Privacy Policy Information

All the Privacy Policies relating to the various services have been published on this page. To facilitate reading and finding the specific Privacy Policy of interest, the page has been divided into various sections, as indicated below:

• IES ITALIA Websites Privacy Policy
• Suppliers Privacy Policy
• Business Clients Privacy Policy

IES ITALIA WEBSITES PRIVACY POLICY

Information on the protection of personal data of corporate website users pursuant to art. 13, 14 of the EU General Data Protection Regulation 2016/679

With this policy IES Italia S.r.l. (hereinafter "IES Italia", "noi", "nostro" ), intends to inform visitors of the websites www.ies-italia.it, www.seafy.com, portal.seafy.com (hereinafter the "Siti IES Italia" ) of the policy adopted regarding the protection of personal data, emphasizing its commitment and attention to the protection of personal data of Site users. Please read this privacy policy (the "Privacy Policy" ) which applies if you access the Site and decide to navigate within it using our services.

Navigation within the Site is free and does not require any registration, except for some areas where the user can freely and expressly provide personal data to access specifically identified services (e.g. requesting information through the Contact Us section, subscribing to the newsletter, etc.). Where, therefore, you intend to provide your personal data to access such additional services, you will be expressly informed pursuant to Regulation (EU) 679/2016 General Data Protection Regulation (the Regulation) with indication (by way of example) of the purposes and methods of use of data by IES Italia as well as the right to request at any time the deletion or updating of such data.

Pursuant to art. 13 and 14 of the Regulation, IES Italia provides you with the following information.

1. Identity and contact details of the data controller

The Site is managed by IES Italia S.r.l. with registered office in Via L. Canonica, 29, Milan (MI), Italy, Tax Code and VAT No. IT07580910961, e-mail privacy@ies-italia.it, as data controller pursuant to the Regulation.

2. Types of personal data processed

To access the Site, no registration is required. However, there are sections within the Site that require personal data such as name, surname, e-mail, and/or telephone number (e.g. to access newsletter services, to request information, for assistance, etc.) [1].

With reference to data relating to navigation within the Sites, see also the following point g. regarding the profiling tools used by the Sites.

3. Purpose of processing

Data is collected and processed for purposes strictly connected to the use of the Sites and its services. The purposes of data use are indicated in detail in the specific privacy policies provided by the Sites in all cases of data collection. We therefore ask you to read the privacy policies that from time to time illustrate the characteristics of the processing that will be carried out by IES Italia (e.g. for subscription to the newsletter service, for Bot Assistance, user registration, etc.). In particular, your data will be processed to:

1) manage the provision of services (including post-sales, related to the management of the specific service purchased by you and provided by us) which can be requested through IES Italia Sites, purchased through shipping company websites, purchased directly on the ship, to fulfill related legal obligations, to respond to any requests for information about the service.

2) Regarding marketing activities, for sending communications via email (newsletter), for analyzing your preferences, for transferring data to commercial partners, which will be implemented by the Controller exclusively on the basis of your consent that you can freely grant through appropriate fields on various forms on the Sites, or through authorization to install Cookies, as described in the Cookie Policy document and equally freely revoke at any time.

The processing of your data will take place in full compliance with privacy regulations [2].

4. Legal basis for processing

The legal basis for processing navigation data on IES Italia Websites is the legitimate interest art. 6, paragraph 1, letter f.

Regarding the provision of Wi-Fi service, the legal basis is the execution of the sales contract established with you and related services and the fulfillment of related legal obligations pursuant to art. 6, paragraph 1, letters b) and c), of the Regulation.

Regarding marketing activities, the analysis of your preferences, the transfer of data to commercial partners, the legal basis is your consent art. 6, paragraph 1, letter a) of the Regulation.

On IES Italia Sites, services and sections are available to update you on our services, initiatives and events, send you promotional material, also personalized (based on user category), for which you will find specific information and where necessary, we will activate the collection of your explicit consent (pursuant to art. 6, paragraph 1, letter a) of the Regulation). Your consent is always freely revocable (see letter h. of this policy) without prejudice to the lawfulness of processing prior to revocation, also by using the link in all our newsletters or writing to the e-mail address privacy@ies-italia.it

5. Optional nature of providing personal data

The provision of personal data is generally optional. Only in certain cases, failure to provide data may result in the inability to access specific services or the inability of IES Italia to respond to your requests.

The data requested from time to time in the collection forms on the Sites is strictly necessary to offer the related requested service.

6. Methods of data processing and scope of communication

Data may be processed both electronically and on paper. IES Italia guarantees the lawful and correct processing of personal data provided through the Sites, in full compliance with current regulations, as well as maximum confidentiality of such data.

Data will not be disseminated and will be processed by persons expressly authorized to manage the user Database.

For exclusively organizational and functional needs, IES Italia has appointed some service providers functional to the management of the Sites as external processors of users' personal data for purposes strictly connected and related to the provision of services provided. A complete list of external processors can be requested by e-mail at privacy@ies-italia.it.

Data may also be made available to companies that provide us with services [3].

7. Links to other sites

This policy is provided only for IES Italia Sites and not for other websites that may be consulted by the user through links. IES Italia cannot be held responsible for personal data provided by users to external parties or to any websites linked to this Site.

8. Profiling and/or personalization tools

IES Italia does not carry out any promotional and/or advertising communication activities without the prior express consent of the user.

The Site uses cookies, both technical (i.e. to facilitate navigation and use of the Sites), and profiling (i.e. to analyze users and their behaviors and preferences, and to provide them with personalized advertising).

Profiling cookies will only be activated with express consent from users. For a detailed explanation of the cookies used by the Site and how to disable them, please read our Cookie Policy.

9. Who processes your data

Your data will not be disseminated or transferred to third parties for compensation. Personal data entered in the appropriate collection forms on the site will be disclosed (limited to their respective area of competence) to persons authorized to process data in the technical support, marketing, finance, and legal departments. Data may also be shared with our commercial partners as well as with companies that provide us with services [3] useful for managing your requests.

10. Place of data processing and transfers outside the European Union

Processing related to services provided by the Sites is carried out at IES Italia headquarters.

Data collected and processed through the Sites will not be transferred to countries outside the European Union.

11. Data retention period

Your data will be processed for the times specified in the specific policies provided at the time of collection [4].

Regarding the retention times of data collected through the use of profiling tools (e.g. cookies), please see our Cookie Policy.

12. Rights of data subjects

By sending a communication to privacy@ies-italia.it, you may at any time exercise the rights [5] referred to in articles 15 to 22 of the Regulation, including knowing what data we are processing, how and for what purposes we use it, modify the data you have provided or delete it, ask us to limit the use of your data, request to receive or transmit your data, while always retaining the possibility of changing your consents (if provided). You may also always object to the processing of your data carried out, in particular, for marketing purposes or analysis of your preferences.

13. Who to contact to file a complaint

We remind you that, if you believe that the processing concerning you violates the provisions of the Regulation, you can always file a complaint with the Data Protection Authority (www.gpdp.it), or, if different, with the Authority of the Member State where you habitually reside, work or where the alleged violation occurred.

14. Applicable law

This Privacy Policy is governed by the Regulation, which ensures that the processing of personal data takes place in compliance with fundamental rights and freedoms, as well as the dignity of the data subject, with particular reference to confidentiality, personal identity and the right to personal data protection.

15. Revision clause

IES Italia reserves the right to revise, modify or simply update, in whole or in part, at its sole discretion, in any way and/or at any time, without notice, this Privacy Policy also in consideration of changes in laws or regulations regarding the protection of personal data. Changes and updates to the Privacy Policy may be notified to users as appropriate by (i) sending e-mail to users registered on the Site and/or (ii) publication on the home page of the Sites, and will be binding as soon as published and/or communicated. We therefore ask you to regularly access this section to verify the publication of the most recent and updated Privacy Policy or to check your e-mail inbox. The full text of the Regulation can be consulted on the website of the Data Protection Authority www.gpdp.it.

Footnotes:

[1] If IES Italia acquires information and personal data, it will inform users in advance of the purposes for which such data is requested and how it will be used. Where necessary, IES Italia will acquire the user's specific consent for the related use of data. By way of example, personal data such as name and surname, e-mail address and other information that the user agrees to provide may be requested to use the services of the Sites through the completion of a specific data collection form. IES Italia will use personal data collected online only for the purposes indicated at the time of collection.

Data relating to connection and navigation within the Sites (such as URI-Uniform Resource Identifier addresses of requested resources, the time of the request, the method used to submit 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 (success, error, etc.) and other parameters relating to the operating system and the user's computer environment) are collected solely for the purpose of obtaining anonymous statistical information on the use of the Sites and to check their correct functioning and are deleted upon completion of their use. Data could be used to ascertain responsibility in case of hypothetical computer crimes against the Sites: excluding this eventuality, data will be deleted after the time useful for the provision of services illustrated in the Sites.

[2] The processing of your data will take place:

- pursuant to art. 6, paragraph 1, letters b) and c) of the Regulation to manage your orders and guarantee you the use of the Services (including after-sales) requested through the Sites, fulfill related legal obligations, to respond to your requests;

- on the basis of your consent, pursuant to art. 6, paragraph 1, letter a) of the Regulation, to carry out marketing activities and analysis of your preferences by IES Italia.

In any case, processing will take place in compliance with the provisions of current measures - and their subsequent amendments and/or additions - issued on the matter by the Data Protection Authority.

[3] Your data will be communicated to:

1. third-party companies for the management of any purchases;

2. third-party companies for the management of Site services, for registration, for the management of Assistance via Chatbot and for sending the newsletter;

[4] Your data provided for contractual purposes and execution of pre-contractual measures will be retained for the time necessary to fulfill the obligations assumed towards you in relation to the commercial relationship and in any case no longer than ten (10) years from the conclusion of the contractual relationship.

Data processed in order to send you responses to your requests, offers, news and events, marketing communications, will be retained for five (5) years from the date of collection or from the date of your last contact with IES Italia for extra-contractual reasons.

[5] Articles 15 to 22 of the Regulation recognize specific rights including:

• obtain confirmation as to whether or not personal data concerning you is being processed;
• obtain access to your personal data and the information indicated in art. 15 of the Regulation;
• obtain the rectification of inaccurate personal data concerning you without undue delay or the completion of incomplete personal data;
• obtain the erasure of personal data concerning you without undue delay;
• obtain restriction of processing of personal data concerning you;
• be informed of any rectifications or erasures or restrictions of processing carried out in relation to personal data concerning you;
• receive or transmit to another controller in a structured, commonly used and machine-readable format personal data concerning you;
• object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you.

In particular, your right to withdraw at any time any consents to processing provided and to object to our analysis activities remains firm. Furthermore, pursuant to art. 21 of the Regulation, you will have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you carried out for the pursuit of the legitimate interest of the controller pursuant to art. 6, paragraph 1, letter f of the Regulation.

Last revision, February 03, 2025

SUPPLIERS PRIVACY POLICY

Information on the processing of personal data pursuant to art. 13 EU Regulation 2016/679

Pursuant to article 13 of EU Regulation 2016/679, we inform you that the personal data you provide will be processed. Personal data means contact data (Name, Surname, e-mail, telephone), address, personal and tax data necessary for the establishment and execution of the existing contractual relationship.

Purpose of personal data processing

The collection and processing of your data is necessary to manage the relationships established in the Collaboration Agreement. Without the communication of your data, it will be impossible to establish a contractual relationship and communicate the data necessary for the performance of the service provided for in the Contract.

Legal basis

The legal basis is the management of the contractual relationship art. 6 letter b) EU Reg 679/2016

Communication and dissemination of data

Personal data will not be transferred or disseminated to third parties, however if necessary, they may also be communicated to:

• all subjects to whom access to such data is granted by virtue of national or EU regulatory provisions, civil and tax regulations;
• our collaborators, employees, any authorized data processors, within the scope of their duties and/or any existing contractual obligations;
• all those natural and/or legal persons, public and/or private (legal, administrative and tax consultancy firms, Revenue Agency, Judicial Offices, Banking Institutions, etc.), when communication is necessary or functional to carrying out the Company's activity and in the ways and for the purposes illustrated above;

Transfer of personal data

Your data may be transferred outside the EU due to the physical location of some of our systems. Regarding the transfer of extra-EU Data, it is noted that the Controller carries out the checks and follows the requirements provided by the GDPR in CHAPTER V Art. 44-50, and specifically regarding the transfer of Data to the USA, has carried out the checks provided for by the DPF (Data Privacy Framework), verifying that the transfer falls within the parameters provided for by the new agreement in force between the EU and the USA since July 10, 2023.

Duration of data collection

Data is stored at our headquarters and at the IT infrastructures we use for this purpose, for the time prescribed by civil and tax regulations (10 years).

Processing methods

The processing of personal data takes place using both paper and electronic supports, by telephone and telematic means, with the observance of every precautionary measure, which guarantees its security and confidentiality. No automated decision-making processes are used.

Data Controller

The Data Controller is IES-ITALIA S.r.l. Viale L. Canonica 29 - 20154 Milan (MI) - tel 0236523886 which can be contacted at the following e-mail address for access to personal data as specified below privacy@ies-italia.it

Right of access to personal data

You have the right to obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in intelligible form.

Specifically, you have the right to exercise all the rights mentioned in articles 15-22 of EU Reg. 679/2016

The above rights may be exercised by request addressed without formality to the controller, also through an authorized person, to which a response will be provided without delay. The request may be transmitted by written communication via e-mail.

In case of violation of the above rights, the data subject may file a complaint with the Supervisory Authority for the processing of personal data by finding all information on the website www.garanteprivacy.it

BUSINESS CLIENTS PRIVACY POLICY

Information on the processing of personal data pursuant to art. 13 EU Regulation 2016/679

With this Document, IES Italia S.r.l. (hereinafter IES Italia), emphasizing its commitment and attention to the protection of personal data of data subjects, intends to inform the contract persons, with whom it interacts, at its Customers, of the policy adopted regarding the protection of personal data. We therefore ask you to read this information carefully.

Pursuant to article 13 of EU Regulation 2016/679, we inform you that the personal data you provide will be processed. Personal data means contact data (Name/company name, e-mail, telephone), address, personal and tax data necessary for the establishment and execution of the contractual relationship following your request

Data Controller

The Data Controller is IES Italia S.r.l. with registered office in Via L. Canonica, 29, Milan (MI), Italy, Tax Code and VAT No. IT07580910961, e-mail privacy@ies-italia.it

Purpose of personal data processing

The collection and processing of your data is necessary to manage commercial relationships. Without the communication of your data, it will be impossible to establish a contractual relationship and carry out our activities: sales, logistics management, administrative and accounting aspects of IES Italia.

Legal basis

The legal basis is the management of the contractual relationship and legal obligations art. 6 letters b) and c) EU Reg 679/2016

Communication and dissemination of data

Personal data will not be transferred or disseminated to third parties, however if necessary, they may also be communicated to:

• all subjects to whom access to such data is granted by virtue of national or EU regulatory provisions, civil and tax regulations;
• our collaborators, employees, authorized data processors, within the scope of their duties and/or any existing contractual obligations;
• all those natural and/or legal persons, public and/or private (legal, administrative and tax consultancy firms, Revenue Agency, Judicial Offices, Banking Institutions, etc.), when communication is necessary or functional to carrying out the Company's activity and in the ways and for the purposes illustrated above;

Duration of data collection

Data is stored at IES Italia's operational headquarters, for the time prescribed by civil and tax regulations (10 years).

Processing methods

The processing of personal data takes place using both paper and electronic supports, by telephone and telematic means, with the observance of every precautionary measure, which guarantees its security and confidentiality. No automated decision-making processes are used.

Right of access to personal data

You have the right to obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in intelligible form.

Specifically, you have the right to exercise all the rights mentioned in articles 15/16/17/18/19/20/21 of EU Reg. 679/2016

The above rights may be exercised by request addressed without formality to the controller, also through an authorized person, to which an appropriate response is provided without delay. The request may be transmitted by registered letter or e-mail to the e-mail address: privacy@ies-italia.it.

In case of violation of the above rights, the data subject may file a complaint with the Supervisory Authority for the processing of personal data by finding all information on the website www.garanteprivacy.it