BE A BUSINESS SPA s.r.l. PROCESSING OF PERSONAL DATA 

Comprehensive Privacy Information Document pursuant to art. 13, D.Lgs. 196/2003

Be A Business SPA s.r.l., V.A.T. Code 03289980363, with legal office in Modena, Strada Gherbella 294/b, (“Be A Business SPA”) respects and protects the right to privacy and personal identity of anybody who, in any moment, goes to www.beabusinessspa.com (“Website”). For this reason, Be A Business SPA particularly cares about personal data processing. This information document ("Information Document"), drafted pursuant to art. 13 of Leg. Dec. 196/2003 (Code regarding the protection of personal data - hereinafter "Code") is aimed at anyone who may communicate their data to Be A Business SPA and, but not limited to, using the Youspa web services which can be accessed from this Website ("Users"). 

This Information Document regulates the ways in which Be A Business SPA gathers, stores, uses, communicates or processes in any other way, all the personal data gathered from the Users.

The phrase "Personal Data" refers to any information concerning a natural person, who is identified and identifiable, even indirectly, through the reference to any other information, including a personal identification number (art. 4 par. b, Code). 

Be A Business SPA may periodically modify, complement or update this Information Document, even considering any potential change in the applicable law or by the Italian Data Protection Authority ("Authority"). The modifications and the updates to the Information Document are implemented and made public to the involved subjects by being published in the website. Hence, every User is invited to check the Website periodically to read the possibly updated Information Document. 

Hypertext links

In the Website there are links to third-parties' websites ("Links") which are deemed interesting for the User and regarding the web services offered by Be A Business SPA. By clicking those links, the User freely decides to enter the third-party owned Website. The information contained in such websites is independent and beyond Be A Business SPA control. Be A Business SPA takes no responsibility in this regard, neither concerning the processing of Personal Data which may occur in such circumstances. Hence: (i) Be A Business SPA takes no responsibility nor gives any guarantee on the nature and the contents of any third-parties' website connected to this Website through links; (ii) this information document cannot be applied to and is not related to the processing of personal data by other websites, even if they are visited by the User through Links; (iii) connection to third-parties' websites is the sole responsibility of the Users.

Data collection

Be A Business SPA perfectly knows the relevance of an informed circulation of Personal Data and, consequently, the importance of an informed consent by the User. Therefore, without the previous specific consent of the User, Be A Business SPA will not gather any information which may allow for the identification of individual Website visitors, nor will make use of any technology aimed at identifying an individual User.

The Users' Personal Data processed by Be A Business SPA ("Data Processing") stored on Be A Business SPA‚Äč or partner-owned servers, as specified hereunder, can be collected in different ways, more precisely:

  1. directly supplied by the User : these are all Personal Data entered in the Website (to browse or, in general, for any other reason) or however directly provided to Be A Business SPA by the User in any other way. Any User, within the restrictions of law, may decide to deny the processing of the whole or part of its Personal Data, even though this exclusion may limit or deny the use or the supply of some Be A Business SPA services. In any case, if Personal Data are voluntarily provided by the Users, the Website keeps the information envisaged by Law on the correct Processing of Personal Data;
  2. provided by third parties: Personal Data collected by Be A Business SPA from other sources (postal services companies, forwarders, data entry companies, etc.) to carry out its services. Also in this case, any User, within the restrictions of law, may decide to deny the processing of its Personal Data, even though this exclusion may limit or deny the supply of some Be A Business SPA services;
  3. automatically collected: Personal Data gathered automatically with the use, and not limited to, of the so called "cookies" (as specified in the following paragraph). These data are usually related to User browsing. During their regular operations, the IT systems and software for the functioning of the website collect some Personal Data, whose transmission is implicit in the use of communication and internet protocols. In general, these kinds of information are not gathered to be matched with identified Users, however, for their own nature, they could allow the identification of Users through processing and queries with data held by third parties. This Personal Data category includes IP addresses, Domain Name Service, computers used by Users browsing the website, URI (uniform resource identifier) addresses of the queried resources, time of query, the method used to submit the query, the size of the file in return, the reply code given by the server identifying the status of the query (completed, error, etc.) and other parameters related to the Operating System and the User IT environment. These Personal Data are mainly used to acquire statistic information on the use of the Website and to control its correct functioning. Data can also be used to ascertain responsibilities in case of possible IT crimes against the Website.

Cookies

Through its Website, Be A Business SPA uses some cookies in order to make the browsing experience as close as possible to the needs and the wishes of the Users, as well as in order to make web contents more usable by the Users. Thanks to cookies, we can guarantee a faster and easier browsing of the Website. For instance, cookies are small text files containing an "information package", which the Website sends to the User device (usually to its browser), where they are stored to be transmitted again to the Website during the same session or in following visits of the same User. In general, cookies give a single number to the User; however, this number has no significance outside the Website in which it was assigned. Cookies can be stored just for the time of use of a given website (session cookies) or for a longer time required by the session (persistent cookies).

Usually, cookies allow Be A Business SPA to see which are the most visited or viewed sections or contents of the Website in order to adapt these to the needs of the Users and, at the same time, to improve the service offered also, but not limited to, established a custom-tailored communication with Users and their interests.

In addition to making the browsing experience easier and user-friendly, Be A Business SPA uses cookies to: i) identify the User when he logs-in to the Website; ii) avoid malicious use of Users' accounts; iii) if authorized, record Users' preferences and obtain a Website and/or customized communications; iv) if authorized, send promotions, contents and advertising related to the User and its preferences and to store such preferences; v) perform market or statistic studies.

Even if the majority of browsers automatically accepts cookies, the Website can be visited even by disabling all kinds of cookies. However, disabling some of the cookiesfrom the User's browsers may limit, or partly exclude, the functions of the Website and its correct browsing. 

The cookies used by the Website - listed hereunder - may be activated or deactivated by the Users modifying cookies settings in this section, which can be accessed from the banner on the Website. However, even if Users fully agree on the use of cookies, they can, in any moment, erase all stored cookies by operating on their own browser.

The types of cookies employed by the Website (ticking the category, the use of the related cookies will be excluded) are:

   Cookies that are needed for browsing; 
   Cookies that are functional for browsing;
    Google Analytics cookies;
    Cookies for marketing.


Cookies that are needed for browsing

These cookies are required for the proper operations and visit of the Website, allowing the User to browse it with basic functions. These cookies do not gather information on the Users which may be used for marketing purposes. Inter-alia, necessary cookies are needed to: (i) remember User's data in different pages during browsing; (ii) view the contents in the chosen language during any access, recognizing which nation the User is from (and remembering this setting for future accesses). The acceptance of the necessary cookies is an essential condition for the correct use of the Website. Blocking them may impede or seriously hinder the Website browsing experience.

Cookies that are functional for browsing

These cookies allow Be A Business SPA to make the User much more comfortable while using the Website. They allow to: (i) identify the Users logging-in to the Website, avoiding the new entry of data at any new browsing session; (ii) store the results of the researches performed by the User in the Website. These cookies are not essential to browse the Website but aim at facilitating and streamlining its use.

Google Analytics cookies

Be A Business SPA uses the web analysis service provided by Google, Inc. to monitor, in an anonymous and aggregated way, the statistical analysis of Users browsing the Website in order to understand their use and to adapt to it, improving the Website. During the visit, Be A Business SPA automatically gathers and stores the following information concerning the computer and the visit of the User: (i) the domain and the host through which it accesses the Internet; (ii) the Website from which the User connected to the Website, if available; (iii) date and time of connection to Website, duration of connection and which pages were visited; (iv) User's Internet Protocol (IP) Address; (v) the Operating System and browser used by the User; (vi) the anonymous demographic details of Users accessing the Website.

For more information on Google Analytics Cookies, Users can visit the following web pages:

https://www.google.com/analytics/learn/privacy.html?hl=it

The information gathered through Google Analytics cookies do not allow Be A Business SPA to retrace Users' Personal Data on its own. Except in case of specific and declared consent, no information on the personal identity of the Users is gathered. 

For the analysis of statistical data, Be A Business SPA may assign the Website performance assessment to third parties. These third parties are explicitly required to comply with privacy protection regulations, giving Be A Business SPA only aggregated data, using the gathered information just for the purposes set by Be A Business SPA and, subsequently, erase any information. These cookies are not essential for the functioning of the Website, however, since they are processed in an anonymous and aggregated way, they do not harm the User Personal Data privacy. However, they can be deactivated by the User without any consequence on Website browsing.

Cookies for marketing
These cookies allow Be A Business SPA to choose advertising and promotional messages on the Website based on User location (through IP address) or on the preferences set by the User itself on the Website. In particular, this Cookie does not allow Youspa to define an individual profile for each User. These Cookies are not essential to browse the Website but aim at improving the service offered by Be A Business SPA to the Users.

Location, Data processing modality and subjects to whom these data may be communicated

Data processing is usually performed in Be A Business SPA legal office. Within Be A Business SPA, Personal Data are only known to those who are specifically in charge of data processing.

Regardless of gathering modalities, Be A Business SPA is fully aware of the importance of a responsible Users' Personal Data Processing. Hence, Personal Data are processed by Be A Business SPA and/or third parties, which were carefully selected for their reliability and skills and to which data can be communicated when necessary or appropriate in order to carry out activities concerning this information document. Moreover, Personal Data can also be communicated to Be A Business SPA owned and/or related companies, pursuant to art. 2359. However, these companies have a privacy policy which is consistent and compliant with the Be A Business SPA one, as long as it is located in Italy or in a EU Member State. In any other case, except for what envisaged by the Law, Personal Data will not be given and/or communicated to third parties. The full updated list of subjects to which Personal Data can be communicated is available at the Be A Business SPA legal office.

Personal Data are processed in compliance with the obligations and the guarantees envisaged by the Code, both in analogue and with IT system by our designated staff (employees or delegated third parties) for the time strictly necessary to achieve the purpose for which they were gathered. Specific security measures were employed to avoid loss of data, malicious or incorrect use. As soon as Personal Data are not needed any longer for the purposes of this Information Document, Youspa proceeds to their deletion, except when the Law envisages storing obligations or the User has agreed for a longer processing or their storage for other purposes.

Processing purposes and nature of consent

The processing purposes of Users' Personal Data are based on the full compliance with correctness, legitimacy and transparency principles. Hence, Be A Business SPA processes Personal Data only for the following purposes:

  1. purposes related to the use of the services offered by Be A Business SPA; 
  2. statistic purposes, market studies, submission of information and advertising materials, notification of promotional initiatives and commercial offers, reception of newsletters and other information services on Be A Business SPA activities;
  3. upon authorization, to define the profile of its Users to customize commercial offers.

The gathering of data for the purpose described under item i) is compulsory for the provision of Be A Business SPA services, while the ones described under item ii) and iii) are not compulsory and the denial only implies the failure to receive news or updates on commercial and promotional initiatives, offers or any other promotional material and/or customized offer.

Communications

All communications and/or materials voluntarily submitted to Be A Business SPA by the Users via e-mail or any other way, including every piece of data, question, remark, suggestion or other, will be treated as a non-confidential and unprotected information, unless otherwise specified or unless the reserved character of the piece of data is evident due to its own nature. Excluding the sole restrictions of the applicable Law, any document sent or submitted will become property of Youspa and can be used for any purpose, including (but not limited to) reproduction, dissemination, transmission, publication and dispatch.

Rights of the interested parties

Pursuant to art. 7 of the Code, every User has the right to obtain the confirmation on the existence of Personal Data concerning them, even if they have not been stored yet, as well as their communication in an understandable way. More precisely, any User is entitled to receive information:

  1. on the origin of Personal Data;
  2. on the purposes and modalities of processing;
  3. on the ways in which IT and electronic tools process data;
  4. on the identity of the Data Controller, data supervisors (or the person in charge of the processing pursuant to article 5, section 2 of the Code);
  5. on the subjects or categories to whom personal data may be communicated or who may get to know them as person in charge of the processing in the State territory, as data supervisors or controllers.

Moreover, any User is entitled to obtain:

  1. the update, the correction or, if interested, the integration of data;
  2. the deletion, the transformation in anonymity or the block of data processed against the law, including those for which storage is not needed for the purposes for which these data were gathered and then processed;
  3. the declaration that the operations under items i) and ii) were brought to the knowledge, even regarding their content, to those who these data were communicated or disseminated to, except in the case this becomes impossible or entails the use of disproportioned resources in comparison with the protected right.

The User has the right to fully or partly oppose: 

  1. for legitimate reasons regarding the processing of personal data concerning them, even if they are related to the gathering purpose; 
  2. the processing of personal data concerning them, aiming at the submission of advertising or direct sales material, as well as market researches or marketing communication.

Finally, the User has the right, in any moment, to revoke the previously granted consent for the processing of Personal Data.

The requests under the previous items must be directed to the Data Processing Controller (described in the following paragraph) via e-mail at info@bbspaweb.com, or by ordinary post or registered mail with return receipt to the operational office in Strada Gherbella 294/b – 41126 Modena (MO).

Data Controller

The data controller is Be A Business SPA S.r.l., VAT Code 03289980363, with legal office in Modena, Strada Gherbella 294/b. 

The updated list of all Data supervisors (if appointed) can be found in the aforementioned Be A Business SPA legal office.