Privacy Policy
privacy policy On operation of web users' personal data in accordance with Regulation (EU) 2016/679
In this privacy policy, made in accordance with the provisions of Articles 13 and 14 of the EU Regulation 2016/679 (hereinafter, GDPR) and Legislative Decree No. 196/2003 and subsequent amendments and additions, we describe the operations performed on the personal data of users collected when using the services provided on the website https://www.utopiathesoftware.com/ (hereinafter, the Site) and not also for other websites that may be consulted by the user through links on the Site.
The operation tion of your personal data will be guided by the principles of fairness, lawfulness, transparency, purpose and storage limitation, data minimization, accuracy, integrity, and confidentiality, as well as the principle of accountability set forth in Article 5 of the Regulation. Your personal data will therefore be processed in accordance with the provisions of the Regulation and the confidentiality obligations set forth therein.
By “ operation ” of personal data, we mean any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or any other form of making available, alignment or combination, restriction, erasure, or destruction.
Owner, purpose and legal basis of operation
Hubenture S.r.l. ( hereinafter, “Hubenture”), with registered office at Via Bonazzi No. 2, 40013 Castel Maggiore (BO), represented by its current Legal Representative, email privacy@hubenture.com, is the Data Controller for operation and for the personal data of users collected when they use the Website’s services.
Data Protection Officer (RDP-DPO)
The Data Protection Officer (DPO) can be reached at the following email address : dpo@hubenture.com
Categories of data processed
Data voluntarily provided by the user
The Site offers users the opportunity to voluntarily provide personal information through, for example, registration via contact forms, requests for services, information, or quotes, and the optional, explicit, and voluntary sending of emails to the addresses listed on the Site, etc. This Privacy Policy also applies to the operation of Personal Data voluntarily provided through the Site.
Specific privacy policies summaries will be given or displayed on the pages of the site set up for particular on-demand services.
Third-party data voluntarily provided by the user
When using certain services on the Site, there may be a operation of third-party Personal Data that you submit to the Data Controller. In such cases, you act as the independent data controller of the operation, assuming all legal obligations and responsibilities. In this regard, you hereby grant the broadest possible indemnification against any dispute, claim, or request for damages from operation, etc., that may be brought against the Data Controller by third parties whose Personal Data has been processed through your use of the Website’s features in violation of applicable Personal Data protection laws.
In any case, should you provide or otherwise process Personal Data belonging to third parties while using the Site, you hereby guarantee—and assume all related liability—that such specific instance of operation is based on an appropriate legal basis pursuant to Article 6 of the Regulation, which legitimizes the operation of the data in question.
Data and Metadata for the Simple Electronic Signature Service
Data and metadata related to the use of simple electronic signature features, including user identification data, contact information, information about the account used, the date and time of the transactions performed, and additional technical evidence associated with the electronic signature process.
Purpose, legal basis, and whether the operation
Your Personal Data will be processed, using both automated and non-automated means, for the following purposes and on the relevant legal bases, where applicable.
1- Requests for Information and Product Demos
The Data Controller will process the personal data of users who request information regarding the initiatives, projects, products, or services offered by Hubenture and/or request a demo, in order to manage, respond to, and fulfill the data subject’s request, including by contacting them using the contact information provided (e.g., email or phone).
The legal basis for operation is the implementation of pre-contractual measures taken at the request of the data subject (Art. 6, para. 1, subparagraph b) of EU Regulation 2016/679). The provision of Personal Data for this purpose is optional, but failure to provide such data would make it impossible to activate the requested services or respond to your requests.
2- Promotional activities and privacy policy
Subject to the data subject’s consent, provided by checking the appropriate box on the data collection form, Hubenture will process the user’s personal data (personal and contact information) to send promotional and commercial communications—including via email, telephone, or other means of contact—related to initiatives, projects, webinars, blog content, products, or services offered by Hubenture; such data will be recorded, stored, and used exclusively for sending communications to promote the activities, initiatives, and projects promoted by the Data Controller.
The legal basis for this operation is the data subject’s consent pursuant to Article 6(1)(a) of the GDPR and Article 130, paragraphs 1 and 2, of the Privacy Code (Legislative Decree No. 196/2003).
Consent for this purpose is optional, and the data will be processed until the data subject revokes consent, which may be done at any time (by clicking “unsubscribe” at the bottom of the message received or by sending a written request to theemail addressprivacy@dilaxia.com).
3- Registration and Login to Utopia
Hubenture will process the personal data of the user who fills out the form for registration and access(sign up) to the Utopia SaaS, as well as the personal data of users who have been given access to the software, in order to enable the use of the application through the functionalities provided therein.
Hubenture will also process personal data of users who use Utopia to:
- Allow the user to access the software;
- Maintain and manage the user's account;
- Store user data and information (master and contact data) in the account;
- Allow the user to make to purchase a paid license of the software;
- Executing the license agreement;
- To receive periodic communications containing information such as—by way of example but not limited to—the release of new features, tutorials on how to use the application, and articles regarding applicable regulations and/or customer satisfaction (Art. 6(f)) and Recital 47 of EU Regulation 2016/679, Article 140, paragraph 4, of Legislative Decree 196/2003). Data subjects are hereby informed that the Data Controller has assessed the lawfulness of this operation (Legitimate Interest Assessment) by balancing its own legitimate interests against those of the data subjects whose data are subject to operation, taking into account the risks to the rights and freedoms of the latter, as well as the nature, context, and purposes of operation.
The legal bases that make this operation lawful are the performance of the contract or, as the case may be, the implementation of precontractual measures taken at the request of the data subject (Art. 6, para. 1, subparagraph b) of EU Regulation 2016/679), as well as the legitimate interest of the data controller (Art. 6, para. 1, subparagraph f) EU Regulation 2016/679).
The provision of data for the purpose in question is optional. However, since operation is necessary to allow access to the application and/or the provision of account management and maintenance services, failure to provide the data will result in the inability of the user to register, access the Utopia application and take advantage of the services provided therein.
4- Webinar and Event Registration
Hubenture will process the personal data of users who fill out the online form on the Website to manage the registration process for webinars or events, workshops, and meetings to which the registration form refers, in order to process any requests from the data subject, to send communications necessary for the data subject’s participation in the selected event, to invite the data subject to future events, or to send communications, including periodic ones.
The legal basis for this operation is the implementation of pre-contractual measures taken at the request of the data subject (Art. 6(1)(b) of EU Regulation 2016/679). Providing data for this purpose on operation is optional. However, failure to provide data, or the provision of incomplete or inaccurate data, may make it impossible for the data subject to register for and participate in the webinars promoted by Hubenture.
5- Collecting feedback through surveys and following up with users
Subject to the data subject’s consent, Hubenture may process the user’s personal data for the purpose of collecting feedback on the services offered through surveys, questionnaires, or other satisfaction-survey tools, as well as to contact the data subject regarding the feedback provided.
Providing data for this purpose is optional. The legal basis for operation is the data subject’s consent pursuant to Article 6(1)(a) of the GDPR.
The data will be processed for the time strictly necessary to achieve the aforementioned purposes and, in any case, until the data subject revokes their consent, which may be done at any time using the procedures outlined at privacy policy.
6- Provision of Electronic Signature Services
Hubenture will process users’ personal data to enable users to utilize the simple electronic signature features that may be made available within the platform for the electronic signing, approval, or acceptance of documents managed through Utopia, including activity logs for operation, contracts, and other documents related to privacy compliance management. Hubenture may retain technical records related to the processes of electronically signing, approving, or accepting documents, such as information regarding the user account used, the date and time of the transaction, the status of the process, and additional metadata necessary for the provision of the service and the security of the platform.
The legal basis for the lawfulness of this operation is the performance of a contract at the request of the data subject (Art. 6, para. 1, subparagraph b) of EU Regulation 2016/679).
Providing data for the purpose described above is optional. However, if the data is not provided, the requested service cannot be provided. The data will be processed for the time strictly necessary to achieve the aforementioned purposes.
Transfer of personal data to countries outside the European Union
The personal data collected by Hubenture is processed and stored within the European Union.
Some Personal Data may be transferred to recipients located outside the European Economic Area. The Data Controller ensures that the operation of personal data by these recipients is carried out in accordance with applicable law, in particular where there is an adequacy decision by the European Commission or where appropriate contractual measures, such as approved standard contractual clauses, are in place. Further details, including a copy of the safeguards adopted, may be requested from the Data Controller at operation.
Data Retention
Personal Data processed for the purpose of handling requests for information will be retained for the time strictly necessary to achieve those purposes. In any case, since these are “ operations ” carried out for the provision of services, the Data Controller will process the Personal Data for as long as permitted by Italian law to protect its interests (Art. 2946 of the Italian Civil Code et seq.).
Personal Data processed for the purposes of promotional activities and privacy policy (direct marketing) will be retained until consent is withdrawn.
Personal Data processed for the purpose of subscribing to the Utopia blog will be retained until consent is withdrawn.
Personal Data processed for the purposes of registration and access to Utopia will be retained for the time strictly necessary to carry out the individual activities of operation. Hubenture may, however, retain the data for a longer period to comply with specific obligations established by applicable regulations and/or laws to which the Data Controller is subject.
Personal Data processed for the purpose of registering for webinars and events will be retained for as long as necessary to achieve the aforementioned purposes, up to a maximum of 10 years from the date of collection.
Categories of individuals to whom the data may be disclosed (recipients)
Your Personal Data may be shared, for the purposes set forth in the section above, with (the “Recipients”):
1. entities that typically act as data processors ( operation ), namely: i) individuals, companies, or professional firms that provide assistance and advice to the Data Controller on administrative and legal matters related to the provision of services; ii) entities with which it is necessary to interact for the provision of services (e.g., hosting providers); iii) or parties delegated to perform technical maintenance activities (including the maintenance of network equipment and electronic communications networks);
2. individuals, entities, or authorities to whom it is mandatory to disclose your Personal Data pursuant to legal provisions or orders from authorities, or in the event of reports of abuse, in order to investigate complaints and identify the source of messages received from users;
3. Persons authorized by the Data Controller to process Personal Data operation necessary to carry out activities strictly related to the provision of services, who have committed to maintaining confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of the Data Controller).
Rights of data subjects
Pursuant to Articles 15 et seq. of the Regulation, you have the right to request from the Data Controller, at any time, access to your Personal Data, to have it corrected or erased, or to object to its operation . Pursuant to Article 21 of the Regulation, you have the right to request the restriction of operation in the cases provided for in Article 18 of the Regulation, as well as to obtain your Personal Data in a structured, commonly used, and machine-readable format in the cases provided for in Article 20 of the Regulation.
Requests by the data subject to exercise the above-mentioned rights may be submitted to privacy@hubenture.com
In any case, you always have the right to file a complaint with the competent supervisory authority (the Italian Data Protection Authority), pursuant to Article 77 of the Regulation, if you believe that the operation of yourPersonal Data violates applicable law.
Changes
The Data Controller may modify or simply update this Website’s Privacy Policy, in part or in full, including in response to changes in the laws and regulations governing this matter and protecting your rights. Such changes and updates to the Privacy Policy will be posted on the Website’s home page. We therefore encourage you to visit this section regularly to review the most recent and up-to-date version of this Privacy Policy so that you are always informed about the information we collect and how we use it.
