To obtain information about the personal data collected, the purposes and the parties with whom the data is shared, contact the Owner.

Owner’s email address: info@subba.eu

The Owner does not provide a list of Personal Data types collected.

Complete details on each type of Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its Service. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Data is mandatory are encouraged to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

The User assumes responsibility for any third-party Personal Data obtained, published or shared through this Application and warrants that they have the right to communicate or disseminate it, thereby releasing the Owner from any liability towards third parties.

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of the Personal Data.

The processing is carried out using computers and/or IT-enabled tools, following organisational procedures and methods strictly related to the purposes indicated. In addition to the Owner, in some cases the Data may be accessible to other parties involved in the operation of this Application (administrative, sales, marketing and legal staff, system administrators) or to external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, where necessary, as Data Processors by the Owner. The updated list of Processors may be requested from the Owner at any time.

The Owner processes Personal Data relating to the User if one of the following conditions applies:

• the User has given consent for one or more specific purposes. Note: under some legal systems the Owner may be allowed to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opt-out”) to such processing. This does not apply, however, where the processing of Personal Data is governed by European data protection law;
• processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, it is always possible to ask the Owner to clarify the specific legal basis of each processing activity and, in particular, to specify whether the processing is based on law, required by a contract or 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. For further information, please contact the Owner.

The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section containing details about the processing of Personal Data.

The User is entitled to obtain information about the legal basis of Data transfers to a country outside the European Union or to an international organisation 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 the Data.

The User can check whether any of the transfers just described takes place by examining the section of this document on the details of the processing of Personal Data, or request information from the Owner using the contact details provided at the beginning.

The Data is processed and stored for as long as required by the purposes for which it was collected.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for purposes attributable to the Owner’s legitimate interest shall be retained as long as needed to fulfil such purposes. The User can find specific information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When processing is based on the User’s consent, the Owner may retain Personal Data for longer, until such consent is withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, upon expiry of that period, the right of access, the right to erasure, the right to rectification and the right to data portability can no longer be exercised.

Users may exercise certain rights with regard to the Data processed by the Owner.

In particular, the User has the right to:

• withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously given.
• object to the processing of their Data. The User can object to the processing of their Data where it is carried out on a legal basis other than consent. Further details on the right to object are given in the section below.
• access their Data. The User has the right to obtain information about the Data processed by the Owner, about certain aspects of the processing, and to receive a copy of the Data processed.
• verify and seek rectification. The User can verify the accuracy of their Data and ask for it to be updated or corrected.
• obtain the restriction of processing. Under certain conditions, the User can request the restriction of the processing of their Data. In this case the Owner will not process the Data for any purpose other than storing it.
• obtain the deletion or removal of their Personal Data. Under certain conditions, the User can request the erasure of their Data by the Owner.
• receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transmitted to another controller without hindrance. This provision applies when the Data is processed by automated means and the processing is based on the User’s consent, on a contract to which the User is a party, or on pre-contractual measures related thereto.
• lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Where Personal Data is processed in the public interest, in the exercise of official authority vested in the Owner or for the purposes of the Owner’s legitimate interests, Users have the right to object to the processing on grounds relating to their particular situation.

Users should be aware that, where their Data is processed for direct marketing purposes, they can object to the processing without providing any justification. To find out whether the Owner processes data for direct marketing purposes, Users can refer to the relevant sections of this document.

To exercise their rights, Users can send a request to the Owner’s contact details indicated in this document. Requests are filed free of charge and handled by the Owner as soon as possible and in any case within one month.

The User’s Personal Data may be used by the Owner in legal proceedings, or in the preparatory stages leading to them, to defend against abuse in the use of this Application or the related Services by the User.

The User declares to be aware that the Owner may be required to disclose Data upon order of public authorities.

Upon the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information notices concerning specific Services, or the collection and processing of Personal Data.

For operation and maintenance purposes, this Application and any third-party services it uses may collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the User’s IP address.

More details concerning the processing of Personal Data may be requested from the Owner at any time using the contact details provided.

This Application does not support “Do Not Track” requests.

To find out whether any third-party services it uses support them, the User is invited to read their respective privacy policies.

The Owner reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, where possible, within this Application and, where technically and legally feasible, by sending a notice to Users through any of the contact details available to the Owner. Please check this page frequently, referring to the date of the last modification indicated at the bottom.

Should the changes affect processing activities based on the User’s consent, the Owner will collect the User’s consent again, where necessary.