Privacy Policy

1. General Information

Twins for Service Srl, as Data Controller (hereinafter, the "Data Controller"), is committed to protecting your ("customer" or "you") personal data and complies with the applicable privacy regulations (Legislative Decree No. 196/2003, "Italian Privacy Code", European Regulation on personal data protection, "GDPR"). Your personal data is processed confidentially and transferred to third parties only as provided in this Policy or with your consent.
We process the personal data you provide us during the use of this website, registration on the website, or use of mobile apps (if applicable). Specifically, we process:

• Identifying personal data ("Data" or "Personal Data") you provide during registration on the website (e.g., in case of contact requests), in compliance with the Italian Privacy Code and the GDPR;
• Access logs to pages; amount of data transferred; sessions.

2. Purpose of Processing

As a rule, we process your Personal Data without your prior consent—in accordance with the Italian Privacy Code and GDPR—for the following purposes:

A) Service Purposes

• To fulfill your requests (e.g., managing contact requests);
• To allow you to register on the Website;
• To provide you with our services;
• To enable technical management of the site and its operational functions, including troubleshooting, statistical analysis, testing, and research;
• To prevent or detect fraudulent activities or abuses that may harm the Website;
• To comply with legal obligations, safeguard individual security, rights, and property of the Data Controller, and to counter fraud or technical problems.

Only based on your specific and prior consent for the following purposes:
B) Marketing Purposes

• To send you commercial communications, information, and news about our services or products.

3. Nature of Data Provision and Consequences of Refusal

Provision of your Data for the purposes described in section 2.A is mandatory. Without such provision, we cannot guarantee your registration on the Website or the provision of the services listed in section 2.A. Provision of Data for the purposes described in section 2.B is optional. You can therefore decide not to provide any data or revoke the processing of previously provided Data. In such cases, you will no longer receive our newsletters but will continue to receive our services and maintain the right to register on the Website as provided under section 2.A above.

4. Processing Methods

The processing of your Personal Data is carried out only if necessary and is performed electronically through the operations indicated in the Italian Privacy Code and GDPR, specifically: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, access, communication, blocking, deletion, and destruction of data. Such processing operations will be carried out by electronic and non-electronic means.

5. Data Access

Your Personal Data will be processed by our staff appointed for data processing (including but not limited to):

• Employees and consultants authorized to manage the website and provide related services, in their capacity as data processors and/or internal data controllers and/or system administrators;
• Employees and consultants of the legal, marketing, finance, administration, accounting departments, and other departments, in their capacity as data processors and/or internal data controllers;
• Third-party companies to which we, as Data Controller, outsource certain services, including processing operations, as external data processors.

6. Data Disclosure

We may disclose your Personal Data to third parties as autonomous data controllers and/or external data processors for the following reasons:

• To comply with obligations prescribed by law, regulations, protocols, and national and EU legislation;
• To implement orders from Authorities;
• To enable defense in judicial proceedings, for example, in the case of violations by web users.

7.Transfer of Data to Non-EU/EEA Countries

Information sent through our Website may be transferred to countries outside the European Union ("EU") and/or the European Economic Area ("EEA"), such as the USA. For example, this can occur if we use a technical service provider located outside the EU/EEA. If we transfer Personal Data outside the EU/EEA in this way, we will take measures to ensure that your privacy rights continue to be protected. In particular, we will only transfer Personal Data to such third countries when permitted, for example, based on an adequacy decision by the European Commission or based on appropriate safeguards provided by standard contractual clauses adopted by the European Commission.

8. Data Retention and Deletion

As Data Controller of your personal data, we retain Personal Data for as long as necessary to achieve the purposes for which the Data were collected and subsequently processed, including the retention period required by applicable law and, in any case, for a maximum period of 10 years from the termination of our relationship with you regarding service purposes.

9. Cookies

Cookies are small text files saved on your computer when you use our Website. They are used to make websites work more efficiently, improve user experience, and provide information about preferences expressed during the site visit or authentication to protected areas. Our Website uses Cookies that remain on your computer for different periods. Some expire at the end of each session, and some persist longer so that when you return to our Website, you benefit from a better user experience.
Web browsers allow you to control Cookies through browser settings. Most browsers allow blocking all Cookies or blocking Cookies from specific sites. Browsers may also help delete Cookies when you close the browser. However, please note that this might mean losing any preferences you set on the site. We invite you to consult technical information related to your browser for instructions. If you disable Cookies or refuse to accept a cookie, some parts of the service may not work correctly or may be considerably slower.
Cookies can be technical, analytical, or profiling. Our Website uses technical or "session" Cookies and persistent proprietary Cookies. Our Website also uses analytical Cookies set by third-party providers, e.g., Google Analytics. The Site does not use profiling Cookies.

10. Social Plugins

Our Website may use social media plugins ("Plugins"). These services are provided by Facebook Inc., LinkedIn, Twitter Inc., and Instagram LLC ("Providers").
If you access our Website containing such Plugins, your browser will create a direct connection to the servers of Facebook, LinkedIn, Twitter, or Instagram. The content of the Plugins is transmitted by the respective Providers directly to your browser and embedded in the site. By incorporating the Plugin, the Providers receive notification that your browser accessed the website, even if you do not have a profile or are not logged in. The information (including your IP address) is transmitted directly from your browser to a Provider’s server and stored there.
If you are logged into one of these services, the Providers may link your visit to our Website directly to your profile on Facebook, LinkedIn, Twitter, or Instagram. If you interact with the Plugins, e.g., by clicking "Like," "Tweet," or "Instagram," this information is also transmitted directly to a Provider’s server and stored there. Moreover, this information may be displayed on the social network, posted to your Twitter or Instagram account, and shown to your contacts.
To learn more about the purpose and scope of data collection, processing, and use by these Providers, as well as your rights and privacy protection settings, please consult the privacy policies of these Providers.
If you do not want Facebook, LinkedIn, Twitter, or Instagram to link data relating to your visit to our Website directly to your profile on those services, you must log out of those services before visiting our Website.

11.Your Rights as a Data Subject

In accordance with the conditions set forth in the Italian Privacy Code and GDPR, you have the following data protection rights as a user ("Data Subject") of our service:
Information: The right to request information about your Personal Data processed by us, as well as access to and/or a copy of such data. This must include information about processing purposes, categories of personal data, recipients or categories of recipients of data, and, where possible, the expected retention period or, if not possible, criteria for determining that period;
Right to Rectification, Deletion, or Restriction: The right to request rectification, deletion, or restriction of processing of personal data;
Right to Object and Withdraw Consent: The right to object to consent or withdraw consent at any time (without affecting the lawfulness of processing based on consent prior to its withdrawal);
Data Portability: The right to receive personal data you provided to us in a structured, commonly used, and machine-readable format and the right to transmit such data to another controller without opposition from us; this includes, where technically feasible, the right to have your personal data transmitted directly by us to another controller;
Right to Object to Processing: The right to object, for reasons related to your particular situation, to the processing;
Automated Decisions: The right not to be subject to decisions based solely on automated processing, including profiling, that have legal effects concerning you or similarly significantly affect you. If such automated decisions occur under applicable laws, the right to receive meaningful information about the logic involved, as well as the significance and consequences of such processing;
Right to Lodge a Complaint: The right to contact the Privacy Authority and, where applicable, to lodge a complaint with it.

12. Data Controller and Data Processor

The Data Controller of your Personal Data is Twins for Service Srl, with registered office at Via Giosuè Carducci, 31, 20123 Milan, Italy.
To exercise the rights listed above or to request information, you can use the contact details provided on the Contacts page or in the website footer.

13. Changes to this Policy

We reserve the right to modify and amend this Policy in accordance with applicable privacy legislation.