Informative note pursuant to legislation on personal data protection

The Legislative Decree no. 196 of 30 June 2003 (“Privacy Code”) and the new European regulation, the GDPR (General Data Protection Regulation) regulation EU and 27 April 2016 no. 2016/679/EU aim at guaranteeing that the treatment of your personal data develops in the respect of the rights, of the fundamental liberties and of the dignity of the people, with particular reference to the reservation and the personal identity. It is therefore our duty to inform you about our privacy policy.

1. Processing purposes

1.1 We inform you that, pursuant to Art. 13 of the Civil Code on the subject of protecting personal data, the personal data you provided at the time of registering to the Service Combivox Cloud, or otherwise acquired in the course of our activity, may be processed for purposes related to the Service. After the registration, pursuant to Art. 130 para. 4 of D.LGS. 196/2003 we could send you e-mails concerning services similar to those provided and you can object to the sending of e-mails at any time.

1.2 Your data will be used, if permission is granted, to send information and commercial offers, also by third parties who belong to the same corporate group of Combivox S.r.l. Unipersonale to which the data controller will be able to communicate the personal data you provided.

1.3 Your data will be used, if permission is granted, to gather general data and information and in particular on your interests and/or preferences.

2. Methods of processing

2.1 The data are collected by the subjects listed under point 5, according to the guidelines of the Privacy Code, in particular in respect of the minimum security measures set out (Articles 33-34), and of the GDPR (Art. 32) with regard to their processing by means of ICT tools, both manual and automated with logic strictly related to the purposes indicated above and, nonetheless, in such a way as to ensure its security and confidentiality.

2.2 In compliance with the applicable legislation, an anti-spam verification system is in place for communications delivered through the announcement reply form made available to users.

The data provided can be verified so as to identify illegal activities or contents which do not comply with the general terms of the Service, but will not be processed or communicated for commercial or promotional scopes.

3. Type of data processed and optionality of providing data.

3.1 The simple navigation of the Site involves the collection by Combivox S.r.l. of so-called “navigation data”, the transmission of which is implicit in the use of Internet communication protocols. This category of data includes: IP addresses, the type of browser used, the operating system, the domain name and website addresses from which log in or out is effected, information on pages visited by the User within the Site, the time of access, the permanence on the single page, the internal path analysis and other parameters regarding the operating system and computer environment, as well as data derived from cookies and/or similar technologies. This technical data is collected and used only in an aggregated and non-identifiable way, but may be used to ascertain responsibility in the event of hypothetical crimes against the Site. However, navigation data does not in itself identify the User. The Site offers specific services that benefit the User and for which the User must provide additional data, classified as personal data. For example, registration to the Site, access to reserved areas on the Site and the purchase of Combivox S.r.l. products and services, are all activities that involve the transfer by the User of personal data that permit Combivox S.r.l. to uniquely identify the User such as, but not limited to, name, surname, date of birth, address of residence and/or home address, telephone number, e-mail address, credit card data. The provision of your personal data is absolutely optional; however, the refusal to enter such data in the registration page for the purposes of the provision of the service (point 1.1) makes it impossible to use the Service offered by the websites www.combivox.it and www.combivoxcloud.com.

3.2 The provision of your personal data is optional for commercial purposes (point 1.2) and profiling (1.3) and a possible refusal to give the consent will not have consequences on using the Service.

4. Categories of persons to whom personal data can be transmitted

4.1 The data collected for aims of Service supply (point 1.1) may be shared with companies who perform functions closely related and instrumental to the operability of the Service, or, however, which carry out services aimed for verifying that the publication of announcements is not aimed at the violation of exclusive rights of third parties. The data may be divulged to connected companies and/or companies that belong to the same corporate group of Combivox S.r.l. Unipersonale.

4.2 The data collected for commercial purposes (point 1.2) and for profiling (point 1.3) may be transferred to third parties that belong to the same corporate group of Combivox S.r.l. Unipersonale, also for the sale or attempted sale, or for commercial and/or authorized statistical purposes. The list of the subjects to whom your personal data are provided can be requested to the data holder by sending an e-mail to the address of point 6.2.

5. The data holder, controllers and processors

5.1 Combivox S.r.l. Unipersonale is the data holder, represented by its pro-tempore legal representative, with registered office in Acquaviva delle Fonti (BA), Via Vito Giorgio  Lotto  126 ZI, Tax Code and Vat No. 05363360727. It independently establishes the purposes and methods of processing, as well as security procedures to be applied to ensure the confidentiality, integrity and availability of data.

5.2 Combivox S.r.l. Unipersonale may designate one or more persons, such as controllers within the meaning and effect of Art. 29 of the Privacy Code. The “data processors” conduct their activities in accordance with the instructions provided by Combivox S.r.l. Unipersonale and under its control; Combivox S.r.l. Unipersonale periodically verifies that the “data processors” have fulfilled their tasks and continue to offer sufficient guarantees in full compliance with the provisions on the protection of personal data. The data holders make use of external controllers to achieve the purposes specified in points 1.1 (technical purposes for the provision of the service), 1.2 (commercial purposes) and 1.3 (profiling purposes). A complete list of the Data processors may be requested by sending an e-mail to the address indicated in point 6.2 of the present data privacy.

6. The rights of persons concerned

6.1 We remind you that, at any time, you are entitled to obtain by the joint holders information concerning your personal data, their origin, purposes and methods of processing; you are also entitled to request the updating, rectification, integration, cancellation, anonymization or blocking of any personal data processed unlawfully, including data whose retention is unnecessary for the purposes for which the personal data were collected or subsequently processed;

6.2 For the exercise of your rights, we provide a dedicated e-mail address: dataprotection@combivox.it

6.3 We remind you that you have the right to lodge a complaint with a supervisory authority.

6.4 In the event that you are no longer interested in the communications of Combivox S.r.l. Unipersonale and you would like to cancel the newsletter subscription, you can do it by clicking on the link “cancellation” at the bottom of every e-mail sent by Combivox S.r.l. Unipersonale.

7. Further information on cookies and similar technologies

7.1 Cookies and similar technologies

7.1.1 www.combivox.it and www.combivoxcloud.com use cookies. These are small text files that are stored on your device while you are browsing the Services of www.combivox.it and www.combivoxcloud.com. Cookies can be stored permanently on your device and have a variable duration (persistent cookies), they can erase themselves when the browser is shut down or they can have a limited duration (session cookies). Cookies can be installed by www.combivox.it and www.combivoxcloud.com or can be installed from other websites (third-party cookies).

7.1.2 The main reasons for the cookies installed by www.combivox.it and www.combivoxcloud.com are: technical, so they are used to constantly improve the Service – statistical, such as counting the number of visits to the websites www.combivox.it and www.combivoxcloud.com. The use of cookies is therefore strictly targeted at facilitating the operations of the server of www.combivox.it and combivoxcloud.com while browsing the site.

8. Redirecting to external sites

The Site may use so-called social plugins. Social plugins are special tools that allow Users to incorporate the functionality of social networks directly within the Site (e.g. The “Like” button on Facebook). All social plugins on the Site are marked by the respective property logo of the social networking platform. When the User visits a Site page and interacts with a plugin (e.g. by clicking the “Like” button) or decides to leave a comment, the corresponding information will be transmitted from the User's browser directly to the respective social networking platform (Facebook this case) and stored. For information regarding the purpose, type and method of collection, processing, handling, use and storage of personal data by social network platforms, as well as the ways in which they exercise their rights, please consult the privacy policy of the social networking platform in question.

9. Connecting to/from third party sites

The User can connect through special links on the Site to other third-party websites. Combivox S.r.l. Unipersonale does not control or monitor such websites or their content. This Privacy Policy does not apply to third-party websites. The Site provides links to other websites exclusively to facilitate the User in research and navigation and to provide easy links via the Internet to other websites. Links to other websites do not imply any endorsement by Combivox S.r.l. Unipersonale or responsibility in regard to access and navigation by the User of such websites, or any guarantee of their contents, services or goods provided by them and sold to Users. Combivox S.r.l. Unipersonale, therefore, declines any responsibility regarding the content of these websites and the regulations adopted by them, even with regard to the protection of personal data and its processing during navigation within the websites in question.

10. Security measures

Combivox S.r.l. Unipersonale takes appropriate security measures in order to minimize the risk of destruction or loss - even accidental - of data, unauthorized access or processing that is not allowed or not in accordance with the collection purposes indicated in this Privacy Policy. However, Combivox S.r.l. Unipersonale cannot guarantee to Users that the measures taken for the security of the Site and the transmission of personal data and information on the Site will prevent or exclude risk of unauthorized access or dispersion of data via the User's own devices; it is suggested, therefore, that the User checks the security of the computer or device in use and makes sure that it is equipped with appropriate security software (such as updated antivirus systems) for the protection of incoming and outgoing data transmissions on the network, and that the User's Internet service provider has taken appropriate measures for the security of network data transmission (such as firewalls and spam filters).

11 Changes

This information may be subject to changes. If substantial changes are made by Combivox S.r.l. Unipersonale to the use of data relating to the user, Combivox S.r.l. Unipersonale will alert the user by posting these changes and highlighting them clearly on their pages. For this purpose, this document shows the date of updating.

Latest update 06/02/2018

Notes - The processing of personal data means collecting, recording, organising, storing, processing, modifying, selecting, extracting, comparing, using, disseminating, erasing, distributing and interconnecting them and everything else that is of use for the delivery of the Service, including the combining of two or more of these operations.


Combivox S.r.l. Unipersonale – Registered office: Via Vito Giorgio Lotto 126 ZI - 70021 Acquaviva delle Fonti (BA)

Tax Code and Vat no./Company Register in Bari: 05363360727