Version 1.05 – Last Updated: 01 November 2021
- Client Data: personal data that we collect, process and manage on behalf of our business customers (“Clients”), submitted to the Sam360 applications and related products, integrations, add-ons and extensions services managed and operated by Sam360 (collectively, the “Platform”).
- User Data: personal data concerning our Clients’ authorized individuals who directly engage with the Platform concerning their Sam360 account (“Users”);
- Prospect Data: data relating to visitors of our websites (including www.sam360.com), participants at our events, and any other prospective Client, user or partner (collectively, “Prospects”) who visits or otherwise interacts with our websites, digital ads and content, emails, integrations or communications under our control (“Sites”, and collectively with the Platform – the “Services”).
You may also choose not to provide us with “optional” personal data (i.e. “not required” fields on forms), but please keep in mind that without it we may not be able to provide you with the full range of our Services or with the best user experience when using our Services.
What Type Of Data We Collect
Personal data processed by us has been voluntarily provided by you or may also be acquired by us in the exercise of our business or from third parties.
You are responsible for any personal and /or third party’s information that you share with us and warrant that you have the right to disclose it, discharging us of any liability toward third parties.
The data processed by us, either on its own or through third parties, could be:
- First and last name, the data relating to your education and job; company name, the Personal Data of the legal representative / attorney; address and other elements of personal identification (date of birth, place of birth); demographic information such as postcode; fiscal code; contact information including e-mail, phone number. If you purchase our Services, Billing and communications information (your credit card details and billing address, identification details of banking relationships (such as IBAN) preferences and business interests.
- Personal Data we process on your behalf: If you purchase our Services, you need to provide us information about Services’ users, such as their names and email addresses, their devices and usage of the Services. We use and process this information to provide the Services in accordance with your instructions.
- Personal Data we collect from other sources: We may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us. Examples of the information we receive from other sources include demographic information, device information, location (such as city and state), and online behavioral data.
We do not collect, access or scan any of your organization’s content including, but not limited to:
- Email messages
- Calendar entries
- Contact lists or Address books
- SharePoint documents or content
We do not process neither do we process any “particular” Personal Data, such as, for example, the Personal Data suitable to reveal the state of health, political opinions, religious beliefs, etc.
Legal Basis For Processing
We process Personal Information about you as a data controller as described in this section, where such processing has a legal basis or is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include improving, maintaining, providing, and enhancing our technology, products and services, as well as ensuring the security of the Services.
Additional Data-Processing Purposes
If additional data-processing purposes are added to the above we will let you know prior to process whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information.
Your Personal Data could be processed by a third party acting as separate controller or, if necessary, as Data processor, on our behalf, in a predominantly automated and computerized manner, in order to guarantee security and confidentiality and to prevent unauthorized access to the data themselves. We do not perform automated decision-making, including profiling.
We may need to communicate your Personal Data to third parties belonging to the following categories:
- People involved in technical and organizational activity on our behalf (including payroll activity);
- Subsidiaries, parent companies and affiliates of the Sam360 group, of which Sam360 S.r.l. is a part;
- Business/marketing partner;
- Authorities and in general, subjects, public or private, with functions of public importance;
- External companies and / or professionals that assistance us;
- Third-party companies for processing aimed for promotional initiatives, if you have expressed your consent.
The list of possible subjects to which your Personal Data can be communicated is available at Sam360 or by contacting us at: email@example.com
Your Personal Data could be processed also by our personnel, acting as authorized or System administrator, according to their role in our company.
We will not sell, distribute or lease your Personal Information to third parties unless we have your permission or are required by law to do so. Your Personal Data will not be disseminated.
Retention Of Data
Your Personal Data will be stored for a period of time not exceeding that necessary to achieve the purposes for which it was collected and in any case for the maximum time required by applicable law (for example, a ten-year prescription for civil and administrative/accounting data).
Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data
- Whether the data is necessary to provide our Services
- Whether our Clients have the ability to access and delete the data within their accounts
- Whether our Clients would reasonably expect that we would retain the data until they remove it or until their accounts are closed or terminated
When we have no ongoing legitimate need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
Regarding the processing for marketing purposes, your data will be processed and stored for a reasonable period of time in relation to the interest you have shown towards our initiatives, which we will periodically check, except for your opposition or request for revocation of the authorization to receive commercial communications.
We take appropriate and reasonable technical and organizational measures to protect your Personal Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.
What We Do With Personal Data We Gather
We use your personal data for a variety of purposes including:
- Management of relations with you deriving from the signed contract;
- Compliance with legal obligations;
- Improve our activity and our Services (eg. Detection of the degree of customer satisfaction on the quality of services rendered and on the activity carried out by us, the preparation of studies and market research);
- Inform you with marketing communications about our products and / or services that we think you may be interested in through letters, telephone, advertising material, automated communication systems and in particular, newsletters (subject to your specific, express consent).The provision of personal data by you necessary for the purposes referred to in point a), is not mandatory, but the refusal to supply them may make it impossible for us to provide the Services. Their processing does not require your consent.
The provision of personal data necessary for the purposes referred to in point b) is mandatory and the relative processing does not require your consent. The provision of personal data necessary for the purposes referred to in point c) is not mandatory and the relative processing requires your consent. The provision of data necessary for the purposes referred to in the previous letter d) is not mandatory and their processing requires your consent, freely expressible and modifiable at any time as better described below (“Your rights”).
The European Economic Area (EEA) provides certain rights to data subjects (including access, rectification, erasure, restriction of processing, data portability, and the right to object and to complain). We undertake to provide you the same rights no matter where you choose to live.
As available and except as limited under applicable law, the rights afforded to individuals are:
- Right of Access (the right to be informed of and request access to the Personal Data we process about you);
- Right to Rectification (the right to request that we amend or update your Personal Data where it is inaccurate or incomplete);
- Right to Erasure (the right to request that we delete your Personal Data);
- Right to Restrict (the right to request that we temporarily or permanently stop processing all or some of your Personal Data);
- Right to Data Portability (the right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s service);
- Right to Object (the right, at any time, to object to us processing your Personal Data on grounds relating to your particular situation);
- Right to object to your Personal Data being processed for direct marketing purposes;
- Right not to be subject to Automated Decision-making (the right to not be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect);
- Right to lodge a complaint with the Guarantor in the event of a breach in the processing of data pursuant to art 77 of Regulation 2016/679;
- Right to appeal to the courts in the event of unlawful processing of the data, even against the acts undertaken by the Guarantor pursuant to art 78 of Regulation 2016/679.
If you have previously opted in to our marketing emails, you can opt out at any time by clicking the “unsubscribe” link at the bottom of our marketing messages. Also, all opt-out requests can be made by emailing us using the contact details firstname.lastname@example.org
If you decide to withdraw your consent, we may continue to send you non-promotional communications, unless you decide to unsubscribe from the contact list. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and you cannot opt out of these messages unless you cancel your account.
If you have any questions or concerns about your rights regarding the use of your Personal Information, please contact us at: email@example.com. We will reply as soon as possible after verifying your identity.
This Cookies Policy explains how we use cookie to collect your Personal Data when you visit our website www.sam360.com and how you can exercise your privacy rights.
We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. If you do not agree with the content of this Policy, then please remember it is your choice whether to use our website.
What Are Cookies?
We use third party analytics service to identify which pages are being used. This helps us to analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can find third party documentation here below:
- Google Analytics: Is a web analytics service provided by Google, Inc. (“Google”). The information generated by the cookie on the website’s use (including IP address) is collected by Google and filed with Google servers in the United States. Google will use this information to track and review website usage, compile website activity reports, and provide other website activity services: https://policies.google.com/privacy https://tools.google.com/dlpage/gaoptout
With your consent, which is free and optional, we may use third-party profiling cookies, that are cookies designed to create user profiles for remarketing purposes, to promote advertising based on preferences expressed by you in navigation within the website. These data are collected and processed using the following services:
- AdWords Remarketing (Google Inc.): AdWords Remarketing is a marketing service provided by Google Inc. It connects the activity of www.example.com with the Adwords advertising network and the Doubleclick Cookie. You can opt out of the cookie tracking here: https://support.google.com/ads/answer/2662922?hl=en
How To Manage Cookies
You can choose to accept or decline cookies.
Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.
You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. Please check with support for your specific browser for instructions.
You can delete or block these cookies, but this may prevent you from taking full advantage of the website.
Links To Other Websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.