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The purpose of this document is to inform Users regarding the Personal Data collected from the website (hereinafter the “Application”).

The Data Controller, as subsequently identified, may modify or simply update, in whole or in part, this Information by informing the Users. Changes and updates will be binding as soon as they are posted on the Application. The User is therefore invited to read the Privacy Policy each time they access the Application.

In the event of non-acceptance of the changes made to this Privacy Policy, the User is required to cease using this Application and may request the Data Controller to remove his Personal Data.

Personal Data collected by the Application

The Data Controller collects the following types of Personal Data:

Data and content automatically acquired while using the Application

  • Technical data: the computer systems and software procedures used to operate this Application may acquire, during their normal operation, some
  • Personal Data whose transmission is implicit in the use of internet communication protocols. This is information that is not collected to be associated with identified Users, but which by their very nature could, through processing and association with Data held by third parties, allow Users to be identified. This category includes the IP addresses, or domain names used by Users who connect to the Application, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained, etc.
  • Usage data: Data relating to the use of the Application by the User may also be collected, such as for example the pages visited, the actions performed, the functions and services used.
  • Geolocation Data: The Application may collect location Data, which may be accurate or inaccurate. Precise Location Data may be Global Navigation Satellite System (GNSS) Data, such as GPS Data, as well as Data identifying the nearest cell tower, Wi-Fi and bluetooth hotspots, communicated when you enable location-based products or features position.

Personal data collected through cookies or similar technologies

This Application uses cookies, web beacons, unique identifiers and other similar technologies to collect Data on the pages, the links visited and the other actions you perform when you use our Services, within the advertising or email content. They are memorized to then be retransmitted to the same sites at the next visit by the same User. The User can view the complete Cookie Policy at the following address:


The Personal Data collected can be used for the execution of contractual and pre-contractual obligations and for legal obligations as well as for the following purposes:

  • viewing content from external platforms
  • statistics only with anonymous data
  • access to accounts on third party services
  • monitoring, analysis and tracking of User behavior
  • technical monitoring of the infrastructure for maintenance, troubleshooting and performance improvement
  • personalization of the user experience
  • Geolocation of the user to allow a quick search for the nearest points of sale

Methods of treatment

The processing of Personal Data is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated.

In some cases, subjects involved in the organization of the Data Controller may also have access to Personal Data (such as, for example, personnel management, sales area employees, system administrators, etc.) or external subjects (such as IT companies, suppliers of services, postal carriers, hosting providers, etc.). When necessary, these subjects may be appointed as Data Processors by the Data Controller, as well as access the Users’ Personal Data whenever necessary and will be contractually obliged to keep the Personal Data confidential. The updated list of Managers can be requested via email at

Legal basis of the treatment

The Data Controller processes Personal Data relating to the User in the event that one of the following conditions exists:

  • the User has given consent for one or more specific purposes
  • the processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment.


The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller at the following email address or at the following postal address Sir Company S.r.l Via Roberto Campana, 17, 64100 Teramo (TE)

Security measures

The Processing is carried out according to methods and with tools suitable for guaranteeing the security and confidentiality of the Data, since the Data Controller has adopted adequate technical and organizational measures which guarantee, and allow to demonstrate, that the Processing is carried out in compliance with the reference legislation.

Data retention period

The Data Controller will process the Personal Data for the time necessary to fulfill the purposes connected with the execution of the contract between the Data Controller and the User no later than 20 years from the termination of the relationship with the User and in any case until the completion of the deadline prescribed by the regulations in force.

When the processing of Personal Data is necessary for the pursuit of a legitimate interest of the Data Controller, the Personal Data will be kept until such interest is satisfied.

If the processing of Personal Data is based on the User’s consent, the Data Controller may keep the Personal Data until revoked by the same.

Personal Data may be kept for a longer period if necessary to fulfill a legal obligation or by order of an authority.

All Personal Data will be deleted upon expiry of the retention period. Upon expiry of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Automated decision-making processes

All the Data collected will not be subject to any automated decision-making process, including profiling, which may produce legal effects for the person or which may significantly affect him.

User rights

Users may exercise certain rights with regard to the Data processed by the Data Controller. In particular, the User has the right to:

  • withdraw consent at any time;
  • oppose the processing of their Data;
  • access to their Data;
  • verify and request rectification;
  • obtain restriction of processing;
  • obtain the cancellation of their Personal Data;
  • receive their data or have them transferred to another owner; lodge a complaint with the Personal Data Protection Supervisory Authority and/or act in court.

To exercise their rights, Users may address a request to the Controller’s contact details indicated in this document. Requests are made free of charge and processed by the Holder as quickly as possible, in any case within 30 days.

Data Controller

The Data Controller is Sir Company S.r.l, Via Roberto Campana, 17 – 64100 Teramo (TE), Fiscal Code / VAT number 01967120674, e-mail address

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