Privacy Policy

This "Privacy Policy" has been drawn up by Smart Living S.r.l., with its registered office in Largo Maresciallo Diaz No. 10, Rome (hereinafter referred to as "Smart Living") pursuant to EU Regulation 2016/679, concerning the protection of personal data (hereinafter referred to as the "Privacy Code"), for the purposes of describing the procedures for administering the site www.smart-living.it (hereinafter referred to as the "Site") and the services made available by Smart Living through the Site (hereinafter referred to as the "Services") in relation to the processing of personal data of users who visit the Site and/or enjoy the use of the Services (hereinafter referred to as the "Users").     
This Privacy Policy is provided only for the Site and not for other web sites that may be accessed by the User through links.

1. Our Policy
Everybody has the right to the protection of their own personal data. Smart Living respects the right of its Users to be informed with regard to the collection and other processing operations of their personal data. In the treatment of data that may, directly or indirectly, identify the User, Smart Living, in compliance with the provisions of the Privacy Code, seeks to respect the principle of strict necessity.  
For this reason, Smart Living has configured the Site so that the use of Users’ personal data is kept to a minimum and excludes the processing of personal data when the purpose of the specific activity can be achieved through the use of anonymous data or through other means which permit the identification of the User only in the case of necessity or at the request of the authorities.   

2. Collection of personal data
Newsletter subscription
Navigation on the Site is free and can be done without any prior registration.
However, for the use of certain services that are available to Users, the latter are requested to register in advance in a special section of the Site.
These data can also be used for a series of additional activities at the expressed consent of the User.
Registration, in particular, is necessary to receive newsletters from Smart Living which are periodic communications sent by e-mail to the e-mail address indicated by the User, through which Users will be informed of Smart Living exclusive initiatives and commercial and/or promotional news (hereinafter referred to as the "Newsletter").    

Data provided voluntarily by the User
The optional, explicit, and voluntary sending of e-mails to addresses indicated on the Site involves the acquisition of the sender's e-mail address which is necessary to respond to requests, as well as any other personal data included in the communication.
In the same way, the transfer of personal data by Users in the section of the Site called "Contacts" involves Smart Living’s acquisition of data voluntarily entered by the User in the appropriate fields, which will be processed in order to respond to messages and/or requests sent by the User and to send commercial, promotional, and/or advertising material to the User by means of electronic mail to the e-mail address indicated by the User, and/or by telephone. Such data will not be used for profiling the User.

Navigation data
I.T. systems and software procedures involved in the operation of this Site acquire, in the course of their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected in order to be associated with identified persons, but by their very nature could, through processing and association with data held by third parties, allow the identification of Users.
This category of data includes IP addresses or MAC addresses of computers used by those Users who connect to the Site, the URI (Uniform Resource Identifier) of requested resources, the time of request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given from the server (successful, error, etc.) and other parameters related to the operating system and the I.T. environment of the user.
These data are used for the sole purpose of obtaining anonymous statistical information on Site usage and to monitor its correct functioning.


Cookies
Cookies are files or pieces of information that are stored on the hard disk of the User's computer (files sent from the server of the internet site to the browser of the user of that site) while navigating the sites.
Cookies stored on Users’ computers cannot be used to retrieve any data from their hard disk, to transmit computer viruses, or to identify and use their e-mail address. Each cookie is unique in relation to the browser and the device used by the User to access the Site.

* Types of cookies used

Smart Living only uses so-called technical cookies, that is, cookies for faster navigation and use of the Site.
Specifically, these are:

Necessary Cookies
These cookies are essential to navigate the Site; allow functions such as the authentication, validation, and management of a browsing session and fraud prevention.

Functional Cookies
These cookies provide additional functionality and allow the tracking of User choices, such as the language selection or the size of the font used.

Performance Cookies
These cookies keep track of the pages that are more frequently visited by the User and of the activity on the Site.  They also allow the immediate identification and resolution of all technical issues that the User may encounter while navigating the Site. The information that these cookies retain is aggregated, anonymous and is not used to collect personal data for advertising purposes.

Session Cookies
Session cookies used are intended to expedite the analysis of internet traffic and to facilitate the User's access to the services offered by the Site.   
No User personal data is intentionally acquired by the Site. Cookies to transmit information of a personal nature are not used, nor are so-called persistent cookies of any kind, or systems for tracking users.
The use of session cookies is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) which are necessary to enable the safe and efficient exploration of the Site.
Session cookies used on this Site avoid the use of other computer techniques that could potentially compromise the privacy of the Users’ browsing experience and do not allow the acquisition of Users’ personal identification data.

Proprietary and third-party Cookies
The categories of cookies mentioned are used directly by Smart Living; they are, therefore, "proprietary cookies" originating from the Site.
However, technical cookies originating from third-party sites are also used, and therefore are released from third parties through the Site onto the User’s computer: these are known as "third party" cookies.
Analytics cookies are "third party" cookies, that is, cookies that are used by the operators of websites to gather information, in aggregate form, on the number of users and on how these visit the site, and therefore, to develop general statistics on the service and its usage.
Analytics cookies used by Smart Living are those made available by Google Inc. through the Google Analytics service.  Google Analytics uses cookies to enable the Site to analyse the ways in which Users use the Site. The information generated by these cookies on the use of the Site (including your IP address) will be transmitted to Google Inc. on servers located, probably, in the United States and stored thereon. Google will use this information for the purposes of assessing the use of the Site, compiling Site activity reports and providing other services relating to Site activity and the use of the internet. Google may also transfer such information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate the User’s IP address with any other data held by Google. Nevertheless, it would be technically possible for Google to identify individual users on the basis of data obtained through the processing performed.
In this regard, please refer to the cookie policy and the related consent form on https://tools.google.com/dlpage/gaoptout?hl=en, through which it is possible to deactivate the Google Analytics service and, therefore, prevent the transfer of data to Google Inc.  For further details, Users are invited to consult Google’s policy on the types of cookies used as part of the services made available to users http://www.google.com/policies/technologies/types/.

* Users’ rights

The use of cookies on the Site will only take place where the person concerned has given consent for this purpose.
The User can consent to the use of cookies by clicking "ok" on the banner that is visible on the first access to the Site, in the homepage of the latter, or by closing the banner and scrolling the homepage or by clicking on any element (by making, therefore, a scrolling action or so-called scroll down).
It should be noted, however, that the consent requested through the aforementioned banner only refers to the use of "third party" technical cookies and does not include proprietary technical cookies.
In order to deactivate the use of proprietary technical cookies, Users must change their preferences on the browser in the manner described below.
If persons concerned refuse the use of cookies, they will not be used but the ability to provide services will be reduced. In the latter case, some Site functions may not work perfectly and some services may not be available. Cookies cannot be used and will not be used to collect Users’ email addresses, nor will they be used to obtain information from the hard disk or personal and/or sensitive data.
Each User, therefore, has the right to deactivate cookies through the software used for the consultation of the Internet network (the so-called "browser"). Many browsers are set up in such a way as to accept cookies in the absence of different instructions from the User.
For this reason, Smart Living encourages Users to check the settings of their browser in relation to cookies, and to adjust them according to their preferences.
For the management of cookies and User preferences, the configuration of each browser is different, and is described in the Help menu of the browser which shows how to change preferences regarding cookies.
• For Internet Explorer™: Click here
 • For Safari™ Safari on iPhone, iPad, or iPod touch:  Click here
 • For Chrome™:  Click here
 • For Firefox™:  Click here
 • For Opera™:  Click here
To manage preferences in relation to the use of cookies, Users may also consult the website http://www.youronlinechoices.com/uk/ and change the settings for cookies at their discretion.

3. Optional provision of data
Apart from what is specified for navigation data, Users are free to provide personal data through registration in the "Contacts" section and/or the Newsletter service, and also by sending their e-mail containing specific personal data, for example, to request information and/or for the sending of information/commercial material and/or other advertising communications.  It should be noted that failure to provide certain data to Smart Living may make it impossible for Users to obtain what was requested from Smart Living.

4. Data Controller and Data Processor
The controller of User personal data is Smart Living S.r.l., with its registered office at Via della Farnesina No. 208, Rome, Tax Code and VAT Registration No. 12303381003.   
The data processor is Mr. Massimo Palone.
It is also possible to request Smart Living to provide the updated list of all the other specially-appointed data processors pursuant to Art. 29 of the Privacy Code by sending a request to the following e-mail address: info@smart-living.it. For any enquiries or information and/or clarification or questions on the treatment of personal data, kindly submit a written request to Smart Living at the following e-mail address: info@smart-living.it.    

5. Methods and purpose of processing
Storage and data access
In its capacity as data controller, Smart Living proceeds, directly or through specially appointed managers, to save Users’ personal data in appropriate databases, stored in the server through the service offered by the company Glacom Italia S.r.l., located in Via Trento No. 124, Toscolano Maderno (BS). This Company which has been entrusted with the outsourcing of the management and updating of the Site also performs hosting services for Smart Living, ensuring compliance with all the necessary security measures in accordance with national and European regulations for the proper treatment and protection of personal data. The servers made available for this hosting service are located on Italian territory.
Data are processed solely by staff responsible for their processing in accordance with proprietary, lawful, transparent, and relevant principles and are restricted to the purpose of data collection and subsequent processing.
Databases can only be accessed by authorised persons using methods that guarantee their protection and confidentiality through the adoption of appropriate security measures to prevent the loss of data, unlawful or improper use and unauthorised access. The data are retained for the time strictly necessary to give course to the processing of operations based on the choices, preferences and instructions of the User.

Treatment in general
Smart Living uses the data of Users in compliance with the choices that Users have freely exercised through their consent, at the time of collection or thereafter, as well as complying with obligations provided by law, regulations and/or European Community directives.
Personal data are processed by automated tools for the time that is strictly necessary to achieve the purposes for which they were collected.
This treatment may consist of collection, processing, recording and/or storage of personal data. The personal data of Users who ask for information, documents, and/or informative material (answers to questions, sending additional documentation, etc.) are used solely to perform the service or assistance requested and are communicated to third parties only if this is strictly necessary in order to meet the User’s demands.

Processing operations subject to consensus, communication and dissemination of data
Only in cases where express authorisation has been obtained from the User, Smart Living proceeds to use the personal data of Users by means of automated tools for purposes as authorised from time to time by the User.  In order to perfectly fulfil the activities requested by Users, Smart Living will transmit the personal data provided by the latter to third-party companies, co-owners or external persons responsible for processing, and who are tasked with carrying out certain activities.
The data will not be disseminated.

6. Security
Personal data are collected and stored in a secure manner by means of technical and organisational measures and procedures that are appropriate to safeguard and secure the information and data collected through the Site.

7. Links to external content
The Site may connect or refer to other sites, services, social networks or external content that are outside the control of Smart Living.  Once the User has left the Site, Smart Living is not in a position to safeguard the security of the User’s personal data and is not liable for the protection and privacy of any personal data that the User may have provided on other sites.

8. User rights
Pursuant to Art. 7 of the Privacy Code, the User has the right to obtain confirmation of the existence or non-existence of personal data, even if not yet registered, and moreover, ask for the communication in an intelligible format.
The person concerned has the right to obtain information on:
a) the source of the personal data;
b) the purposes and methods of processing;
c) the logic applied in case of processing carried out by means of electronic instruments;
d) the identification details of the owner, managers and designated representatives pursuant to Art. 5, paragraph 2;
e) the subjects, or categories of subjects, to whom the personal data may be transmitted or who is privy to the knowledge in their capacity as designated representative in the State, as managers or as agents.
The person concerned has the right to obtain:
a) the updating, rectification or, where there is an interest, the integration of the data
b) the cancellation, the anonymisation or the blocking of data processed unlawfully, including data that need not be retained for purposes for which the data were collected or subsequently processed;
c) the confirmation that the operations referred to in (a) and (b) were brought to the notice, also as regards to their content, of those to whom the data were communicated or disseminated, except in the case where this is impossible or involves the use of means that are manifestly disproportionate in relation to the protected right.
The User has the right to oppose, in whole or in part:
a) the processing of personal data for legitimate reasons, even if relevant for collection purposes;
b) the processing of personal data for the purpose of sending advertising material or direct sales or for the undertaking of market research or commercial communication.
The rights listed above may be exercised by writing to Smart Living at the following e-mail address: info@smart-living.it.

9. Changes to this Privacy Policy
Notwithstanding the fact that, in any case, Smart Living will not proceed to processing operations other than those expressly authorised and/or requested by each User, this Privacy Policy may be subject to modifications in order to comply with new legal provisions or policy changes on the treatment of data by Smart Living.
Each updated version of this Privacy Policy will be made available on the Site in the dedicated section: Smart Living invites all Users to periodically consult the Site in order to always be informed of the latest version loaded.