privacy policy



SMAPP S.p.a. takes care of the privacy of its customers. We believe in transparency and we engage to be clear about our privacy procedures, included the way we handle user’s personal information.

This Privacy Policy is provided pursuant to Regulation EU 679/2016 and the subsequent national adaptation legislation (hereinafter, as a whole "GDPR") and describes how SMAPP S.p.a. (referred to “SMAPP or “Company”) with registered office in Trezzano S/N (MI), via Circonvallazione 7, 20090 as the Data Controller collects and process the personal data of users or customers through their websites, in particular www.salumipasini.com ("Site"), events, or more generally every time that express reference is made to this Privacy Policy.
The term "personal data" means any information concerning a identified or identifiable physical person. For example, personal data is the name, an identification number, location data, an online identifier.
SMAPP may amend, supplement or periodically update this Privacy Policy, also in consideration of possible regulatory changes which are applicable or provisions from the Guarantor for the Protection of Personal Data. The changes and substantial updates to the Privacy Policy will be applied and brought to the attention of the interested parties as soon as they are adopted by updating the link to the Privacy Policy in the Site footer and by emailing the registered users. In case of changes that significantly affect the rights of the registered user, the communication will be made with reasonable notice.
All processing of personal data will be carried out according to the principles of necessity, correctness, lawfulness, proportionality and transparency. Where necessary, in relation to any use or specific treatment of Personal Data, the user's prior consent will be required.

Although not mandatory, failure to provide certain data for the purposes specified below may make it impossible to render the services requested in whole or in part.
This information is intended for all those who interact with the web pages of the site, and in particular:
(a) to those who use the Website without making any registration;
(b) to those who register on the Website and make use of the services offered online through the Website, including the e-commerce service;
(c) in general, to all those who use the services rendered by SMAPP regardless of the online or contact platform in which the service is offered: website, app, telephone, in events or via social networks




The data are processed for the following purposes.
a) Based on the contractual need in order to: 
- manage orders and perform related activities (ex: sales and after-sales customer assistance, communications with the customers on the status of their orders, responses to their information requests, management of payments, etc.);
- managing user accounts when registered with the Site in order to use the related services;
- allow access to specific and additional services requested from time to time by the user (e.g. registration to events organized by SMAPP);
- manage product shipments and create waybills;
- follow specific user requests (e.g. managing information requests through our form or through the telephone number made available on this purpose).

b) Based on the consent expressed by the user, specifically collected each respective time, in order to carry out market research, as well as to contact the user and send commercial communications and promotional offers, in addition to sending the Newsletter described below, with regard to products, services and/or events of SMAPP, through SMS, telephone, paper mail or other means, including through a prior analysis of consumer behaviour aimed at customising commercial messages. 

After making a purchase on the Sites, the user will receive the Newsletter regarding similar products or services offered on the Sites. The user has a right to oppose to such processing right away (i) by using the appropriate link at the end of each email, (ii) by using the contact details indicated below in the section "Rights of the data subject".

c) Based on the legitimate interest of SMAPP, specifically:
- for the analysis and improvement of its services;
- for statistical and/or research and development activities, also by analysing data deriving from the use of services and products or consumer behaviour;
- in order to defend their rights in the course of court, administrative or extrajudicial proceedings, and in disputes arising in connection with the services offered;

d) Based on the need to fulfill the legal obligations to which SMAPP is subject.
The provision of data for the purposes referred to in paragraph (a) above is mandatory, as it is necessary to process the sale and delivery of products and services purchased, or for registration at the site. Refusal to provide personal data for processing makes it impossible to perform the services required for the purchase of goods and services on the Site.




It is possible to access the Site without being required to provide any personal data. However, the computer systems and software used to operate the Site acquire, during 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 interested parties, but due to their nature could, through processing or associations, allow the identification of the user.

This category includes IP addresses or domain names of the computers used by users who connect to the Site, URL 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, etc. These data are used only to obtain anonymous statistical information on the use of the Site (such as, in particular, the number of accesses) and to check its correct functioning and are deleted immediately after processing. In this process is not foreseen the processing of directly identifying information.

The use of so-called session cookies (which are not stored permanently on the user's computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow the safe and efficient Site browsing ).





Cookies consist of portions of code installed in the browser that assist the owner in providing the service according to the purposes described. Some of the purposes of cookies may also require the consent of the User.

This site uses cookies to make the browsing experience simple and effective for those who view the pages. Users who view the site will enter the minimum amount of information in the devices in use, which are computers and mobile devices, in small text files called "cookies" saved in the directories used by the user's web browser. Disabling cookies, some of the features of the site may not work properly. There are various types of cookies, some to make the use of the Site more effective, others to enable certain features. Our cookies allow you to store your preferences, avoid re-enter the same information several times and analyze the use of the Site to optimize the browsing experience.





This type of cookie is strictly necessary for the proper functioning of some sections of the Site. There are two categories: persistent and session cookies:1) persistent cookies: once closed the browser are not destroyed but remain up to a preset expiration date 2) session cookies: they are destroyed every time the browser is closed. These cookies, always sent from our domain, are necessary to view the site correctly and in relation to the technical services offered, will therefore always be used and sent, unless the user does not change the settings in its browser (thus disrupting the display of the Site pages).



These cookies are used to collect information on the use of the Site. This information is used for anonymous statistical analysis in order to improve the use of the Site and to make contents more interesting and relevant to the wishes of users. This type of cookies collect anonymous data on the activity of users and how they arrived on the Site. Analytical cookies are sent from the Site itself or from third-party domains.



These cookies are used to collect information on the use of the Site by users anonymously such as:  visited pages, time spent, traffic provenance, geographic origin, age, gender and interests for the purpose of marketing campaigns. These cookies are sent from third-party domains external to the Site.



This type of cookie integrates features developed by third parties within the pages of the site such as icons and preferences expressed in social networks in order to share site content or for the use of third-party software services (such as maps generator software and further software offering additional services). These cookies are sent from third-party domains and from partner sites that offer their functionality between the pages of the Site.



These cookies are necessary to create user profiles in order to send advertising messages in line with the preferences expressed by the user within the pages of the Site.



In this Site, according to current legislation, we are not required to seek consent for technical cookies, as necessary to provide the required services.

For all other types of cookies the consent can be changed or revoked by the user with one or more of the following methods:

1) Through the appropriate window that appears when opening the Cookie Policy web page accessible from the footer at the bottom of the page
2) By specific configurations of the browser used or the related computer programs used to navigate the pages that make up the Site.
3) By changing the settings in the use of third-party services

These solutions may prevent you from using or viewing parts of the Site.



The Site may contain links to other Web sites that have their own Privacy Policy that may be different from the one adopted by this Site and therefore not responsible for these sites.




The information and data requested in case of registration will be used both to allow access to the reserved area of the Site, and to take advantage of the online services offered by SMAPP. The personal data of registered users will be processed for the purposes and according to the procedures set out in this policy.




In the event that, following registration on the Site, an online purchase order is made, some data are recorded, such as the IP address from which the transaction originated, the time of the request, the type of browser used, etc. These data could be used to ascertain responsibility in case of hypothetical computer crimes against the Site and / or third parties, at the request of the competent investigating authorities according to the law. The registration on the Site and any subsequent use of the services rendered by SMAPP through the Site, including the online purchase service, will result in the processing of personal data released during registration.

Therefore, in compliance with the provisions of the Privacy Code, we hereby intend to inform you that the Company, as Data Controller, will process personal data concerning users at the following conditions.




The provision of data for the purposes set forth in letters a) and b) above of art. 1 is purely optional. However, because such treatment is needed to allow the registration to the Site and, therefore, the provision of the services offered by SMAPP through the Site, including the e-commerce service, any refusal to provide such data will make it impossible to complete the registration procedure and to make purchases on the Site. 
If, after registering, the user intends to conclude an on-line purchase of products, they must provide some additional personal data to those already conferred upon registration to the Site and, in particular, those relating to the address of delivery of the products to be purchased. The processing of such personal information is necessary in order to make purchases of products through the Site, and failure to provide it will make impossible the completion of an online purchase. 
In addition, if the client chooses to pay by credit card, it will be requested the data concerning the credit card. Such data will not be in any way treated by us, but only by the payment service provider. 
With reference to the purposes of the processing mentioned in art. 1, in letters c), d) and e) above, please note that the consent to the data processing is purely optional. However, lack of consent will entail the following consequences. 
In particular, lack of consent to the data processing for the purposes in art. 1, letter c) above, will make it impossible to receive newsletters, alerts or communications by SMAPP relating to the services and products offered by the Company or by third parties. 
Finally, lack of consent to the processing of data for the purposes in art. 1, letter d) above will make it impossible for the company to develop a consumption habits profile (intended to ensure a greater satisfaction of customer needs and the continual improvement of services), as well as the chance to send informative and advertising material of specific interest for the user. 
Please note, also, that consent to the data processing for one or more of the purposes indicated above may be withdrawn at any time requesting to SMAPP the modification of the data consent. 
The client may revoke the consent to the data processing related to advertising, informational brochures and communications by SMAPP on services and products offered by the Company or by third parties by clicking the appropriate link [Unsubscribe] present in every communication containing advertising information or information that will be sent by SMAPP.




The processing of personal data will be mostly carried out with the help of electronic or automated means, in the manner and with the appropriate tools to ensure the safety and confidentiality of the data, in accordance with the provisions of the Privacy Code. In particular, all technical, computer, procedural, logistical and organizational security measures will be taken, in order to guarantee the minimum level of data protection provided by the law, allowing access only to the people in charge of the data treatment by the Owner or by the Managers designated by the Owner. 
The information acquired, and the data treatment method will be relevant and not excessive in relation to the kind of services provided. 




The data may be processed by third parties carefully selected for reliability and competence that act as data controllers, in the name and on behalf of SMAPP on the basis of contractual agreements and specific instructions, as this is necessary or appropriate for the purpose to carry out activities, including the instrumental or ancillary ones, related to the purposes of data processing indicated in this statement, the main one of which consists in the supply of goods or services requested by the interested party (eg: postal service companies, couriers, data entry companies, companies that manage marketing and newsletters, etc.). In any other case, except as required by applicable law, personal data are not transferred and / or disclosed to third parties.




As soon as personal data are no longer necessary for the purposes for which they were collected, SMAPP will delete them, unless the law requires filing requirements or if the user has consented to the data processing for a longer time or for archive purposes. In particular, following the deactivation of the account or, for unregistered users, of the order completion, SMAPP will retain the personal data that are necessary for:
- fulfill the requests of the authorities within their competence;
- defend or assert any existing or potential claim;
- handle any complaint regarding the contract or the orders concluded.

The retention period of the data necessary to achieve the aforementioned purposes is linked to the limitation period of a claim that in many cases is equal to 10 years. SMAPP will retain personal data after such time has elapsed only when required to comply with legal obligations or in the event of extraordinary claims and in the case that reasonably require the retention of personal data. The user can oppose this treatment at any time by submitting a request to the contacts indicated on the online Site.




In accordance to the GDPR, each user has the right to access their personal data and to obtain confirmation of the existence of his personal data, even if not yet registered, and their communication in intelligible form. In particular, each user has the right to obtain access to his / her data from SMAPP, as well as any information about the methods and characteristics of the processing. In addition to the above, the user, in the cases provided for by law, has the right to receive his personal data in a structured, common and readable format, as well as the right to transmit such data to another data controller without impediments. Furthermore, each user has the right to obtain updates, rectification or integration of its data from SMAPP. The user also has the right to cancel his / her personal data as well as to limit the processing in cases provided by law. Finally, each user has the right to object, in whole or in part, to the processing of personal data if the treatment is based on the legitimate interest of the owner, as well as for direct marketing purposes. The requests referred to in the previous points should be addressed to the data Owners contacts indicated in the "Data Controller" section below. Requests must be addressed to the reference Owner for the relevant activities. If you have any doubts or if you want more information about the relevant data holder from time to time, contact the Site Customer Service.




The Owner of the personal data processing is the company SMAPP S.p.A., established in Trezzano Sul Naviglio (MI), Via Circonvallazione 7, 20090. 

The updated list of data Managers and Representatives for the treatment is available in the Company offices. 
All requests and inquiries related to the processing of personal data of the users can be sent to: 

Via Circonvallazione 7
20090 Trezzano Sul Naviglio (MI)
Tel. +39 02 48401725
Fax. +39 02 48400502

eMail: info@salumipasini.com