The purpose of this document (hereinafter referred to as "Privacy Policy") is to inform Users about personal data, understood as any information that allows the identification of a natural person (hereinafter referred to as "Personal Data"), collected by the website https://www.start-power.com/ (hereinafter referred to as "Website").
The Data Controller, as subsequently identified, may modify or simply update, in whole or in part, this Policy giving information to Users. Changes and updates will be binding as soon as they are published on the website. The User is therefore invited to read the Privacy Policy whenever accessing the website. If you do not accept the changes to the Privacy Policy, you must cease using this website and you may request the Data Controller to remove your Personal Data.


1. Personal Data collected by the website
The Data Controller collects the following types of Personal Data:

1. Content and information provided voluntarily by the User
• Contact data and contents: are those Personal Data that the User voluntarily provides to the website during its use, such as personal data, contact details, credentials for access to the services and/or products provided, personal interests and preferences and other personal content, etc.
•  Personal data collected by social media: Users may share with the website data provided to social media. The User has the right to control the Personal Data that the website can access through the privacy settings available in the social media in question. By associating accounts managed by social media with the website and authorizing the Data Controller to access such Personal Data, the User consents to the acquisition, processing and storage of such Personal Data in accordance with this Privacy Policy. Failure by the User to provide Personal Data, for which there is a legal, contractual or necessary requirement for the use of the service or for the conclusion of the contract, will make it impossible for the Data Controller to provide all or part of its services. The User who communicates to the Data Controller Personal Data of third parties is directly and exclusively responsible for their origin, collection, processing, communication or dissemination.

2. Data and content acquired automatically during the use of the website:
• Technical data: the computer systems and software procedures responsible for the operation of this website may acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of internet communication protocols. This is information that is not collected to be associated with identified Users, but by its very nature, could, through processing and association with Data held by third parties, allow you to identify Users. This category includes the IP addresses, or domain names used by users who connect to the website, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the obtained file, etc.
• Usage Data: We may also collect Personal Data relating to the User’s use of the website, such as pages visited, actions taken, features and services used.
• Geolocation data: the website may collect Personal Data on the User’s location which may be GNSS (Global Navigation Satellite System) data, in addition to data identifying the nearest repeater, Wi-Fi hotspots and Bluetooth, communicated when enabling location-based products or features.

3. Methods of processing
The processing of Personal Data is carried out by means of computer and/or telematic tools, with organizational methods and with logics strictly related to the purposes indicated. In some cases, parties involved in the Data Controller’s organization (such as personnel managers, sales people, system administrators, etc.) or external subjects may also have access to the Personal Data (such as IT companies, service providers, postal carriers, hosting providers, etc.). These subjects may, if necessary, be appointed Data Processors by the Data Controller, as well as access to the Users' Personal Data whenever necessary and will be contractually obliged to keep Personal Data confidential. The updated list of Managers can be requested by email at info@start-power.com.

4. Legal basis for processing
The processing of Personal Data relating to the User is based on the following legal bases:
- the consent given by the User for one or more specific purposes;
- the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures the processing is necessary to fulfil a legal obligation to which the Data Controller is subject
- processing is necessary for the performance of a task in the public interest or for the exercise of public authority by the Data Controller
- the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties
- the processing is necessary for the pursuit of a vital interest of the Data Controller or third parties.
However, it is always possible to ask the Data Controller to clarify the legal basis of each processing at info@start-power.com.

5. Place
Personal Data are processed at the operating offices of the Data Controller and at any other place where the parties involved in the processing are located. For further information, contact the Data Controller at the following email address info@start-power.com or at the following postal address {address}, 13876, {city}, {country}.

6. Security measures
The Processing is carried out in a manner and with appropriate tools to ensure the security and confidentiality of Personal Data, having the Data Controller adopted appropriate technical and organizational measures that guarantee, and allow to demonstrate, that the Processing is carried out in accordance with the relevant legislation.

7. Retention Period of Data
Personal Data will be stored for the period of time necessary to fulfil the purposes for which they were collected. In particular, the Personal Data will be kept for the duration of the contractual relationship, for the execution of the related and consequential obligations, for compliance with the applicable legal and regulatory obligations, and for its own or third party defence purposes. If the processing of Personal Data is based on the User’s consent, the Data Controller may retain Personal Data until the withdrawal of consent. Personal Data may be stored for a longer period if required to comply with a legal obligation or by order of an authority. All Personal Data will be deleted or stored in a form that does not allow the identification of the User within 30 days from the end of the retention period. At the end of this period, the right of access, cancellation, rectification and the right to the portability of Personal Data can no longer be exercised.

8. Automated decision-making processes
The website uses automated decision-making processes that can produce legal effects for the person or affect him significantly and that operate according to these criteria: Email Marketing, Social Media Marketing.

9. Rights of the User
Users may exercise certain rights with regard to the Personal Data processed by the Data Controller. In particular, the User has the right to:
• withdraw your consent at any time;
• object to the processing of your Personal Data;
• access your Personal Data; verify and request rectification;
• obtain the restriction of processing;
• obtain the cancellation of your Personal Data;
• receive your Personal Data or have it transferred to another data controller; lodge a complaint with the supervisory authority for the protection of Personal Data and/or take legal action. To exercise their rights, Users can address a request to the contact details of the Data Controller indicated in this document. Requests are made free of charge and processed by the Data Controller as soon as possible, in any case within 30 days.

10. Data Controller
 The Data Controller is START POWER S.r.l., with registered office in {address}, 13876, Sandigliano, {nation}, Fiscal Code 02333870026 and VAT Number 02333870026, e-mail address info@start-power.com, PEC address startpower@pec.start-power.com.

Last update: 18/02/2022

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