Dear user,
Our job is to manage lists of email addresses acquired from third-party suppliers in order to send on these lists marketing and advertising communications on behalf of our clients.

More clearly: we build lists of email addresses from lists acquired from different suppliers and we use these lists to send advertising on behalf of our client companies.

This means that the collection of your personal data was not done directly by us but by third parties (suppliers) who have recorded your personal data on their computer systems (i.e. personal data of users who, like you, receive marketing and commercial communications).

Why do you have and process my personal data?

If you have previously participated in sweepstakes, quizzes, or online games held by one or more of our suppliers, then it is possible that your data were recorded and then transferred to us.

It is also possible that you have allowed the use of your personal data for marketing and advertising purposes following the subscription to services offered by many different online services: from weather forecasts to dating services, from sports newsletters to financial information, from registration to e-commerce sites to download apps for mobile phones and smartphones.

The suppliers you talk about can give you my data?

We ask all our suppliers, i.e. the subjects who provide us with the email lists, that the personal data of the users have been collected in accordance with the Italian law on privacy in force since 2003. In other words we ask that the data have been collected by consent of the interested party. According to the new General Regulation (Article 4 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, the "GDPR"), the consent is any manifestation of free, specific, informed and unequivocal interest, with which he expresses his assent, by declaration or unequivocal positive action, to the processing of personal data concerning him.

In particular, we request that all data that are given to us have been previously authorized by users. Or, better said, we ask that the data be given to us only after every single user has expressed the consent (informed and separated) also to the transfer of such information to companies that like us do the job of sending promotional emails.

In fact, we do not simply ask it with courtesy, we contractually impose it on all our suppliers.

This means that if you have doubts about the lawfulness of the data processing (= it is impossible that the site from which you say you have received my data obtained them from me and voluntarily) please inform us immediately. In addition to a violation of the law on privacy would also be the hypothesis of non-compliance with the contractual terms.

I did not know anything about it and now I want you to stop processing my data.

Among the multitude of email lists we manage, we do not exclude that  may have occurred cases in which the user was not adequately informed or that the privacy policy was not clear enough to allow the user to understand what he was doing and therefore the data collection was (in good faith) vitiated by the origin. For this reason we provide the tools that the GDPR requires us to make public to all our users.

There is the right to delete data established by art. 17 of the GDPR in relation to the revocation and / or opposition to the processing of data.

For this reason , please read the privacy notice drawn up in compliance with art. 14 of the GDPR and, if it is not completely clear, contact us at the address indicated in art. 4.

Privacy Notice to Users

iQube S.r.l. with registered office in Via Vespri Siciliani, 34 - 20146 Milan (MI) ITALY, (hereinafter, "Holder"), provides below the privacy policy pursuant to art. 14 of EU Regulation 2016/679 of 27 April 2016 (hereafter, "Regulations" or "Applicable Regulations") as data controller of the personal data of users whose personal data have been regularly purchased by the Data Controller (hereinafter " Users "or, individually, the" User ").

The Owner takes really seriously the right to privacy and protection of personal data of its Users. For any information related to this privacy statement, Users may contact the Data Controller at any time, using the following methods:

The Data Controller has not identified the person in charge of data protection (RPD or DPO), as it is not subject to the obligation of designation provided for by art. 37 of the Rules.

1. Purpose of the processing

Users' personal data will be processed lawfully by the Data Controller pursuant to art. 6 of the Regulations for the following processing purposes:

a) because the Users have given their consent, for the purpose of communicating to third parties for direct marketing purposes, to the subject from which the Data Controller has regularly acquired the data: the User's personal data (ie the surname name, email address, telephone number as well as some profiling data such as sex and age ....) will be processed by the owner for marketing purposes (sending advertising material, direct sales, commercial communication), or in order for the owner to contact the user via mail, email, telephone (fixed and / or mobile, with automated call or call communication systems with and / or without the intervention of an operator) and / or SMS and / or MMS to propose to the User the purchase of products and / or services offered by the Owner and / or third-party companies, submit offers, promotions and business opportunities.

The User may at any time revoke the consent given, making a request to the Data Controller in the manner indicated in the following paragraph 4.

The User can also easily oppose further sending of promotional communications via email by clicking on the appropriate link for the revocation of consent, which is present in each promotional email. Once the consent has been withdrawn, the Data Controller will send an e-mail to the User to confirm the revocation of the consent. If the User intends to withdraw his consent to the sending of promotional communications by telephone, however continuing to receive promotional communications via email, or vice versa, please send a request to the Owner in the manner indicated in paragraph 4 below.

The Data Controller informs that, following the exercise of the right of opposition to the sending of promotional communications via email, it is possible that, for technical and operational reasons (eg formation of contact lists already completed shortly before receipt by the Owner of the opposition request) the User continues to receive some further promotional messages. Should the User continue to receive promotional messages after 24 hours have elapsed from the exercise of the right of opposition, please report the problem to the Holder, using the contacts indicated in paragraph 4 below.

b) administrative-accounting purposes, or to perform activities of an organizational, administrative, financial and accounting nature, such as internal organizational activities and activities functional to the fulfillment of contractual and pre-contractual obligations;

c) legal obligations, or to fulfill obligations under the law, an authority, a regulation or European legislation.

2. Processing methods and data retention times

The Data Controller will process the personal data of Users using manual and IT tools, with logic strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of the data.

Users' personal data will be kept for the time strictly necessary to carry out the primary purposes described in paragraph 1 above, or in any case as necessary for the protection in civil law of the interests of both the Users and the Data Controller.

In the cases referred to in paragraph 1 a) the personal data of Users will be kept for the time strictly necessary to carry out the purpose illustrated in the same and, in any case, for no more than twenty-four (24) months (as required by the Measure of a general nature of the Guarantor for the protection of personal data called "Fidelity card" and guarantees for consumers, the rules of the Guarantor for loyalty programs "of 24 February 2005).

3. Scope of communication and dissemination of data

The personal data of the Users may be disclosed to the employees and / or collaborators of the Data Controller in charge of managing the data. These subjects, who are formally appointed by the Data Controller as "in charge of processing", will process the User's data exclusively for the purposes indicated in this statement and in compliance with the provisions of the Applicable Law.

The personal data of the Users may also be disclosed to third parties who may process personal data on behalf of the Data Controller as "External Processors", such as, for example, IT and logistic service providers functional to the activities of the activities. , outsourcing or cloud computing service providers, professionals and consultants.

Users have the right to obtain a list of any data controllers appointed by the Data Controller, upon request to the Data Controller in the manner indicated in paragraph 4 below.

4. Rights of the interested parties

Users may exercise their rights granted by the Applicable Law by contacting the Data Controller in the following ways:

Pursuant to Applicable Regulations, the Data Controller informs that Users have the right to obtain indication (i) of the origin of personal data; (ii) the purposes and methods of the processing; (iii) the logic applied in the event of processing carried out with the aid of electronic instruments; (iv) of the identification details of the owner and managers; (v) the subjects or categories of subjects to whom the personal data may be communicated or who may come to know them as managers or agents.

Furthermore, Users have the right to obtain:

a) access, updating, rectification or, when interested, integration of data;

b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;

c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment is it proves impossible or involves a use of means manifestly disproportionate to the protected right.

Furthermore, Users have:

a) the right to withdraw consent at any time, if the processing is based on their consent;

b) the right to data portability (right to receive all personal data concerning them in a structured format, commonly used and readable by automatic device), the right to limit the processing of personal data and the right to cancel (" right to be forgotten ");

c) the right to oppose:

i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;

ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;

iii) if personal data are processed for direct marketing purposes, at any time, to the processing of their data for this purpose, including profiling in so far as it is connected to such direct marketing.

d) if they believe that the treatment that concerns them violates the Regulation, the right to lodge a complaint with a Supervisory Authority (in the Member State in which they usually reside, in the one in which they work or in the one in which the alleged violation has occurred ). The Italian Supervisory Authority is the Guarantor for the protection of personal data, located in Piazza di Monte Citorio n. 121, 00186 - Rome (http://www.garanteprivacy.it/).

The Owner is not responsible for updating all links that can be viewed in this Notice, therefore whenever a link is not functional and / or updated, Users acknowledge and accept that they must always refer to the document and / or section of the websites referred to by this link.