gender, marital status, date and place of birth.
• Sensitive Personal Data: health data.
• Identification Details: identification numbers issued by government agencies or entities (for example, depending on the data subject's country of residence, passport number, identity card number, tax code, driver's license number).
• Financial Information: payment card number, account number, and bank details.
• Marketing Data: information regarding the data subject's expressed or denied consent to receive marketing communications from the controller.

Purposes of Processing.

Personal Data is processed for:

Purposes of providing analysis and rehabilitation services:

• entering into contracts for products sold by the Controller, such as lighting equipment and systems;
• fulfilling pre-contractual, contractual, and tax obligations arising from existing relationships;
• complying with obligations provided by law, regulations, EU legislation, or an order from the Authority;
• exercising the Controller's rights, such as the right of defense in court.

Direct Marketing purposes with the specific consent of the Data Subject:

• sending commercial communications and/or advertising material via email, post and/or SMS and/or telephone contacts, push notifications, about products or services offered by the Controller, including remotely, through registration and access to the customer reserved area on the Sovil website;
• sending commercial and/or promotional communications from Sovil via email, post and/or SMS and/or telephone contacts.

Sources of Personal Data

Sovil collects Personal Data directly from data subjects, taking care to inform them about the necessity of obtaining such information and the consequences that may arise from the decision not to provide it in the appropriate form.

Processing Methods

Sovil processes Personal Data to the extent necessary to achieve the purposes identified in this privacy policy or within the limits permitted by law.

Period of Retention of Personal Data

Sovil will process personal data for the time necessary to fulfill the aforementioned purposes, and in any case, for no longer than 10 years from the termination of the relationship for service purposes and for no longer than 2 years from data collection for marketing purposes, and, in any case, in accordance with the rules of the relevant supervisory authority.

Recipients / Categories of Recipients of Personal Data

Personal data may be made accessible for the purposes of this policy to:

• employees and collaborators of Sovil in their capacity as authorized persons and/or internal data processors. The updated list of Data Processors and Authorized Persons is kept at Sovil's registered office.
• third-party companies or other entities (e.g., system administrators, professional firms, consultants, insurance companies for the provision of services rendered, experts, lawyers, etc.) who carry out outsourcing activities on behalf of Sovil, in their capacity as external data processors.
• other subjects to whom the communication of data is mandatory by law, such as: ASL (Local Health Authority), Agenzia delle Entrate (Italian Revenue Agency), Magistratura (Judiciary), Law Enforcement.

Automated Profiling

Sovil, through the management of information acquired during the provision of services, can acquire from the Client the necessary information to evaluate their needs, in accordance with current legal provisions. The use of acquired information and Clients' Personal Data can be used for their profiling, subject to the informed consent of the Data Subjects. Currently, the structure does not perform customer profiling.

Security Measures

Sovil adopts electronic and procedural security measures adequate to the sensitivity of the information in its possession. Security measures include the installation of firewalls to protect and ensure the protection of Personal Data. Access to data is limited to personnel and third parties who need to access it for appropriate and legitimate purposes complementary to the activity. Any possibility of external access is excluded. A copy of the security protocols implemented for Cybersecurity is available at the operational headquarters.

Transfer of Personal Data to recipients located in Third Countries

Personal data is stored on servers located within the European Union. In any case, it is understood that Sovil, if necessary, will have the right to move servers even outside the EU. In this case, Sovil guarantees from now on that the transfer of data outside the EU will take place in accordance with applicable legal provisions, subject to the signing of the standard contractual clauses provided by the European Commission.

Data Subject Rights

The data subject has the rights set forth in Art. 7 of the Privacy Code and Art. 15 of the GDPR, namely the rights to:

• obtain confirmation of the existence or non-existence of personal data concerning them, even if not yet registered, and their communication in intelligible form;
• obtain information on: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in case of processing carried out with the aid of electronic instruments; d) the identification details of the controller, processors, and the designated representative pursuant to Art. 5, paragraph 2 of the Privacy Code and Art. 3, paragraph 1 of the GDPR; e) the entities or categories of entities to whom the personal data may be communicated or who may become aware of it as designated representatives in the State territory, as processors or persons in charge of processing;
• obtain: a) the update, rectification or, when interested, the integration of the data; b) the erasure, anonymization, or blocking of data processed in violation of the law, including those whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; the certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where such fulfillment proves impossible or involves a manifestly disproportionate use of means compared to the protected right;
• object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning them for the purpose of sending advertising material or commercial communication, through the use of email and/or traditional marketing methods via telephone and/or paper mail.

Where applicable, you also have the rights under Articles 16-21 of the GDPR (Right to rectification, right to erasure ('right to be forgotten'), right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Garante per la Protezione dei Dati Personali (Italian Data Protection Authority) (Public Relations Office, Piazza di Montecitorio n. 121 – 00186 Rome Telephone: (+39) 06.69677.2917 Email: urp@gpdp.it).

Sovil strives to ensure that Personal Data is always accurate, complete, and up-to-date. Data Subjects can contact us at servizioclienti@sovil.com or by calling 0761 749830 to update their personal information.

Questions - Requests – Complaints

For any questions or requests regarding this privacy policy, you can write to the following address:
Sovil S.r.l.

Strada Statale n° 204 Ortana - Loc. Sanguetta
01038 Soriano nel Cimino (Viterbo)

Tel. (+39) 0761 759303
servizioclienti@sovil.com