Privacy Policy

Our commitment to privacy

UpSurgeOn Srl
Via Cascina Venina, 7, 20090 Assago MI
VAT: 09723700960
website: www.upsurgeon.com

Information pursuant to art. 13 of EU Regulation 2016/679

This page describes how to manage the site in relation to the processing of personal data of users who consult it. This information (or “Privacy Policy”) is provided pursuant to art. 13 of EU Regulation 2016/679 (hereinafter, “GDPR”) to those who interact with the web services of the website.

The information is provided only for the website and not for other websites that may be consulted by the user via links.

1. Data Controller

The data controller is:

UpSurgeOn Srl (hereinafter, the “Website Owner”, or the “Data Controller”)

Via Cascina Venina, 7, 20090 Assago MI
VAT: 09723700960
website: www.upsurgeon.com

2. Personal data subject to processing

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 information is not collected to be associated with identified interested parties, but 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 (internet addresses assigned to the user’s computer by the internet service provider), the domain names of the computers used by users who connect to the site, the browser (for example Firefox or Internet Explorer) , the date, time of the request and other parameters relating to the operating system and the user’s computer environment.

These data could be used to ascertain responsibility in case of hypothetical computer crimes against the site and are in any case canceled after processing within 6 (six) months.

Anonymous data is also collected and processed for the sole purpose of obtaining statistical information on the use of the site and to verify its correct functionality.

Data provided voluntarily by the user

The optional, explicit and voluntary sending of electronic mail 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 e-mail.

3. Cookies

> Read the cookie policy

4. Purpose and legal basis of the processing

The personal data provided will be processed in compliance with the conditions of lawfulness pursuant to art. 6 of EU Reg. 2016/679, for the following purposes:

Nature of the data processingPurposesLegal BasisRetention Period
Registration ProcessEnabling you to create an account and register to the websiteThe contractual necessity to provide the service to the registered users (Art. 6.1.b. GDPR).In the event of receipt of a cancellation request or detecting account inactivity over more than [TBC], we will proceed to cancel the account and all the relating Data.
Purchasing productsYour data will be used to process your purchase orders and related activities (shipment of goods, billing, payment processing).The contractual necessity to provide the products requested (Art. 6.1.b. GDPR)Your data will be kept for the time required in order to fulfill the contractual obligations as well as the obligations imposed by law (e.g. for tax matters).
Browsing the websiteEnabling you to browse the website, monitor and improve website operation, prevent fraud and abuse.The contractual necessity to allow the users to access and use the website (Art. 6.1.b. GDPR).Data controller’s legitimate interest in ensuring the proper functioning of IT systems (Art. 6.1.f. of the GDPR)Your Data will be processed for the time required in order to enable you to access and to browse the website.
Request for contact, also through the LiveChatEnabling you to request and obtain information and assistance, including via LiveChat.The performance of pre-contractual measures at the request of the user (Art. 6.1.b. GDPR)Your data will be retained for no longer than [TBC] after you have sent us your request for contact and/or information.
Soft spamYour contact details will be used to send you email communications relating to services which are similar to the Service you requested. Under art. 130, co 4, d.lgs. 196/2003, the Data controller will be able to use the email address which you provided in order to promote services similar to the Services you used or requested, unless you object said processing by sending an email to info@upsurgeon.com or by clicking on the specific link to object to the receipt of commercial communications from the Data controller. The registered users will also be able to opt out from said processing when they create their account, by selecting the specifically provided checkbox. [TBC].The legitimate interest of the Data controller. (Art. 6.1.f. GDPR and art. 130, co 4, d.lgs. 196/2003).Your data will be retained until you opt out or object the legitimate interest of the processing.
Direct marketingSending you commercial and/or promotional information as well as advertising material or engaging in direct selling of products, services or engaging in market research endeavours. For example, we may send you emails or use instant messaging or contact you by phone through an operator to illustrate commercial offers, initiatives and promotions relating to our products and services (including products and services other than those you requested).Your consent (Art. 6.1.a GDPR).Your Data will be retained until you withdraw your consent.
Compliance with a legal obligationYour Data may be used to comply with legal obligations.Compliance with a legal obligation (Art. 6.1.c. GDPR).Your Data will be retained for the time required to comply with the legal obligation at issue.
Enforcement of rightsYour Data may be used to enforce a right of the Data Controller before or out of Court (i.e., for illicit uses of the website).Legitimate interest of the Data Controller to enforce its rights (Art. 6.1.f. GDPR).Your Data will be retained for the time required to enforce our rights.

5. Any recipients and any categories of recipients of personal data

The data may be communicated to third parties, who act as supervisors as well as by persons appointed as persons authorized to process, in charge of managing the requested service. In particular, the data will be communicated to:

  • subjects that provide services for the management of the information system and communication networks including e-mail and website management;
  • third parties who collaborate with the Data Controller for direct marketing activities;
  • studies or companies in the context of assistance and consultancy relationships;
  • competent authorities for compliance with legal obligations and / or provisions of public bodies, upon request.

The updated list of data processors and persons in charge of the processing is available at the registered office of the Data Controller and can be consulted by making an informal request, also via email at the following email address: info@upsurgeon.com

5.1 Address management and mail sending

The following services allow us to manage a database of email contacts, telephone contacts or contacts of any other type, used to facilitate communication with you. These services may also allow us to collect data relating to the date and time of viewing of the messages by you, as well as your interaction with them, such as information on clicks on links inserted in messages.

Mailchimp

Mailchimp is an address management and email message sending service provided by Mailchimp Inc. Personal data collected: Name, Surname, phone, vat number, address, products purchased.
Place of processing: USA.
Privacy Policy

SPAM protection

These services analyze the traffic of this Site, which may potentially contain your Personal Data, in order to filter it from traffic (messages and contents) recognized as SPAM.

Akismet (Automattic Inc.)

Akismet is a SPAM protection service provided by Automattic Inc.
Personal data collected: Various types of data as specified in the privacy policy of the service.
Place of processing: USA
Privacy Policy

5.2 Embedded content from other websites

This site may include embedded content (e.g. videos, images, articles, etc.) from other websites. The content incorporated from other websites behaves in exactly the same way as if you had visited the other website.

These websites may collect data about you, use cookies, integrate additional third-party tracking and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Google Font (Google Inc.)

Google Fonts is a font style visualization service managed by Google Inc. that allows this Site to integrate such content within its pages.
Personal data collected: Cookies and usage data
Place of processing: USA
Privacy Policy

Google Maps (Google Inc.)

Google Maps is a map viewing service managed by Google Inc. that allows this Site to integrate such content within its pages.
Personal data collected: Cookies and usage data
Place of processing: USA
Privacy Policy

Video Vimeo (Vimeo, LLC)

Vimeo is a video content viewing service managed by Vimeo, LLC that allows this Application to integrate such content within its pages.
Personal data collected: Cookies and Usage data.
Place of processing: USA
Privacy Policy

Video Youtube (Google Inc.)

Youtube is a video content viewing service managed by Google Inc. that allows this Site to integrate such content within its pages.
Personal data collected: Cookies and Usage data.
Place of processing: USA
Privacy Policy

6. Transfer of personal data to a third country and / or an international organization

The personal data provided will be transferred to countries belonging to the European Union and countries outside the EU in order to comply with the aforementioned related purposes. The Data will only be transferred to countries which provide a level of protection adequate to the one set out by the EU applicable legal framework, or by means of the implementation of adequate safeguards to protect your Data, such as the Standard Contractual Clauses issued by the EU Commission with the implementing decision (UE) 2021/914 of June 4th 2021. In any case, the data transfer will comply with the recommendations (n.1/2020 and n.2/2020) issued by the European Data Protection Board (“EDPB”). The data subjects may obtain information about the guarantees for data transfer by writing an email to info@upsurgeon.com

7. Rights of the data subject

Pursuant to the articles 15 and ss. of EU Regulation 2016/679, the data subject has the right to ask the Data Controller: access to your personal data; the correction or cancellation of the same or the limitation of the processing that concern it; opposition to processing; data portability in the terms set forth in art. 20 cit. Without prejudice to any other administrative or judicial appeal, the data subject who considers that the treatment concerning him violates the GDPR, has the right to lodge a complaint with a supervisory authority, particularly in the Member State in which he habitually resides, works or places where the alleged violation occurred (art. 77 cit.).

To exercise the above rights, the data subjects may contact the Data Controller at the addresses indicated in point 1 of this information notice.

In addition, we want to inform you that you have the right to opt out from soft spam activities at any time by sending an email to info@upsurgeon.com.

8. Updates

This privacy policy may be modified and / or supplemented as a result of any subsequent changes and / or regulatory additions, the updating or provision of new services or technological innovations.

Cookie Policy

This Cookie Policy is intended to inform users about the procedures followed for the collection, via cookies and / or other monitoring technologies, of the information provided when they visit the website.

The Data Controller is:

UpSurgeOn Srl
Via Cascina Venina, 7, 20090 Assago MI
VAT: 09723700960
website: www.upsurgeon.com

What are cookies

Cookies are small text files that the sites visited by users send to their terminals, where they are stored to be re-transmitted to the same sites on subsequent visits. Cookies are used for different purposes, have different characteristics, and can be used both by the owner of the site you are visiting and by third parties. Below you will find all the information on the cookies installed through this site, and the necessary information on how to manage your preferences regarding them.

To learn more about cookies and how they work, visit www.allaboutcookies.org or www.youronlinechoices.eu.

What types of cookies exist?

Technical cookies

Technical cookies are those used for the sole purpose of “transmitting a communication over an electronic communication network, or as strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide this service “(see Article 122, paragraph 1 of the Code).

They are not used for other purposes and are normally installed directly by the Website Owner or manager. They can be divided into browsing or session cookies, which guarantee the normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas);

Used cookies:
  1. Woocommerce (Automattic Inc.) WooCommerce is an open-source e-commerce plugin for WordPress. It is designed for small to large-sized online merchants using WordPress.
    Personal data collected: Name, Surname, phone, vat number, address, products purchased.
    Storage time: 24 months.
    Place of processing: USA
    Privacy Policy

wc_cart_hash_#
Description: Used to store a unique identifier for the user shopping cart.
Stay: persistent

wc_fragments_#
Description: Used to store the content of the user shopping cart.
Stay: session

woocommerce_items_in_cart
Description: Used to store the number of items in cart.
Stay: session

wp_woocommerce_session_#
Description: Store the current session with a unique identifier.
Stay: session

Functionality cookies

that allow the user to browse according to a set of selected criteria (for example, the language, the products selected for purchase) in order to improve the service rendered to the same.

For the installation of these cookies, users’ prior consent is not required.

Used cookies:

cookielawinfo-checkbox-necessary
Description: This cookie is set by our GDPR Cookie Consent functionality. The cookies is used to store the user consent for the cookies in the category ‘Necessary’.
Stay: 1 year

cookielawinfo-checkbox-non-necessary
Description: This cookie is set our GDPR Cookie Consent functionality. The cookies is used to store the user consent for the cookies in the category ‘Non-necessary’.
Stay: 1 year

CookieLawInfoConsent
Description: This cookie is set our GDPR Cookie Consent functionality. The cookies is used to store the user consent.
Stay: 1 year

viewed_cookie_policy
Description: This cookie is set our GDPR Cookie Consent functionality. The cookies is used to store if the user has viewed the privacy policy notice.
Stay: 1 year

Analytics cookies:

Analytics cookies are similar to technical cookies when used directly by the site manager to collect information, in aggregate form, on the number of users and how they visit the site.

Used Cookies:

  1. Google Analytics (Google Inc.). Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Site, compiling reports and sharing them with other services developed by Google.
    Google may use the Personal Data to contextualize and personalize the advertisements of its own advertising network.
    Google has also made available a browser add-on for the deactivation of Google Analytics: Opt Out Google Analytics.
    Personal data collected: Cookies and Usage data.
    Shelf life: 14 months.
    Place of processing: USA
    Privacy Policy

_ga
Description: Register a unique ID that is used to generate statistical data on how the visitor uses the website.
Stay: 2 years

_gat
Description: Used by Google Analytics to limit the frequency of requests
Stay: 1 minute

_gid
Description: Register a unique ID that is used to generate statistical data on how the visitor uses the website.
Stay: 24 hours

  • Mailchimp.

Personal data collected: Cookies and Usage data.
Place of processing: USA.
Privacy Policymailchimp_landing_site
Description: This cookie is set by Mailchimp to store which page was visited first. Its purpose is to permit statistical data.
Stay: 1 month

Profiling cookies

Profiling cookies are aimed at creating user profiles and are used in order to send advertising messages in line with the preferences shown by the user in the context of web browsing. Due to the particular invasiveness that such devices may have in the private sphere of users, European and Italian legislation provides that the user must be adequately informed about their use and express their valid consent.

First-party cookies

These are cookies managed by the Website Owner. For these cookies, the obligation of disclosure rests with the owner of the site. The latter also has the obligation to indicate the methods for the possible blocking of the cookie.

Third-party cookies

Cookies are managed by a third party other than the Website Owner. For these cookies, the obligation of the information and the indication of the modalities for the possible blocking of the cookie lies with the third party, while the Website Owner is obliged to insert on the site the link to the website of the third party where these elements are available.

In both types of cookies (first-party or third-party) the collection of consent, necessary if the cookie is a profiling cookie, occurs through a special banner on the home page of the site.

Used cookies

Profiling cookies:

  1. Jetpack (Automattic Inc.). Jetpack simplifies the management of WordPress sites by offering visitor statistics, security services, making image viewing faster and allowing you to get more traffic.
    Personal Data collected: Cookies and Usage Data
    Place of processing: USA
    Privacy Policy

tk_lr, tk_ortk_r3d
Description: referral cookies used to analyse referrer behavior for Jetpack connected sites using WooCommerce.
Organization: Automattic
Stay: 1 year.

tk_ai, tk_qs
Description: Gathers information for analytics tool about how website services are used. A collection of internal metrics for user activity, used to improve user experience.
Organization: Automattic
Stay: 1 year.

2. Facebook Pixel

We use the “visitor action pixels” from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our website. This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter a GDPR[UeN1] . You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
Personal data collected: Cookies and usage data.
Place of processing: Ireland.
Privacy Policy


Remember that you can also manage your cookie preferences through the browser.

If you do not know the type and version of browser you are using, click on “Help” in the browser window at the top, where you can access all the necessary information.

If you know your browser, click on the one you are using to access the cookie management page.

Internet Explorer

https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11

Google Chrome

https://support.google.com/accounts/answer/61416?hl=it

Mozilla Firefox

http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies

Safari

http://www.apple.com/legal/privacy/

To change your privacy settings please refer to the button below:

Cookie settings

To request the complete deletion of your data please email us to: info@upsurgeon.com