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.

Owner, purpose and legal basis of operation

Hubenture S.r.l. (hereinafter, Hubenture), with registered office in via Bonazzi n. 2, 40013 Castel Maggiore (BO), in the person of its Legal Representative pro tempore, e-mail [email protected], is the Owner of operation of the personal data of users collected when using the services of the Site.  

Hubenture will process the personal data it comes into contact with in accordance with the principles of lawfulness, fairness and transparency as well as the provisions of the law and regulations for the following purposes:

1. Inquiries;
2. Utopia Community Membership;
3. Utopia Newsletter Subscription;
4. Subscription to the Utopia Blog;
5. Registration and access to Utopia.
6. Registration for events and webinars  

The use of personal data for site access and browsing activities involves operation data to execute measures taken at the request of the data subject, which is the legal basis that legitimizes operation.  

The use of personal data to manage the further processes of operation, with an indication of the specific legal bases of operation, are described in the section of this privacy policy devoted to the principles applicable to operation of data by Hubenture.

Data Protection Officer (RDP-DPO)

The Data Protection Officer (DPO) can be reached at: ‍DilaxiaS.p.A. - Data Protection Officer, via Bonazzi, 2 - 40013 Castel Maggiore (BO), e-mail: [email protected].

Place of operation data

The operations related to the web services of this Site take place at the aforementioned registered office of the Owner and at the hosting company providing the service, with servers located in the EU.

Categories of data processed

Navigation data

The computer systems and software procedures used to operate this website acquire, in the course of their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.

This category of data includes IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses 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 in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the user's operating system and computer environment.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of computer crimes against the site or the Owner: except for this eventuality, at present, data on web contacts do not persist beyond the terms of the law.

Data voluntarily provided by the user

The optional, specific and voluntary sending of electronic mail to the addresses indicated in this site entails the subsequent acquisition of the sender's address by Hubenture, necessary to respond to requests, as well as any other personal data included in the communication.

Specific privacy policies summaries will be given or displayed on the pages of the site set up for particular on-demand services.

Personal Data

Through the features within Hubenture's website, you may grant certain of your personal information that may make you identifiable and which may be processed in order to handle, for example, your requests.

Principles applicable to operation data by Hubenture

Hubenture will treat users' personal data lawfully, fairly, and transparently.  

The Owner will collect personal data from users and process them only for the purposes set forth in this Privacy Policy and in a manner that is not incompatible with those purposes.  

Data processed by Hubenture are adequate, relevant, and limited to what is necessary for the purposes for which they are processed, including:

1- Inquiries.

The Data Controller will process the personal data of users who request information regarding initiatives, projects, products or services offered by Hubenture in order to manage, feedback and provide what has been requested by the interested party. The data will be recorded, kept and used to give feedback to the requests of the interested parties and for the time necessary to achieve the mentioned purpose.  

The legal basis of operation is the execution of pre-contractual measures taken at the request of the data subject (Art. 6(1)(b) EU Reg. 2016/679).

2- Utopia community membership

The Data Controller will use the user's personal data (first name, last name and email address) to enable the data subject's registration in the Utopia Community. The legal basis for this operation is the execution of pre-contractual measures taken at the request of the data subject (Art. 6(1)(b), EU Reg. 2016/679). The provision of personal data for this purpose is optional; however, failure to provide, inaccurate or partial provision of data may result in the data subject being unable to register with the Utopia Community. For this purpose and in the absence of further legal retention obligations for the Data Controller, the data will be processed for as long as the data subject is enrolled in the Community and for at least 5 years after unsubscribing.

3- Promotional activities and privacy policy (direct marketing)

Subject to the consent of the interested party exercised by means of the appropriate tick on the data collection form, Hubenture will process the user's personal data (personal and contact details) to send communications, including in the form of newsletters, pertaining to the initiatives, projects, products or services offered by Hubenture and the related data will be recorded, kept and used exclusively for sending communications to promote the activities, initiatives and projects promoted by the Owner.

The legal basis for this operation is the consent of the data subject (Art. 6(1)(a), GDPR).

The provision of consent for this purpose is optional and the data will be processed until consent is revoked by the data subject exercisable at any time (by clicking unsubscribe at the bottom of the communication received or by written request to the email address[email protected]).

4- Subscription to the Utopia blog

Subject to the consent of the data subject, Hubenture will process the user's personal data (first name, last name and email address) in order to allow the user to download free material (e.g., infographics) made available by the Utopia Team as well as to stay in touch with the data subject by sending communications aimed at illustrating the potential and functionalities of Utopia, sharing news and novelties from the Utopia Blog as well as sending informative material and/or promotional communications. The legal basis for this operation is the consent of the data subject (Art. 6 lett. a) EU Reg. 2016/679). The provision of data and consent for this purpose is optional and the data will be processed until the withdrawal of consent by the data subject exercisable at any time, through the unsubscribe function or by request to the address [email protected]

5- Registration and access to Utopia

Hubenture will process the personal data of the user who fills out the form for registration and access(sign up) to SaaS Utopia to enable the use of the application through the functionalities provided by the Free Trial version. The legal basis that makes this operation lawful is the fulfillment of the contract or, as the case may be, the execution of pre-contractual measures taken at the request of the data subject (Art. 6, par. 1 lett. b) EU Reg. 2016/679). The data will be processed for the time strictly necessary to carry out the individual activities of operation. However, Hubenture may retain the data for a longer period of time to fulfill specific obligations established by Regulations and/or laws in force and to which the Data Controller is subject.

Hubenture will process personal data of users who register and access Utopia for:

• 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;
• Receive periodic communications with informative content such as, by way of example but not limited to, on the release of new features, tutorials for the use of the application and articles regarding the reference legislation as well as commercial communications and/or customer satisfaction (art. 6 lett. f) and Recital 47 EU Reg. 2016/679, art. 140, c. 4, Legislative Decree 196/2003). Data subjects are informed that the Data Controller has assessed the lawfulness of this operation (Legitimate Interest Assessment) by balancing its own legitimate interests and those of the data subjects whose data are the subject of operation, given the risks to their rights and freedoms, the nature, context and purposes of operation.

The provision of data for the purpose in question is optional. However, since operation is necessary to allow access to the Site and/or navigation as a logged-in user 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 restricted area of the Site and use the services reserved for registered Users.

Mode of operation

Personal data are and will be processed, in paper and/or digital form, for as long as is strictly necessary to achieve the purposes and purposes for which they were collected.

There are no operations automated operations on the collected data, including user profiling.  

Specific security measures are observed to prevent data loss, illegal or incorrect use, and unauthorized access.

Transfer of personal data to countries outside the European Union

Personal data collected by Hubenture are processed and stored within the territory of the European Union. Some personal data may be subject to transfer to recipients located outside the European Economic Area. In this case, the transfer will take place in compliance with the provisions of Chapter V of the EU Regulation 2016/679 ("GDPR"); in particular, the data will be transferred only after signing the Standard Contractual Clauses approved by the EU Commission by Decision No. 2021/914/EU or to countries able to guarantee an adequate level of protection of personal data and recipients therefore of an Adequacy Decision adopted by the EU Commission.

Categories of individuals to whom the data may be disclosed (recipients)

The data may be communicated to all persons to whom the right of access to such data is recognized by virtue of regulatory provisions; to collaborators or employees of the Data Controller, authorized to process the data as part of their duties and activities; and to all natural and/or legal persons, public and/or private, when the communication is necessary or functional for the pursuit of the purposes indicated in this privacy policy.

Rights of data subjects

Interested users of the Site have the right, pursuant to Articles 15-22 GDPR, to:

• Request for access to personal data: You have the right to obtain from the Data Controller of operation confirmation as to whether or not there is a operation of personal data concerning you and, if so, access to that data. Access may be directed to obtain the following information:  
  1. The purposes of operation;
  2. The categories of personal data in question;
  3. The recipients or categories of recipients to whom the data have been or will be disclosed, particularly if destined for third countries or international organizations;
  4. The retention period of personal data or the criteria used to determine this period;
  5. The existence of the right to request from the Data Controller the rectification or deletion of data or the restriction of operation or opposition to the same;
  6. The existence of automated decision making. ‍
• Request for rectification of personal data: the data subject has the right to obtain rectification of inaccurate personal data concerning him or her, as well as to obtain supplementation of incomplete personal data.
• ‍Requestfor deletion of personal data: for the reasons stated in Article 17 GDPR, the data subject has the right to request from the Data Controller of operation the deletion of the data without undue delay and the Data Controller has the obligation to delete the personal data of the data subject, provided that there is no ex lege retention obligation on the data.
• ‍Requestfor Limitation of operation data: in the event that one of the cases referred to in Article 18 GDPR occurs, the data subject has the right to request the limitation of operation data concerning him or her.
• ‍Requestfor data portability: the data subject has the right to receive in a structured, commonly used and readable format, personal data concerning him or her provided to a Data Controller and has the right to transmit such data to another Data Controller at operation if the operation is based on consent, on a contract, or is carried out by automated means.
• ‍Requestto object to operation: Data subjects have the right to object to operation of personal data concerning them at any time, for reasons related to their particular situation.
• ‍Withdrawal ofconsent: the data subject has the right, at any time and as easily as he or she gave it, to withdraw consent to operation of his or her personal data.  

The data subject also has the right to file a complaint with the Italian Data Protection Authority(www.garanteprivacy.it).  

Requests for the exercise of the above rights by the data subject may be forwarded to. [email protected]