European Regulation 2016/679 below "GDPR"

S.P.M. Srlwith registered office in Via Via G. Galilei 8, 20876 Ornago (MB), CF09166960154 and VAT number 00945390961as data controller (hereinafter called "Data Controller") informs you pursuant to art. 13 D.Lgs. 30.6.2003 n. 196 (hereinafter called "Privacy Code") and art. 13 EU Regulation n. 2016/679 (hereinafter called "GDPR") that your data will be processed in the manner and for the following purposes.


Object of the treatment

The Data Controller processes personal, identifying and non-sensitive data (in particular, name, surname, tax code, VAT number, email address, telephone number - hereinafter referred to as "personal data" or even "data") communicated by you during request for information on the products or services offered by the Owner.



The data will be processed for purposes related to the implementation of the following obligations, related to legislative or contractual obligations and for further purposes:

  • Mandatory obligations by law in the fiscal and accounting fields;
  • Management of customers and suppliers;
  • Scheduling of activities;
  • Historical billing of customers and suppliers;
  • Post-sales services;
  • Litigation management;
  • Credit recovery activities;
  • Quality management;
  • Detection of customer satisfaction;
  • Communication about new services and/or products of SPM.


The processing of functional data for the fulfilment of these obligations is necessary for a proper management of the relationship and their conferment is mandatory to implement the purposes indicated above. Any non-communication, or incorrect communication, of one of the mandatory information, may cause the Data Controller's inability to guarantee the adequacy of the processing itself.


Method of treatment

The processing of your personal data is carried out by means of the operations indicated in art. 4 of the Privacy Code and art. 4 n. 2) GDPR and precisely:

  • collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.


Your personal data are subjected to both paper and electronic processing.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the Service Finality report and for no more than 5 years from the collection of data for Marketing Purposes.

Each treatment is carried out in compliance with the methods set out in articles. 6, 32 of the GDPR and through the adoption of the appropriate security measures.

The data will be processed only by personnel expressly authorized by the Owner and by external subjects expressly appointed by the Data Controller.

Third parties who carry out processing operations on behalf of the Data Controller are expressly appointed as External Managers for the relevant treatments.


Access to data

The data may be made accessible for the purposes referred to in the chapter Purpose of processing:

  • to employees and collaborators of the Data Controller, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators;
  • to partners or suppliers of the Data Controller (for example, for activities of technical management of services, for the storage of personal data, etc.) or to third parties (for example, providers for the management and maintenance of the website, suppliers, credit, professional offices, etc) that carry out outsourcing activities on behalf of the Owner, in their capacity as external managers of the treatment


Communication to third parties

The data will be communicated exclusively to the competent subjects for the fulfilment of the services necessary for a correct management of the relationship, with guarantee of protection of the rights of the interested party:

  • Consultancy company in accounting, administrative and tax matters;
  • IT structure management company (IT)
  • Consultants and freelancers, also in associated form;
  • Banks and credit institutions;
  • Other public and / or private entities for which the communication of data is mandatory or necessary in compliance with legal obligations or is in any case functional to the administration of the relationship;



Personal data will not be disclosed in any way.


Time of retention of personal data.

Your data will be stored in our archives or authorized managers only for the time necessary for the purposes of treatment, subject to compliance with the storage times.


Data transfer

The management and storage of personal data will be carried out on servers located within the European Union of the Data Controller and / or third-party companies appointed and duly appointed as Data Processors.

Currently the servers are located in Italy.

The data will not be transferred to outside the European Union.

In any case, it is understood that the Data Controller, where necessary, will have the right to move the server location to Italy and / or the European Union and / or non-EU countries. In this case, the Data Controller hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided for European Commission.


Navigation data

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

This is information that is not collected to be associated with identified interested parties, but which by their 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 who connect to the site, the addresses in URI notation of the requested resources, the time of the request, the method used in submitting the request to the server, the file size obtained in response, the numerical code indicating the status of the response given by the server and other parameters related to the operating system and the user's 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 hypothetical computer crimes against the site: except for this eventuality, at present the data on web contacts do not persist for more than seven days.


Data provided by the user

The optional, explicit and voluntary sending of e-mails to the addresses indicated on this site entails the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the message.

Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request.


Method of treatment

Personal data are processed using paper / IT tools for the time strictly necessary to achieve the purposes for which they were collected.

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


Rights of the interested party

In his capacity as an interested party, he has the rights set forth in art. 7 of the Privacy Code and art. 15 GDPR and precisely the rights of:

  • obtain confirmation of the existence or not of personal data concerning them, even if not yet registered, and their communication in an intelligible form;
  • obtain the indication:
    • the origin of personal data;
    • or the purposes and methods of processing;
    • of the logic applied in case of treatment carried out with the aid of electronic instruments;
    • of the identification details of the owner, the managers and the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, managers or agents;
  • get:
    • the updating, rectification or, when there is interest, the integration of data;
    • cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
    • the attestation that the operations referred to in subparagraphs a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which such fulfilment is revealed impossible or involves a use of means manifestly disproportionate to the protected right;
  • object, in whole or in part:
    • or for legitimate reasons, the processing of personal data concerning them, even if pertinent to the purpose of the collection;
    • to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator through email and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right to object even only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.


Where applicable, the interested party also has the rights set forth in articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.



The sites and services of the Data Controller are not intended for minors under the age of 18 and the Data Controller does not intentionally collect personal information about minors. In the event that information on minors were unintentionally registered, the Data Controller will delete them in a timely manner, at the request of users.


How to exercise rights

The interested party may at any time exercise the rights:

  • by e-mail, at the address:
  • by fax: +39 039 6011434
  • by registered letter with receipt of return at the following address: Via G. Galilei 8, 20876 Ornago (MB)