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Privacy & Terms

Information and request for consent pursuant to and for the purposes of articles 13 and 14 of Regulation (EU) 2016/679

1. Data Controller

The data controller is Ummy s.r.l. Benefit Company, hereinafter Qomprendo, with registered office in Corso Castelfidardo, no.30/A Turin, Italy, 10029 in the person of the Legal Representative. The Data Controller can be reached at the address

2. Purpose of processing

Your data will be processed:

  1. Without your express consent (art. 6 GDPR) for the following service purposes:

    • conclude contracts for the services of the Data Controller;

    • fulfil pre-contractual, contractual and fiscal obligations arising from relations with you in place;

    • comply with obligations established by law, regulation, community legislation or an order from the Authority;

    • exercise the rights of the Data Controller, for example the right to defense in court;

    • for the management of requests for information from users through the sending of emails and other contacts via form.

  2. Only with your specific and distinct consent (art. 7 GDPR), for the following purposes:

    • Send you via email, newsletters, commercial communications and/or advertising material about products or services offered by the Data Controller.

3. Method of Treatment

The personal data of users are treated with appropriate security measures; these measures are useful to prevent disclosure, modification, or other unauthorized uses. In addition to the Data Controller, other authorized parties may have access to the Personal Data and any third parties duly designated by the Data Controller.

4. Consequences of Data Refusal

Nature of the data provision and consequences of the refusal to respond.

The provision of data for the purposes set out in point 2.1 is mandatory. In their absence, we will not be able to guarantee the related services.

The provision of data for the purposes set out in point 2.2 is instead optional. You can therefore decide not to provide any data or subsequently refuse the possibility of processing for such purposes data already provided; in this case, you will not be able to receive newsletters, commercial communications, and advertising material related to the services and products offered by the Data Controller. You will still be entitled to the services referred to in point 2.1.

5. Retention Period

All personal data provided will be processed in compliance with the principles of lawfulness, fairness, relevance, and proportionality, only with the modalities, including computer and telematic, strictly necessary to pursue the purposes described above.

In any case, personal data will be kept for a period not exceeding that strictly necessary to achieve the purposes indicated. Therefore:

  • Personal Data collected for the management of requests will be stored for a term of 24 months;

  • Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the completion of this contract;

  • Personal Data collected for purposes attributable to the Data Controller's legitimate interest will be retained until the satisfaction of this interest. The User can obtain further information about the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller;

  • The Data Controller may be required to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority;

  • Personal data collected for marketing purposes will be stored for 24 months.

  • At the end of the retention period, the Personal Data will be deleted or made anonymous. Therefore, at the expiration of this term, the right of access, cancellation, rectification, and the right to data portability can no longer be exercised.

6. Data Communication

Without the need for express consent (Art. 6 GDPR), the Data Controller may communicate your data for the purposes set out in point 2.1 to Supervisory Bodies and/or Judicial Authorities as well as to all other subjects to whom communication is mandatory by law for the performance of the aforementioned purposes. Your data will not be disseminated.

7. Data Transfer

Your data will not be transferred outside the European Union. However, it should be understood that the Data Controller, if necessary, will have the ability to transfer data to the European Union and/or non-EU countries. In such cases, the Data Controller ensures that the data transfer outside the EU will comply with the applicable legal provisions, stipulating, if necessary, agreements that ensure an adequate level of protection and/or adopting the standard contractual clauses provided by the European Commission.

8. Rights of the Data Subject

Under Articles 15 and following of the Regulation, you, as a data subject, have the right to ask the Data Controller for:

  • the right to information, communication and transparency (Articles 12, 13 and 14, Article 1 Dl 104/2022);

  • access to your personal data (Article 15); \r\n- the correction or deletion of your data or the restriction of processing related to you (Articles 16, 17, 18);

  • to object to processing (Article 21);

  • data portability (Article 20); \r\n- if the processing is based on Article 6(1)(a) or Article 9(2)(a) of the Regulation, to withdraw your consent at any time without affecting the lawfulness of processing based on consent given before the withdrawal.


Without prejudice to any other administrative or judicial remedy, the data subject who believes that the processing of his or her data infringes the GDPR has the right to lodge a complaint with a supervisory authority, particularly in the Member State where he or she habitually resides, works or where the alleged infringement occurred, pursuant to Article 77 of the Regulation (the Italian supervisory authority is the Guarantor for the protection of personal data).

To exercise the above rights, the data subject may contact the Data Controller at the contact details provided in point 1 of this notice.

9. How to Exercise Rights

To exercise the User's rights, Users can direct a request to the contact details of the Owner indicated in this document. The requests are filed for free and processed by the Owner as quickly as possible, in any case within one month.

10. Changes to This Privacy Policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if technically and legally feasible, by sending a notification to Users through one of the contact details the Owner has. Please therefore regularly check this page, referring to the date of the last modification indicated at the bottom.

Last edited on March 27, 2023

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