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Privacy policy of Harpa Italia S.r.l.

We apply the same high standards that you expect from our products and services when managing your personal data. For Harpa Italia S.r.l. the confidentiality and integrity of your personal data are important. Therefore, we will treat them carefully and for specific purposes, in line with the consent that you may have issued and, in any case, in compliance with the provisions of the law on data protection.
In the following sections you will find the description on how Harpa Italia S.r.l. collects and processes the personal data of its users (eg Customers, Personnel, Suppliers, etc.).
About us
About Harpa Italia S.r.l.
http://www.harpaitalia.it/#about

How do we collect your personal data?
The Harpa Italia S.r.l. company processes your personal data in the following circumstances:
– If you contact us directly, for example through our websites (www.harpaitalia.it, www.mcuboict.com, www.mcuboenergy.com e www.aircare.it), by e-mail or by telephone through our direct line, in order to request information about our products and services;
– If you buy our product or service, for example through our websites (www.harpaitalia.it, www.mcuboict.com, www.mcuboenergy.com e www.aircare.it) or our sales network (direct or commercial representatives);
– If you respond to our marketing campaigns, for example by filling in a reply form, or by entering data on our website;
– If your contact details are communicated to Harpa Italia S.r.l. by a salesman in his sales and assistance activities or by a third party figure with your consent;
– If other companies or business partners legitimately transfer your personal data to Harpa Italia S.r.l.;
– If we acquire your personal data from other sources (eg from intermediaries), in full compliance with applicable legislation;
– If you attend an event organized by Harpa Italia S.r.l.
If you provide personal data on behalf of someone else, it is your responsibility to ensure, before doing so, that the interested party has read this Privacy Notice. If you are under 16, please do not provide us with any personal information.
We ask for your support in order to keep your personal data up to date, informing us of any changes to them.

What personal data concerning you can be collected?
The following categories of your personal data can be collected through the various services and contact channels described in this Privacy Policy:

  • Contact detailsinformation concerning name, surname, date and place of birth, tax identification number, address, telephone number, email address, IP address
  • Interests – information that you provide us regarding your interests, including the type of hardware, software, product and / or service you are interested in
  • Other personal data – information you provide us with regards to your date of birth, education or professional situation
  • Contract data – customer number, contract number, active assistance and software development services
  • Use of the Site and Communications – information relating to the ways in which you use our site, open or forward our communications, including information collected through cookies and other tracking technologies (you can check our Cookie policy)
  • Online account data – information on portals accounts (www.harpaitalia.it, www.mcuboict.com, www.mcuboenergy.com e www.aircare.it)
  • Information on Sales and Assistance – information related to purchases, support and assistance, including complaints
  • Hardware and software configuration details – information on the functions and current software settings (identified by IP)
  • Software technical information and databases – information on how software and/or databases are working or have worked
  • Location data from installed software – the location of the mobile device on which the Apps are installed
  • Images – images of you collected through photos and/or videos made during events organized by Harpa Italia S.r.l.

For what purposes can your personal data be used?
The processing of personal data in compliance with European regulations on data protection must be legitimized by one of the various legal conditions provided and Harpa Italia S.r.l. is required to indicate these conditions for each treatment described in this statement. An in-depth analysis of these possible assumptions can be found later in this statement. You will find the indication of the assumption underlying each purpose of the treatment noted at the bottom of the same.
Your personal data will in any case be processed, for the purposes described below, mainly with IT tools, also using the various channels available depending on the configuration of the software or its default equipment (such as, for example, monitoring systems)

First Purpose: Customer Loyalty and Marketing – to provide you with news and offers
Harpa Italia S.r.l. collects contact data, interests, other personal data, use of company websites (www.harpaitalia.it, www.mcuboict.com, www.mcuboenergy.com e www.aircare.it) and communications. Harpa Italia can use these information on Sales and Assistance  through the contractual activities carried out, the institutional websites and the various events realized (conferences, seminars, product and / or service presentations, etc.), or through your own sales network (Sellers, Agents, etc.) in order to contact you about generic commercial offers, including sending periodic newsletters (respecting your preferences) or to invite you to promotional events, as well as to carry out market research and / or satisfaction surveys of customers. Harpa Italia S.r.l. may share this information with its suppliers to propose more specific offers or to contact you in the event of dissatisfaction expressed during satisfaction surveys.
Condition for processing: consent
Choice: The consent can be revoked at any time through our data controller Dr. Bruno Facello at the e-mail address gdpr@harpaitalia.it or by post at the address Via Vitorchiano 123, 00189 Roma – Harpa Italia srl

 

Second Purpose: sending newsletter – allow periodic sending of newsletters and/or commercial information
Harpa Italia S.r.l. collects contact data through special sections of the company websites (www.harpaitalia.it, www.mcuboict.com, www.mcuboenergy.com e www.aircare.it), and any subdomains, in order to send periodic communications by email, letters, SMS, WhatsApp with informative content on offers, products, news, events concerning the world of Harpa Italia S.r.l. (in the event that you have requested to receive periodic newsletters, the withdrawal of the consent referred to in paragraph 1 will have no effect on the continuation of this service).
Condition for processing: consent
Choice: The consent can be revoked at any time through our data protection manager Dr. Bruno Facello at the e-mail address gdpr@harpaitalia.it or by post at the address Via Vitorchiano 123, 00189 Roma – Harpa Italia srl

 

Third Purpose: Fulfillment of a customer request – to respond to your request (eg software and hardware tests, purchase and loan for use contracts, quotation, contact request or participation in events open to the public, IT courses, service execution, e-commerce etc.)
Harpa Italia S.r.l. collects contact data and Interests, also via company websites i (www.harpaitalia.it, www.mcuboict.com, www.mcuboenergy.com e www.aircare.it), and other subdomains in order to respond to your requests, also by sharing, if necessary, such information with the managers and the sales partners and/or business partners who can act as autonomous holders of the data processing, not before the release of their information.
Condition for processing: execution of pre-contractual and contractual measures
Choice: The consent can be revoked at any time through our data protection manager Dr. Bruno Facello at the e-mail address gdpr@harpaitalia.it or by post at the address Via Vitorchiano 123, 00189 Roma – Harpa Italia srl

 

Fourth Purpose: Fulfillment of a customer request
The personal data collected for the purpose of fulfilling a request from the customer may also be processed for further purpose of verifying the effectiveness of the response to your requests, so as to improve the service rendered to its customers.
Condition for processing: legitimate interest. This treatment is based on the legitimate interest of Harpa Italia S.r.l. to assess the degree of effectiveness of the replies to customer requests in order to verify that the quality standards of the services comply with those of Harpa Italia Srl, and to adopt any improvement measures that may be appropriate, also in the interest of the customers themselves.
Choice: opposition in the case of legitimate interest, if the conditions exist.

 

Fifth Purpose: Participation in a competition or prize operation: to allow your participation in competitions or prize-winning operations organized by Harpa Italia S.r.l.
Harpa Italia S.r.l. collects the contact data, and if necessary, the interests and other personal data in order to allow your participation in competitions or prize operations organized by Harpa Italia Srl.
Condition for processing: execution of pre-contractual measures
Choice: The consent can be revoked at any time through our data protection manager Dr. Bruno Facello at the e-mail address gdpr@harpaitalia.it or by post at the address Via Vitorchiano 123, 00189 Roma – Harpa Italia srl

 

Sixth Purpose: Support to the Sales and Assistance of the hardware and software – to provide support, also through the provision of the IT infrastructure, in sale management, to configure your hardware and software and to provide the related services.
The sellers and sometimes the service personnel collect the contact data, the details of the software configuration, the technical information of the software and the sales and assistance information if you purchase, ask for assistance or repair the software with them as part of the sale or assistance, and will use them to provide the services requested by you and to inform you in case of any problems concerning your software. These information will be held by Harpa Italia S.r.l. which provides the IT infrastructure, also to identify and resolve any technical issue or other problems related to the provision of the indicated services, including communications related to recall actions and product improvement actions. Harpa Italia S.r.l. may also receive limited information on software localization during the repair process that may be used in compliance with the Localization Information Protection.
Condition for processing: fulfillment of contractual obligations, legitimate interest.
Legitimate interest: This treatment is based on the legitimate interest of Harpa Italia S.r.l. to satisfy any requests and problems of customers that may arise during sales and assistance, as well as to allow sales and assistance staff to provide their services using the tools made available by Harpa Italia S.r.l.
Choice: opposition in the case of legitimate interest, if the conditions exist.

 

Seventh Purpose: The personal data collected for the purpose of supporting the sale and assistance of the software could also be processed for the further purpose of managing the commercial program.
Harpa Italia S.r.l. may process such data for the purpose of executing contractual relationships and existing commercial programs with the sellers and service personnel.
Condition for processing: this treatment is based on the legitimate interest of Harpa Italia S.r.l. to verify the existence of the prerequisites to implement what was agreed in the commercial program, and to provide the proof where necessary.
Choice: opposition in the case of legitimate interest, if the conditions exist.

 

Eighth Purpose: Direct sales of Hardware and Software – to manage the direct sale of hardware and Software and provide the related services.
Harpa Italia S.r.l. collects Contact Data through different channels (online, agents, vendors, service representatives), details of the Software Configuration, Software Technical Information and Sales and Assistance Information if you purchase a software, and will use them to provide the services requested by you and to inform you in case of any problems relating to your software, including communications relating to actions to intervene on the software and to improve products and services. Harpa Italia S.r.l. will have access to these information in order to identify and resolve any technical issue related to the provision of the indicated services.
Condition for processing: execution of pre-contractual measures
Choice: The consent can be revoked at any time through our data protection manager Dr. Bruno Facello at the e-mail address gdpr@harpaitalia.it or by post at the address Via Vitorchiano 123, 00189 Roma – Harpa Italia srl

 

Ninth Purpose: Promotion of the Harpa Italia S.r.l. Brands  (www.harpaitalia.it, www.mcuboict.com, www.mcuboenergy.com e www.aircare.it) to promote them on social media channels or other media.
During events in which there is a service of Images, Photos and Video footage, Harpa Italia S.r.l. could collect the Image data, without acknowledging any compensation, in order to promote the Harpa Italia S.r.l. (www.harpaitalia.it, www.mcuboict.com, www.mcuboenergy.com e www.aircare.it) by publishing them on social media channels (eg: Facebook, Twitter, Instagram, Linkedink, etc.) or distributing them on local, national or international newspapers.
Condition for processing: consent.
Choice: The consent can be revoked at any time through our data protection manager Dr. Bruno Facello at the e-mail address gdpr@harpaitalia.it or by post at the address Via Vitorchiano 123, 00189 Roma – Harpa Italia srl

 

Tenth Purpose: Management of insurance coverage and possible claims – to protect one’s own interests, fulfill legal and contractual obligations or judicial authority provisions.
Harpa Italia S.r.l. during events organized for the promotion of Harpa Italia S.r.l. (www.harpaitalia.it, www.mcuboict.com, www.mcuboenergy.com e www.aircare.it) needs to have insurance coverage. Therefore, your Contact Data could be processed by the company for these purposes and communicated to the insurance companies as well as, in the event of a claim, to third-party companies that deal with assessing the damage occurred.
Condition for processing: legal obligations, fulfillment of contractual obligations and legitimate interest.
Legitimate Interest: This treatment is based on the legitimate interest of Harpa Italia S.r.l. to protect its assets and its image.
Choice: opposition in the case of legitimate interest, if the conditions exist.

 

Eleventh Purpose: Compliance with the legally binding demands of your personal data and protection of your own right.
To fulfill legal obligations, regulations or provisions of the judicial authority, as well as to defend a right in court. All owners are subject to the laws of the countries in which they operate and must comply with these laws. We will provide information concerning you to the law enforcement agencies, regulations and court documents in any part of the world if needed. Furthermore, Harpa Italia S.r.l. could process your personal data where it needs to defend its own right in court.
Condition for processing: legal obligations, legitimate interest. This treatment is based on the legitimate interest of Harpa Italia S.r.l. to protect and defend their rights.
Choice: opposition in the case of legitimate interest, if the conditions exist.

 

Twelfth Purpose: Quality Control, Research and Development – in order to improve our products and services.
Harpa Italia S.r.l. can use any information received regarding services rendered in anonymized form for quality control and for purposes of product and service development. Before starting such processing, your information will be anonymized so that it can no longer be traced back to you.
Condition for processing: legitimate interest. This treatment is based on the legitimate interest of Harpa Italia S.r.l. to satisfy the high expectation of its customers regarding the quality of our current products and services as well as their desire for new innovative solutions.
Choice: The consent can be revoked at any time through our data protection manager Dr. Bruno Facello at the e-mail address gdpr@harpaitalia.it or by post at the address Via Vitorchiano 123, 00189 Roma – Harpa Italia srl

 

How do we keep your personal data safe?
We use a wide range of security measures, including encryption and authentication tools, in order to improve the security and maintenance of security, integrity and accessibility of your personal data. Although it is not possible to guarantee the total security from intrusions for the transmission of data that takes place on the internet and websites, we and our subcontractors and business partners do our best to ensure physical, electronic and procedural safeguards to protect your personal data in accordance with data protection requirements.
We adopt measures such as:
strict restriction of access to your personal data, based on the need and only for the purposes communicated;
– transfer of data collected only in encrypted form;
– storage of highly confidential information (such as credit card information) only in encrypted form;
– IT firewall systems to prohibit unauthorized access, for example by hackers;
– permanent monitoring of access to IT systems to identify and stop the abuse of personal data.

If we have provided you (or you have chosen) a password that allows you to access to certain sections of our website or other portals, applications or services provided by us, you will be responsible for maintaining the secrecy of this password and for respecting any other security procedure. We ask you not to share your passwords with anyone.

Protection of location data:
Some services may be offered only if you accept to activate your location or the location of your software and/or other device. We take the confidentiality of location data very seriously.
Below are the security measures applied to Location Data (including information accessible as part of the software assistance process):

  • such data is stored, in the form associated with you or your software, only for the time necessary to fulfill the permitted purposes;
  • these data are collected, stored or accessed only to provide the requested service, in accordance with the law;
  • Software Location Data and Device Location Data are not linked to each other unless this is necessary to provide the requested service;
  • For statistical analysis purposes we will use only irreversibly anonymized data for any other use of the Software/Device Localization Data.

Harpa Italia S.r.l., sellers and service technicians can have access to the Software and/or device Localization Data through the services provided.

You will be provided with a detailed description of the Location Data necessary to provide a service based on such Data, at the time of purchase of the software and / or service or when you have activated or configured the service or application.
However, we ask you to consider that we will not be able to provide you with certain features of our services, if you limit the collection of your Location Data.

For how long do we keep your data?
We keep your personal data only for the time necessary to achieve the purposes for which they were collected for or for any other legitimate purposes connected (for example, whenever they are relevant for a defense against claims made against us or in the presence of a legitimate interest). Therefore, if personal data are processed for two different purposes, we will keep such data until the purpose with the longer term expires ; however we will no longer treat personal data for that purpose whose retention period has ceased.
We limit access to your information to those who need to use it for relevant purposes. Your personal data that are no longer necessary, or for which there is no longer a legal prerequisite for their conservation, are irreversibly anonymized (and thus can be stored) or permanently deleted. To this end, personal data will be stored for the time necessary to achieve the purposes for which they were collected for. For greater clarity we list below the retention periods related to the main purposes:
Marketing purposes: personal data processed for marketing purposes may be kept for 10 years from the date on which we obtained your last consent for this purpose (with the exception of opposition to receive further communications);
Fulfillment of contractual obligations: the data processed to fulfill any contractual obligation with you, may be kept for the entire duration of the contract as well as for other 10 years from the end of the subsequent fiscal year, to deal with any investigation and / or tax dispute;
Purposes related to the provision of online services: information relating to the storage times of the Software Localization Data [and Device Information] in relation to the various services is available;
In the event of disputes: in the event that it is necessary to defend ourselves or act or even make claims against you or third parties, we may keep the personal data that we consider to be reasonably necessary to process for these purposes, for as long as this claim can be prosecuted.
Image processing: Image data will be stored in Harpa Italia S.r.l. for a period of 60 months and will be subsequently canceled.

With whom can we share your personal data and how do we keep them safe?
Your personal data may be accessed by our staff, agents and suppliers also located in countries outside the European Economic Area (EEA), for one of the established purposes, whose laws regarding data protection could be less strict than those of the AEE. If this happens, we will ensure that all your personal data accessible outside the EEA is treated with appropriate safeguards.
In case of data transfer to foreign countries, you will be asked for your consent or your personal data will be transferred using the contractual clauses approved by the European Commission. These clauses impose similar data protection obligations directly on the recipient, unless we are allowed by the applicable data protection law to transfer the data without such formalities.
Although the transmission of data via the Internet or websites cannot be guaranteed to be completely safe from intrusions, we and our subcontractors, as well as our commercial partners, strive to maintain physical, electronic and procedural security measures to protect your personal data, compliant with the requirements imposed by the data protection legislation.
All your personal data is stored on our secure servers (or hard copies securely stored) or on those of our subcontractors or our business partners, and are accessible and usable according to our standards and our security policies (or equivalent standards for our subcontractors or business partners).
The personal data that we collect, for example to implement the Insurance Services, can be communicated to third parties, on your behalf and with your consent, only for the purpose of allowing these subjects to render their services (e.g. insurance sector).

How can you verify and change your online and/or paper privacy settings?
You can check and change the online settings for the use of your data through the company websites (www.harpaitalia.it, www.mcuboict.com, www.mcuboenergy.com e www.aircare.it), using the possible options. Here you can choose your preferred communication channel (communication via mail, email, etc.).

Contact details of the Data Protection manager, data protection rights and the right to make complaints before the Control Authority.
If you have any questions regarding the use of your personal data, please contact the Data Protection manager Dr. Bruno Facello at the e-mail address gdpr@harpaitalia.it or on the phone number 06 33236915 (from Monday to Friday 9.00 am – 5 pm).
You can edit or choose any option regarding marketing communications through our company websites (www.harpaitalia.it, www.mcuboict.com, www.mcuboenergy.com e www.aircare.it).
Based on current legislation, you have the right to ask us:

  • further details on data processing we carry out;
  • copy of the personal data you provided;
  • to update any inaccuracies on the data in our possession;
  • to delete any data for which we no longer had any legal basis for processing;
  • to withdraw your consent, in the event that the processing is based on consent and is related to direct marketing activities, so that such treatment ceases;
  • to oppose to any data processing [including profiling] based on legitimate interests unless the reasons for which we are obliged to perform such processing outweigh any prejudice to your data protection rights;
  • to limit the way in which we process your personal data during the verification of a complaint via the form available here.

The exercise of these rights is subject to some exceptions aimed at safeguarding the public interest (for example the prevention or identification of crimes) and our interests. In the event that you exercise any of the aforementioned rights, it will be our responsibility to verify that you are entitled to exercise it and we will reply within a month.
In the event that you, having complied with the conditions, withdraw your consent or exercise the right to cancel your data, it will be necessary to consider that this operation will require technical processing time during which you could still be contacted regarding marketing activities already underway. If you are not satisfied with the way we treat your personal data, or with our feedback, you will have the right to lodge a complaint with the supervisory authority.

Company and Personal Data Protection Manager contacts:
Should you have any questions regarding the processing by Harpa Italia S.r.l. of your personal data, please contact us directly or through our Data protection manager at the following addresses:
a) Harpa Italia S.r.l. e-mail address e-mail gdpr@harpaitalia.it or phone number 06 33236915 (Monday to Friday 9.00 am – 5.00 pm).
b) Harpa Italia S.r.l. Data protection manager Dr. Bruno Facello can be contacted at the e-mail address: e-mail gdpr@harpaitalia.it

Legal requirements for the processing of personal data:
The processing of your personal data described above is authorized by European legislation on data processing, based on the following legal assumptions:

  • Consent: if you have consented to their use having agreed to the request that can be revoked at any time;
  • Implementation of pre-contractual measures or fulfillment of contractual obligation: if it is necessary to conclude or to fulfill a contract with us or to execute pre-contractual measures;
  • Legal obligations: if it is necessary for us to use your personal data to respect our legal obligations;
  • Legitimate interest: if we use your personal data to pursue a legitimate interest and our reasons exceed any prejudice to your data protection rights;
  • Legitimate interest: if it is necessary for us to defend ourselves, act in court or make claims towards you, ourselves or third parties;

Authorized treatments are possible based on additional requirements; in this case we will do all that is reasonably possible to identify this assumption and give appropriate communication.

Consequence of refusal to provide personal data by the interested party:
The provision of personal data is not mandatory. If the interested party does not consent to the processing of personal data, the relative service (sale of products, services and assistance) cannot be performed.
Consent to processing for scientific, research and marketing purposes is optional, and withholding the consent does not prevent in any way access to the requested services. The interested party has the right at any time to modify or revoke the consent given for each of the processing operations by contacting the Data protection manager.

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