The purpose of this document is to inform the natural person (hereinafter “Interested party “) regarding the processing of your personal data (hereinafter”Personal Data “) collected by the data controller, API SU APE snc di Bollini Gianluca and Bollini Beatrice, with registered office in Via Salvo D’Acquisto 1, 20812 Limbiate (MB), CF / VAT number 11771110969, REA MB-2623889, address e-mail, (hereinafter “Owner “), through the application (hereinafter”Application “).

Changes and updates will be binding as soon as they are published on the Application. In case of non-acceptance of the changes made to the Privacy Policy, the interested party is required to cease using this Application and may request the Data Controller to delete their Personal Data.

  • Categories of Personal Data processed

The Data Controller processes the following types of Personal Data provided voluntarily by the Data Subject:

  • Contact details: name, surname, address, e-mail, telephone, images, authentication credentials, any additional information sent by the interested party, etc.
  • Tax and payment data : tax code, VAT number, credit card details, bank account details, etc.

The Data Controller processes the following types of Personal Data collected in an automated manner:

  • Technical data: Personal data produced by the devices, applications, tools and protocols used, such as, for example, information on the device used, IP addresses, type of browser, type of Internet provider (ISP). Such Personal Data may leave traces which, in particular when combined with unique identifiers and other information received from servers, can be used to create profiles of natural persons
  • Browsing and use data of the Application : such as, for example, pages visited, number of clicks, actions performed, duration of sessions, etc.

Failure by the Data Subject to provide Personal Data for which there is a legal or contractual obligation or if they constitute a necessary requirement for the conclusion of the contract with the Data Controller, will make it impossible for the Data Controller to establish or continue the relationship with the Interested.

The interested party who communicates the Personal Data of third parties to the Data Controller is directly and exclusively responsible for their origin, collection, processing, communication or dissemination.

  • Cookies and similar technologies

The Application uses cookies, web beacons, unique identifiers and other similar technologies to collect the Personal Data of the Data Subject on the pages, links visited and other actions that are performed when the Data Subject uses the Application. They are stored to be then transmitted to the next visit of the interested party. The complete Cookie Policy can be viewed at the following address:

  • Legal basis and purpose of the processing

The processing of Personal Data is necessary:

  • for the execution of the contract with the interested party and precisely:
    • fulfillment of any obligation deriving from the pre-contractual or contractual relationship with the interested party
    • registration and authentication of the interested party: to allow the interested party to register on the Application, access and be identified also through external platforms
    • support and contact with the interested party : to respond to the requests of the interested party
    • payment management : to manage payments by credit card, bank transfer or other tools
  • by law and precisely:
    • the fulfillment of any obligation envisaged by current regulations , laws and regulations, in particular, in tax and fiscal matters
  • on the basis of the legitimate interest of the Data Controller, for:
    • marketing purposes via email of the products and / or services of the owner to directly sell the products or services of the owner using the email provided by the interested party in the context of the sale of a product or service similar to the one being sold
    • management, optimization and monitoring of the technical infrastructure : to identify and solve any technical problems, to improve the performance of the Application, to manage and organize information in a computer system (e.g. server, database, etc.)
    • security and anti-fraud : to guarantee the security of the Owner’s assets, infrastructures and networks
    • statistics with anonymous data : to perform statistical analysis on aggregate and anonymous data to analyze the behavior of the interested party, to improve the products and / or services provided by the Data Controller and better meet the expectations of the interested party
  • on the basis of the consent of the interested party, for:
    • retargeting and remarketing : to reach with a personalized advertisement the Data Subject who has already visited or has shown interest in the products and / or services offered by the Application using his Personal Data. The interested party can opt out by visiting the Network Advertising Initiative page
    • marketing purposes of the Controller’s products and / or services : to send information or commercial and / or promotional materials, to carry out direct sales of the Controller’s products and / or services or to carry out market research using automated and traditional methods
    • detection of the exact position of the interested party : to detect the presence of the interested party, to check the accesses, times and presence of the interested party in a specific place, etc.

Based on the legitimate interest of the Data Controller, the Application allows interaction with external platforms or social networks whose processing of Personal Data is governed by the respective privacy policies to which please refer. The interactions and information acquired by this Application are in any case subject to the privacy settings that the interested party has chosen on such platforms or social networks. This information – in the absence of a specific consent to the processing for further purposes – is used for the sole purpose of allowing the use of the Application and providing the requested information and services.

The Personal Data of the interested party may also be used by the Data Controller to protect themselves in court before the competent judicial offices.

  • Methods of processing and recipients of Personal Data


The processing of Personal Data is carried out using paper and IT tools with organizational methods and with logic strictly related to the purposes indicated and through the adoption of adequate security measures.

Personal Data are processed exclusively by:

  • persons authorized by the Data Controller who are committed to confidentiality or have an adequate legal obligation of confidentiality;
  • subjects who operate independently as separate data controllers or by subjects designated as data processors by the Data Controller in order to carry out all the processing activities necessary to pursue the purposes referred to in this information (for example, commercial partners, consultants, IT companies , service providers, hosting providers);
  • subjects or entities to which it is mandatory to communicate Personal Data by law or by order of the authorities.

The subjects listed above are required to use the appropriate safeguards to protect Personal Data and can only access those necessary to perform the tasks assigned to them.

Personal Data will not be disclosed indiscriminately in any way.

  • Place

Personal Data will not be subject to any transfer outside the territory of the European Economic Area (EEA).

  • Retention period of Personal Data

Personal Data will be kept for the period of time necessary to fulfill the purposes for which they were collected, in particular:

  • for purposes relating to the execution of the contract between the Data Controller and the Data Subject, they will be kept for the entire duration of the contractual relationship and, after termination, for the ordinary prescription period of 10 years. In the event of a judicial dispute, for the entire duration of the same, until the deadlines for appealing actions are exhausted
  • for purposes relating to the legitimate interest of the Data Controller, they will be kept until such interest is fulfilled
  • for the fulfillment of a legal obligation, by order of an authority and for legal protection, they will be kept in compliance with the timing provided for by said obligations, regulations and in any case until the limitation period provided for by the regulations in force
  • for purposes based on the consent of the interested party, they will be kept until the consent is revoked

At the end of the retention period, all Personal Data will be deleted or stored in a form that does not allow the identification of the interested party.

  • Rights of the interested party

Interested parties may exercise certain rights with reference to the Personal Data processed by the Data Controller. In particular, the interested party has the right to:

  • be informed about the processing of their Personal Data
  • withdraw consent at any time
  • limit the processing of your Personal Data
  • oppose the processing of their Personal Data
  • access your Personal Data
  • verify and request the rectification of their Personal Data
  • obtain the limitation of the processing of their Personal Data
  • obtain the cancellation of their Personal Data
  • transfer your Personal Data to another owner
  • lodge a complaint with the supervisory authority for the protection of your Personal Data and / or take legal action.

To exercise their rights, interested parties can send a request to the following e-mail address Requests will be dealt with by the Owner immediately and processed as soon as possible, in any case within 30 days.

Last updated: 21/10/2021