Privacy Policy

1. Personal Data collected by the Application

The Data Controller shall collect the following categories of Personal Data:

1. Voluntary contents and information provided by the User

• Contact information and contents: Personal Data that the User voluntarily provides to the Application during use, such as personal details, contact information, login credentials for services and/or products provided, interests and preferences, and any other personal content, etc.
• Sensitive data: Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning the sex life or sexual orientation of a natural person.
• Personal Data from social media: Users may share with the Application data that they have provided to social media. The User can control the Personal Data that the Application may access through the privacy settings of the relevant social media website. By connecting social-media accounts to the Application and authorising the Data Controller to access their Personal Data, the User consents to its acquisition, processing and retention in accordance with the Privacy Policy.

If the User does not communicate Personal Data for which there is a legal or contractual obligation, it will be impossible for the Data Controller to provide its services, in whole or in part. The same applies where Personal Data is a necessary requirement for use of the service or conclusion of the contract.

The User who communicates third parties' Personal Data to the Data Controller is directly and exclusively liable for its origin, collection, processing, communication or disclosure.

2. Data and contents automatically acquired while using the Application

• Technical Data: the computer system and software procedures used to operate this Application may acquire, during their ordinary activity, Personal Data whose transmission is implicit in the use of Internet communication protocols. Such information is not collected in order to associate it with identified Users; however, by its nature, it may allow Users to be identified through processing and association with Data held by third parties. This category includes IP addresses or domain names used by Users who connect to the Application, Uniform Resource Identifier (URI) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained, etc.
• Usage Data: Personal Data may be collected relating to the use of the Application by the User, such as the pages visited, the actions performed, the features and services used by the User.

3. Personal Data collected through cookies or similar technologies

The Application uses cookies, web beacons, unique identifiers and other similar technologies to collect Personal Data about pages, visited links and other actions performed while using our Services. They are stored and sent back to the same websites on the User's next visit.

Complete information is available in the Cookie Policy.

4. Google Analytics site-usage measurement

Only after the User explicitly accepts Analytics, the Application uses Google Analytics 4, provided by Google LLC, to measure page views and aggregate site usage. This processing may include the page address and title, approximate geographic area, browser, device, operating system, language, session information, and page-view time. The Application does not send waiting-list fields or lead data to Google.

Analytics consent is separate from waiting-list privacy consent and may be refused or withdrawn at any time through Cookie settings without limiting access to the Application. Advertising features, remarketing, advertising personalization, Google Signals, Enhanced Measurement, and custom events are not used. Details about cookies, recipients, transfers, retention, and withdrawal are provided in the Cookie Policy.

2. Purposes of the processing

Collected Personal Data may be used for the performance of contractual and pre-contractual obligations and legal obligations.

3. Personal Data processing methods

Personal Data is processed using paper, IT and/or digital tools, with organizational methods and logic strictly related to the stated purposes.

In certain cases, persons other than the Data Controller who are involved in the Data Controller's organization (such as personnel-management staff, sales personnel, employees and system administrators) or external parties (such as IT companies, service providers, postal couriers and hosting providers) may access Personal Data. Where necessary, the Data Controller will appoint these parties as Data Processors. They will have access to Users' Personal Data whenever required and will be contractually obliged to keep it confidential.

The updated list of Data Processors may be requested via email at the email address info@surfaceidentity.com.

4. Legal basis for the processing

The User's Personal Data is processed on the following legal bases:

• user's consent for one or more specific purposes
• processing is necessary for the performance of a contract with the User and/or for the performance of pre-contractual measures
• processing is necessary to comply with a legal obligation to which the Data Controller is subject
• processing is necessary for the performance of a task carried out in the public interest or for the exercise of public authority vested in the Data Controller
• processing is necessary for the purposes of the legitimate interest pursued by the Data Controller or by a third party
• processing is necessary for the purposes of the vital interest pursued by the Data Controller or by a third party
• It is always possible to ask the Data Controller to clarify the legal basis of each processing at the following mailing address info@surfaceidentity.com.

5. Place

Personal Data is processed at the Data Controller's operating offices and at any other place where the parties involved in the processing are located. For further information, contact the Data Controller at info@surfaceidentity.com or Via Gorizia 20, 26013 Crema, Italy.

6. Security of processing

Data Processing is performed through adequate methods and tools to ensure the security and confidentiality of Personal Data. The Data Controller has implemented appropriate technical and organizational measures that demonstrably ensure that the Processing complies with applicable law.

7. Period of storage of Data

Personal Data will be stored for the time necessary to perform the purposes for which they have been collected.

In particular, Personal Data will be stored for the entire duration of the agreement, to fulfil related and resulting obligations, to comply with legal provisions, and for defensive purposes.

When the Processing of Personal Data is based on the User's consent, the Data Controller may store Personal Data until that consent is withdrawn.

Personal Data may be stored for a longer period in order to comply with a legal obligation or an order from a public authority.

All Personal Data shall be deleted or stored in a form that does not allow the User to be identified within 30 days from the end of the storage period. After that period expires, the rights to access, rectify, erase and port Personal Data can no longer be exercised.

8. Automated individual decision-making

All collected Data shall not be subject to automated individual decision-making, including profiling, which may produce legal effects concerning the User or may significantly affect the User.

9. Rights of the User

The Users may exercise specific rights with respect to Personal Data processed by the Data Controller. In particular, the User has the right to:

• withdraw their consent at any time;
• object to the Processing of their Data;
• access their Data;
• verify and request the rectification of their Data;
• obtain a restriction of Processing;
• obtain the erasure or removal of their Personal Data;
• receive their Data or obtain its transfer to a different Data Controller;
• lodge a complaint before the supervisory authority for the protection of personal data or start legal proceedings.

In order to exercise their rights, Users may send a request using the Data Controller's contact information indicated in this document. These requests are free of charge and are handled by the Data Controller as quickly as possible and, in any case, no later than 30 days.

10. Data Controller

The Data Controller is Beniamino Ferrari, Via Gorizia 20, 26013 Crema, Tax Code FRRBMN82M11G842O, e-mail info@surfaceidentity.com.

Originally published: 04/03/2021

Last updated: 11/08/2026