Privacy Policy

Last updated: 09/02/2026

1. Data Controller

Smart37 SRL Unipersonale

Piazza Monte Grappa 6, 21100 Varese (VA), Italia
Partita IVA: 04109700122

privacy@smart37.com

2. Types of Data Collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:

  • First name and last name
  • Email address
  • Usage Data
  • Tracker and Cookies
  • Device information (browser type, operating system, IP address)

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy.

3. Mode and Place of Processing the Data

3.1 Methods of Processing

The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

3.2 Place

The Data is processed at the Data Controller's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. Users are entitled to learn about the legal basis of Data transfers to a country outside the European Union.

3.3 Retention Time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users' consent.

4. The Purposes of Processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:

  • Registration and authentication
  • Contacting the User
  • Analytics and statistics
  • Managing support and contact requests
  • Platform services and hosting

5. The Rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:

Withdraw consent

Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

Object to processing

Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.

Access their Data

Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

Verify and seek rectification

Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

Restrict processing

Users have the right, under certain circumstances, to restrict the processing of their Data.

Have Data deleted

Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

Data portability

Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.

Lodge a complaint

Users have the right to bring a claim before their competent data protection authority.

6. How to Exercise These Rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

7. Cookie Policy

This Application uses Trackers. To learn more, Users may consult the Cookie Policy.

8. Additional Information About Data Collection and Processing

8.1 Legal Action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.

8.2 System Logs and Maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

9. Changes to This Privacy Policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top.

10. Definitions and Legal References

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.

Contact Information

Smart37 SRL Unipersonale

Piazza Monte Grappa 6
21100 Varese (VA), Italia
P.IVA: 04109700122