Privacy Policy

General introduction
This website is owned and managed by ICAM S.r.l. As a result of the use of this website, data relating to identified or identifiable individuals or legal entities, considered personal data as defined under Legislative Decree 196/03, may be processed. ICAM S.r.l., in line with current Italian data protection laws, undertakes to guarantee the privacy and the security of each website navigator's personal data, even when the Internet is accessed from abroad. This page describes the procedures used to manage the website with regard to the processing of the personal data supplied by site users. Detailed information regarding processing, as per Article 13 of Legislative Decree 196/03 – Personal Data Protection Code - is provided on each page where services are offered. These disclosure statements aim to define the data processing limits and procedures for each service so that the customer/visitor may freely provide consent and authorise collection of his/her personal data and its subsequent use.

Type of data processed
This website offers informative and interactive content. During site navigation, information regarding the customer, or more generally regarding the visitor to the site, may be acquired as follows:

Navigation data
During normal operation, the IT systems and software procedures used to run this site collect personal data, which is implicitly transmitted through the use of Internet communication protocols. This information is not collected in order to be associated with identified data subjects, but could, by its very nature, and if processed and integrated with third-party data, allow Users to be identified. IP addresses, browser type, operating system, domain name and Web referring or exit pages, information on pages visited by the User within the site, access time, length of stay on each page, clickstream analysis and other parameters regarding the operating system and the User's IT environment all fall under this category of data. This technical/IT data is collected and used on an aggregated and anonymous basis exclusively to improve quality of service and obtain statistics on site use. This data is not associated with Users who may access this site or certain areas of it by using an authentication system based on the use of a username and password. Data voluntarily supplied by the customer/visitor These cases involve the customer/visitor entering his/her personal data on the site after reading detailed information in order to access personally selected services. "Opt-in" and "Opt-out" policies: in all cases, appropriate detailed information is provided and, where required, consent for the processing of personal data is obtained before a given service is activated. Said consent may be revoked at any time, whereby the ability to use the service in question is lost. Specific information is gradually provided or displayed on pages of the site that offer specific services on request.

Data from minors
ICAM S.r.l. does not allow minors under 18 years of age to supply personal data.

Data retention
Data collected is retained only for the amount of time strictly necessary to achieve the purpose of the processing. Once the service has been provided, all personal data required to activate and manage the service requested will be deleted, in accordance with data retention policies, unless otherwise requested by government or legal authorities or otherwise stipulated by law.

Technologies

Cookies
Cookies are pieces of information that may be saved in a computer during website navigation, in order to process and identify usage data. The cookie file is usually extremely small and does not take up excessive space on the computer's hard disk. The cookie is transferred to the User's disk after registration in order to "remember" the areas of the website that were visited. This allows the User to save time, by more readily reaching the main areas of a previously visited website. Various types of cookies exist: perrmanent cookies, which remain on the computer's hard disk, even once the browser has been closed; temporary or session cookies, which are saved only for the navigation session and which are deleted from the computer when the browser is closed; third-party cookies, which are generated by a website other than the one you are currently visiting. The cookies used by ICAM S.r.l. are a combination of these three types: some serve only to open and maintain an authenticated session (temporary cookies). In this case, closing the authentication session or browser will make them unusable both to us and to third parties, even though they physically remain on the hard disk of the computer that is used (permanent cookies). In order to offer a site that better meets customer/visitor expectations and interests, data collected using cookies is continually analysed; this data indicates exclusively and anonymously how our website is used, and what areas and sessions are of most interest and use to navigators. The customer/visitor may set his/her browser to accept all cookies, some cookies, or to refuse them. Note that failure to accept cookies may prevent us from providing the service requested in areas requiring authentication. In addition, at the end of each navigation session, the customer/visitor may delete the navigation cache memory as well as the cookies collected from his/her hard disk.

JavaScript
This is a technique used as an alternative to direct analysis of Web server log files. It consists of collecting and processing navigation data using dedicated JavaScript code in the HTML pages deemed of interest. This technique is also used in newsletters sent out via email. This website uses the external Web analysis service provided by Google Analytics, which uses javascript technology to allow the website to analyse how Users use this site. The information generated regarding use of the website by the User (including his/her IP address) will be sent and stored on the servers of Google Analytics. will not associate your IP address with any other data in possession of Google Analytics. By using this website, the User consents to the processing of his/her personal data by Google Analytics for the abovementioned purposes and procedures.

Connection to third-party sites
It is possible to link to other websites from this site; the ability to do so is clearly indicated in order to inform the customer/visitor that he/she is leaving the Smoov ASRV site. The customer/visitor should note that these sites are not the property or responsibility of ICAM S.r.l. as they are fully managed by other companies and/or organisations. It is therefore necessary to verify and accept their data protection policies. ICAM S.r.l. consequently declines all responsibility for requests and/or release of personal data to third-party sites.

Other forms of data use
In addition, and exclusively in the interest of law and order, observance of provisions of law regarding national security and defence, and prevention, investigation and/or prosecution of criminal offences, the data provided may be used for purposes other than those required to provide services and may be communicated to public entities, including law enforcement agencies and public and judicial authorities to allow them to perform duties that fall under their responsibility.

Behaviour inconsistent with the policy (Loyalty)
This document has been drafted to better satisfy our customers' needs for transparency and trustworthiness and to preserve Smoov ASRV company values, in particular that of protecting the privacy of collected data. For any problems or to request explanations on website content or any information contained in this document, please contact us at ICAM S.r.l. - Customer Services – Privacy Office, S.P. 237 delle Grotte 70017 Putignano (BA) – ITALY

Policy changes
This Privacy Policy governs the methods for processing personal data provided by customers/visitors when navigating our website. These methods may need to be modified as a result of new laws entering into force or after examination and updating of User services. As a result, our policy may be modified over time, and we kindly ask customers/visitors to periodically consult this page.

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