Privacy information pursuant to Regulation (EU) 2016/679 on protection of personal data

1. Object

This information (“Privacy Policy”) is provided pursuant to articles 13 and 14 of Regulation (EU) 2016/679 (the "GDPR") in order to inform you about the processing of your personal data (the "Personal Data") carried out in the context of interaction with the services of the Do It Now group (*) (hereinafter, "DIN Group"), for example in the context of browsing the website https://www.supermoneydigital.eu (the "Supermoney Site") or on third-party sites that have installed tracking tools of the DIN Group (together with the Supermoney Site, the "Sites"), or provided over the telephone to representatives of the DIN Group, also acting on behalf of third parties.

2. Data Controller, Joint Data Controllers and Data Protection Officer

The Data Controller is Digital SM LTD, VAT 392 6307 81, with registered office in 162-168 Regent Street (Room 252-254), Linen Hall, London. For any information on the processing of Personal Data as well as for the exercise of your rights, you can contact the data protection officer designated by the Data Controller pursuant to art. 37 of the GDPR (the "Data Protection Officer” o “DPO"). You may, at any time, contact the Data Protection Officer at the following email address: dpo@supermoney.it.

3. Type of Personal Data

The Personal Data covered by this Privacy Policy may have different nature and origin. It is possible that in the past you have authorized third parties to provide us with your Personal Data for business contact purposes. You may also provide information by filling in forms on the Sites (e.g. registration forms, form for comparing quotes or loans, etc.). Furthermore, the computer systems and software procedures used to operate the Sites automatically acquire certain information, such as your IP address or other parameters relating to your operating system. This is information which, by its nature, could, through processing and association with other data, allow your identification. Finally, if you express your consent, we could enrich and profile your Personal Data by observing the interaction you have with the Sites or with third-party services over time, through cookies and other digital tracking tools authorized by you. The Personal Data processed in the context of one or more of the activities described above are personal data, contact details (e.g. email address, mobile phone, etc.), relating to the electronic devices you use, your consumption and navigation preferences, your location etc.

4. Purpose and legal basis of the processing

Personal Data is processed:

  1. to guarantee the use of the services requested by you through the Supermoney Site and to answer promptly and correctly to your requests for information and assistance pursuant to art. 6(1) lett. b) of the GDPR. For example, if you complete the form for comparing estimates on the Supermoney Site, the Data Controller may directly process your Personal Data or may communicate some of your Personal Data, including your telephone number, to partners both for the formulation of the estimates and for the provision of a consultancy service, also by telephone, in relation to these estimates, which is part of the service requested by you through the Site; to offer you the best support, if you make a request for a comparison of quotes on the Supermoney Site during public holidays, this consultancy service could be provided, also by telephone, at the same time as your request for a comparison or in the following seventy-two hours;
  2. to fulfill legal obligations to which the Data Controller and/or the other companies of the DIN Group are subject, for example in the accounting and tax fields, in accordance with art. 6(1), lett. c) of the GDPR;
  3. to satisfy the legitimate interest of the Data Controller in guaranteeing the security and correct functioning of the Sites, or for administrative-accounting purposes of the Data Controller or the DIN Group, in accordance with art. 6(1), lett. f) of the GDPR;
  4. To assert or defend a right in court or in a preparatory phase for the trial, pursuant to art. 6(1), lett. f) of the GDPR.

Exclusively with your specific, free and informed consent, pursuant to art. 6(1), lett. a) of the GDPR, the Data Controller may:

  1. enter and/or enrich your Personal Data over time within its commercial database, using monitoring tools on electronic communication networks including cookies, tags, and other tools, in order to know your preferences, needs and habits consumer and professional and, more generally, to carry out profiling activities;
  2. contact you, through automated tools (e.g. automated calls, text messages, push notifications, emails, instant messaging apps, messages on social networks) and non-automated tools (e.g. telephone with operator, paper mail) to update you on the offers of products and services of the Owner and/or third parties, as well as to carry out market surveys;we inform you that you may, at any time, express your wish to receive commercial and promotional communications exclusively through traditional means of contact by sending your request to the channels mentioned in paragraph 2;
  3. send you the DIN Group newsletter to promote Supermoney services or DIN Group services, editorial content from Blasting News as well as third-party products and/or services. You can, at any time, revoke the specific consent given and decide not to receive the DIN Group newsletter using the appropriate function in the footer of the emails;
  4. communicate the Personal Data, including profiled Personal Data, to other companies of the DIN Group or to business partners belonging to various categories, including in particular, to financial companies, financial agents, credit brokers, banks, insurance companies, insurance intermediaries, fixed and mobile telephony, ADSL and fiber suppliers, suppliers of energy, electricity, gas, new downstream products and services, television services, customer care services and sales outside and inside commercial premises ( contact center, door to door, mall point, flagship), publishers, media centres, pharmaceutical companies, healthcare companies, car manufacturers, car dealerships, car dealers, subjects operating in the hospitality and catering sector, in the world of culture and sports, information and marketing, companies active in direct marketing and list brokerage, companies operating in the management of events (all together, the "Main Recipients"). These subjects will process the Personal Data for their own commercial contact purposes through automated means (e.g. automated calls, text messages, push notifications, emails, instant messaging apps, messages on social networks) and non-automated means (e.g. telephone with operator, paper mail ). The list of third parties to whom your Personal Data may be disclosed on the basis of your specific consent is available at the following link: https://www.supermoneydigital.eu/en/privacy/partners/;
  5. communicate Personal Data, including profiled Personal Data, to third parties other than the Main Recipients and, in particular, to suppliers of consumer goods and services and, in general, of goods and services relating to the care and well-being of the person and to world of fashion, to entities operating in the field of design and development of interior spaces, to political parties, trade union organizations and third sector entities, to non-profit and non-profit associations, to both public and private research organizations and companies, to commercial distributors, communication agencies, distributors of newspapers, periodicals and books, subjects operating in the food and wine, alcoholic and non-alcoholic beverages, food, organic and zero km agriculture fields, suppliers of office materials and services for the company, manufacturers and/or distributors of articles for children, roadside assistance companies, driving schools, entities that issue and renew licenses, entities that deal with the maintenance of cars and motorcycles, tire specialists, suppliers of safety devices, specialist medical services, electrical and burglar alarm systems, subjects operating in the world of data management, digital, technology and the Internet, suppliers of sanitation products, solutions related to the environment, subjects from the world of entertainment, music, cooking and, in general, offering products and services related to the world of hobbies, suppliers of tourist services, subjects operating in the field of betting, games and prize operations, contests and lotteries, subjects linked to the organization of rallies and competitions, to the world of navigation and, in general, to the aquatic world, subjects from the world of photography, gardening, construction, decoration, design, modeling and aeromodelling, real estate agencies, playgrounds, parks entertainment, beauty farms, gyms and fitness clubs, suppliers of food products linked to specific diets (all together, the "Secondary Recipients"). These subjects will process the Personal Data for their own commercial contact purposes through automated means (e.g. automated calls, text messages, push notifications, emails, social networks, instant messaging apps, messages on social networks) and non-automated (e.g. telephone with operator , paper mail). The list of third parties to whom your Personal Data may be disclosed on the basis of your specific consent is available at the following link: https://www.supermoneydigital.eu/en/privacy/partners/.

Subject to your specific consents, your Personal Data may be processed for the purposes referred to in letters f) and g) which also precede Do It Now.
We may also send you emails to promote goods and/or services similar to those you have already purchased on the Sites, without your consent, but without prejudice to your right to object to such communications at any time by contacting the Controller at the addresses indicated in paragraph 2 of this Privacy Policy.

5. Nature of the provision of Personal Data and consequences of any refusal to respond

The provision of Personal Data is optional. However, some Personal Data is necessary in order to allow us to provide the services you have requested and to fulfill the legal obligations to which we are subject. Failure to provide such information will prevent you from using the services offered through the Supermoney Site. Where necessary for the performance of the treatments described in the Privacy Policy, the required consent is free. Failure to provide one or more of the required consents will not prevent you from using the services and products offered through the Supermoney Site.

6. Processing methods

The processing of Personal Data will take place - according to the principles of correctness, lawfulness and transparency - through IT, manual and/or telematic supports and/or tools, with logic strictly related to the purposes of the processing and, in any case, guaranteeing the confidentiality and security of the data themselves and compliance with the specific obligations established by law. The availability, management, access, conservation and usability of the data referring to you is guaranteed by the adoption of technical and organizational measures to ensure suitable levels of security pursuant to articles 25 and 32 of the GDPR, as well as, in relation to the specific processing purposes identified by the legislation on the protection of personal data, to ensure compliance with the guarantee measures of the Guarantor for the protection of personal data and with the relevant sectoral provisions according to European Union law and national law (for example , the specific provisions on commercial communications). The Supermoney Site uses cookies and other tracking tools. For more information, please see the cookie policy. The processing is carried out by people specifically authorized and trained in full compliance with art. 29 of the GDPR and art. 2 quaterdecies of Legislative Decree 196/03 as amended. In any case, the logical and physical security and confidentiality of the information processed will be guaranteed.

7. Retention of Personal Data

Personal Data will be kept only for the time strictly necessary for the purposes for which they are collected, respecting the principle of minimization referred to in Article 5(1), lett. c) of the GDPR, as well as the legal obligations to which each data controller is required. If you decide to revoke the consent given, the Personal Data whose processing is based exclusively on the revoked consent will be immediately deleted or made anonymous.

8. Scope of circulation of Personal Data

The Personal Data will not be disclosed (meaning by this, the giving knowledge of personal information to indeterminate subjects, in any form, including by making them available or consulted), except in the hypothesis in which the communication or dissemination is requested, in accordance with the law, by the police forces, by the judicial authorities, by information and security bodies or by other public entities for purposes of defense or state security or to prevent, ascertain or repress crimes. Subject to your specific consent, the Data Controller may communicate the Personal Data to the Main Recipients, to the other companies of the DIN Group and to the Secondary Recipients, also located outside the European Union. The Main Recipients and Secondary Recipients, as identified above, will process the information referring to you for their own commercial purposes. When you request estimates on the Supermoney Website, your Personal Data may be communicated to the following data categories of recipients to perform the estimate service and/or contractual negotiation you requested:

  1. Communication and/or ADSL service providers and/or their intermediaries
  2. Gas and electricity service providers and/or their intermediaries

Some subjects could act as data processors on behalf of the Data Controller (e.g. the company IT Hub S.r.l. which deals with the technological development of the DIN Group) . Some commercial campaigns could be conducted in the interest of third-party clients (the "Clienters") with whom the Owner may have concluded joint-controller agreements (the "External Joint-Controllers"). In these commercial campaigns, your Personal Data won’t be disclosed to Clients; the Personal Data will stay available to the Data Controller who will process them for the benefit of the Clients (e.g. if Supermoney knows that you are interested in renewing an energy contract, it could contact you to propose an offer from its partner energy company; your Personal Data would be communicated to the Customer only upon your request). Personal Data may be transferred to third countries outside the European Union. This transfer will take place to countries that guarantee an adequate level of protection according to the European Commission (e.g. Switzerland, Canada, Japan or Argentina) or, in any case, subject to the adoption of adequate guarantees, such as the signing of Standards Contractual Clauses approved by the European Commission or the selection of subjects adhering to international programs for the free flow of data.

9. Data Subjects’ rights

You may, at any time, exercise your rights pursuant to articles from 15 to 22 of the GDPR and in particular obtain:

In case of opposition to the processing of Personal Data processed for direct marketing purposes and for the performance of profiling activities connected to such direct marketing, you will obtain the immediate interruption of the processing. We inform you that you can exercise the right to oppose the processing for marketing purposes even only in relation to one or more specific contact channels (for example, you can decide to continue to want to be contacted by the operator, but not to receive any more text messages or e-mail). In any case, if the contact channel in relation to which the right is exercised is not specified, the opposition to the processing will be understood as extended to all communication methods used.

Without prejudice to other administrative or jurisdictional recourse, you also have the right to lodge a complaint with the Personal Data Protection Authority (www.garanteprivacy.it) as provided for in Article 77 of the GDPR, or to bring an action before the appropriate courts, if you consider that the processing of your Personal Data has been carried out in breach of the provisions of the applicable data protection legislation.

If you want to exercise your rights, you can contact the Data Controller or the DPO, by sending an e-mail to the addresses in paragraph no. 2 of the Privacy Policy.

With reference to the Personal Data processed in the context of a commercial campaign carried out in the interest of a Customer, you can also exercise your rights according to the technical and operational methods indicated during this commercial campaign (for example by selecting the contact channels from which you want to unsubscribe following a call from an operator).

Any modification or cancellation or limitation to the processing carried out at your request or following the withdrawal of your consent - unless this is impossible or involves a disproportionate effort - will be communicated by each owner to the other, as well as to each of the recipients to whom they are the Personal Data has been disclosed.

(*) The DIN Group is made up of the following companies: Do It Now S.p.A., Supermoney S.p.A., Performance Credit Mediazione Creditizia S.r.l., IAMB S.r.l., Blasting SA, Massima Energia S.p.A., Supermoney Contact S.r.l., It Hub S.r.l., Reti Digitali S.r.l., Agente Unico S.r.l., Digital SM LTD.

Ultimo aggiornamento: 17/04/2024