Privacy & Cookie Policy

Boole Server Srl, with registered office at Via Melchiorre Gioia 112/A, Milan (hereinafter “Company”, “us” or “our”), in its capacity as data controller, is committed to protecting the privacy of the user. This privacy policy (“Privacy Policy”) only applies to the website www.boolebox.com and to any other website or service controlled by the Company through which the Privacy Policy is published or referred to (hereinafter, collectively, the “Site”).
Please, read the Privacy Policy carefully before using the Site.

1. The Site
The main purpose of the Site is to display products and services of the Company, by providing users with detailed information.
In addition, the following services are also provided through the Site:

sale and/or use even free of charge of Company products and/or services;
customer care, both for current and future customers, on Company products and/or services through chats, messages and call centers;
webpage for spontaneous application and CV submission to the Company.

This Privacy Policy describes how we collect, use and share the personal data we obtain as a result of the use of the Site by users.
As the Company reserves the right to add or remove features from the Site and to modify the services and/or products offered at any time, the Privacy Policy may be updated by the Company at any time and users and visitors of the Site will be notified of any change made.
As the Site may allow access to websites owned and operated by third parties, we would like to point out that the Privacy Policy does not apply to such third party web sites and the Company is not responsible for the protection of personal data by such third parties.

2. Data processed
Data voluntarily provided by the user. The Company may collect the following personal data voluntarily provided by the user:

user’s name and surname
his/her domicile or residence address,
his/her email address, telephone number
his/her date of birth
his/her CV
details of purchased products and/or services

We may collect data, for example, when the user purchases and/or uses even free of charge a product and/or service from us, contact us for information about our products and/or services, submit his/her CV, create an account, take part in a survey or participate in our prize-giving events.
If the user provide us with personal data of third parties, the user shall do whatever is necessary to ensure that the communication of data to the Company and our subsequent processing for the purposes specified in this Privacy Policy is carried out in compliance with applicable laws, so that for example the user, before providing us with personal data of third parties, shall inform them and obtain their consent to the processing, if required by the aforementioned laws. The Company processes the personal data of third parties only to allow the use of our products and/or services depending on the requests of the user registered on the Site.
Browsing data. Browsing data includes all data automatically collected through the Site and relates, for example, to the types of actions the user performs on the Site and how the user is using the Site. In addition, we may automatically record your IP address (i.e. the unique address that identifies the user’s device on the Internet), which is automatically recognized by our server. Unless the user expressly consents to the purpose as described in point 3.D, browsing data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its proper functioning and are immediately deleted after their processing. Such data may also be used to ascertain liability in the event of cybercrimes against the Site or to protect our rights.

3. Purposes and processing legal bases

4. Nature of providing data and consequences of possible refusal
Providing data for the purposes referred to at points 3.A, 3.D and 3.E is necessary and denial thereof would make it impossible for the Company to perform its contractual obligations and provide the user with the functionality, services and information requested as specified above. Providing data for the purposes referred to in point 3.D is automatic and implicit in the transmission protocols of the Internet. Providing data for the purposes referred to in points 3.B and 3.C is voluntary and any refusal thereof will have no effect on the provision of services to the user, on functionality and on information requested through the Site.

5. Data recipients
Subsidiary, controlled or controlling Companies. The Company discloses users’ personal data to its subsidiaries, controlled and controlling Companies, including those located outside the European Union, where necessary to pursue the purposes described in this Privacy Policy.
Third party service providers. We share users’ personal data with third party service providers acting as data processors in order allow the use the Site and/or receive services through the Site. For example, such third parties may include professionals, also in associate form, providing technical, commercial or administrative advice to the Company for the performance of its activities and the purposes described in this Privacy Policy, companies that manage or maintain the information infrastructure on which the Site is built, call center service providers or pre-sales or after-sales assistance service providers, logistics operators if it is necessary to deliver a product to the user, agencies specialized in the management of promotional and marketing services in name of and on behalf of the Company.
Third parties in compliance with a legal obligation or to protect the rights of the Company. The disclosure of users’ personal data may be made to institutions, law enforcement agencies, judicial, administrative, regulatory or public security authorities, in the context of legal or administrative proceedings, or in order to comply with a legal obligation or protect our rights, even in court.
Third parties in case of corporate operations. The disclosure of users’ personal data may occur in connection with events such as mergers, transfers of business (or a branch of business) or other extraordinary operations in which the Company may have to share information with potential buyers or counterparties and their advisors.

6. Child data
The Company does not intentionally collect or store personal data of individuals under the age of 18, nor does it intentionally allow such individuals to use the Site.
Users under the age of 18 are kindly requested not to register on the Site and not to provide any personal data.

7. International data transfers
The Company may need to transfer users’ personal data abroad to provide services to the users and to pursue the other purposes indicated in this Privacy Policy. Before proceeding with the transfer of data outside the European Union, the Company will adopt all appropriate measures, including contractual measures as provided under the applicable Privacy Law, in order to guarantee the protection, security and confidentiality of the personal data transferred (for instance, it will adopt the Standard Contractual Clauses adopted by the European Commission) or, if the recipient of users’ personal data is established in the United States, the Company will verify that the recipient regularly adheres to the “Privacy Shield” program.

8. Data retention
We retain personal data of the users only for the time strictly necessary either in order to provide services or to achieve the purposes for which the data were collected, or in compliance with legal obligations. For example, we retain personal data necessary for the exercise of our rights of defence in the event of legal disputes, such as personal data relating to a contract or the provision of a service, up to a maximum of 10 years from the conclusion of the service provision and/or the supply of the product, on the basis of the ordinary limitation period prescribed by the Civil Code.
After such time limits, personal data will be deleted or rendered anonymous.
In the event that we have collected personal data based on the user’s consent and we no longer have any other valid legal basis to continue the data processing, if the user subsequently withdraws his or her consent we will delete the personal data covered by such withdrawal. Without prejudice to the foregoing, we retain the personal data of users collected in accordance with this Privacy Policy for the marketing purposes referred to in paragraph 3.B for a period not exceeding 2 years from their collection and for profiling purposes referred to in point 3.C for a period of time not exceeding 12 months from their collection.
After such time limits, the data will be deleted or rendered anonymous.

9. Cookies
A “cookie” is a small text file sent by the websites visited by users and stored on the device used to access these websites. When users visit the same site again, the browser reads the cookies stored on the device and retransmits the information to the site that originally created the cookies. Our Platform uses different types of cookies and other technologies for reading and storing information on the user’s device in order, for example, to perform statistical analysis, customize and facilitate the browsing experience of users and, with users’ prior consent, offer users advertising based on their interests. We do not use cookies that have the ability to start programs on devices or to send viruses on them.
Our Site uses technical cookies, for which the user’s consent is not required, which are necessary for the functioning of the Platform, including the provision of the services it offers. This category of cookies includes analytics, session cookies and functionality cookies, used by the owner for example, to collect information, in aggregated form, on the number of users and how they visit the website, to save users’ browsing preferences, such as the language, or to recognize the user who returns to the website.
Our Site also uses its own and third-party profiling cookies, aimed at creating profiles related to the user and used to send and show advertising communications in line with the preferences expressed by the same during navigation. User consent is required for profiling cookies.
The aforementioned cookies can be either temporary (when they are automatically deleted at the end of the session), or permanent (when they remain stored on the users’ hard disk, unless the user deletes them), First-Party Cookies (when they are set and managed directly by us) and Third-Party Cookies (when they are managed by a third-party website domain).
Since most browsers are set to automatically accept cookies, we remind the user that either he or she can manage and disable cookies directly from your browser settings:

or through the portal www.youronlinechoices.com/it or by sending an e-mail to us at the address legal@boolebox.com.
In the chart below we provide you with details about the cookies used on our Site.

10. Data security
The Company implements security measures in order to ensure the confidentiality of users’ personal data. Nevertheless, due to the design of the Internet, ever-changing technology, and other factors outside of our control, the security of data transmission via the Internet cannot be totally guaranteed, therefore we cannot ensure or guarantee the security of data and of the information that the user transmits to us and the user acknowledges and agrees to bear the risks of such transmission. It is recommended that the user adopts precautionary measures when using the Site, such as keeping the Site access information confidential and change it regularly.

11. Privacy rights
The user has the right to access, rectify or delete the data stored by the company that concerns him or her, as well as the right to object to, or restrict, certain types of processing (including the right to withdraw his or her consent to the processing as previously given), as well as to receive personal data concerning him or her in a structured, commonly used and machine-readable format (right to data portability). Finally, the user has the right to lodge a complaint with a competent Supervisory Authority. The exercise of the above rights is free of charge but in case we consider the exercise of the privacy rights by the user manifestly unfounded or excessive, we can reserve ourselves to charge the requesting user a reasonable fee for attending the request. To exercise your privacy rights, as well as to request any information or clarification regarding this Privacy Policy, you can contact the Company at the following addresses: legal@boolebox.com

Purpose	Legal basis
A. The Company processes the user’s personal data in order to provide the product and/or service at the user’s request, to respond to or satisfy an user’s request, including pre-sales and post-sales assistance, the creation of an account, the request to evaluate the user’s CV for recruiting purposes, as well as to ensure and manage participation in initiatives, events or promotions the user has chosen to participate in.	A. For such purposes the Company processes data for the performance of a contract and/or in order to take steps at the request of the user prior to entering into a contract.
B. The Company processes the user’s personal data in order to send the user promotional information regarding Company and/or third party services and/or products, to send invitations to Company and/or third party events and to carry out market surveys, through automated means (email, sms, mms, fax, autoresponders) and not automated means (paper mail, telephone calls with operator), without prejudice to the possibility for the user to oppose the sending of such communications at any time, including being able to select the means the user may or may not be contacted with.	B. The Company processes data for such purposes with the user’s prior consent only.
C. The Company processes the user’s personal data for profiling purposes related to advertising and/or commercial purposes, to customize services on the basis of the user’s particular characteristics and, for example, to offer contents in line with the user’s interests and to develop services that are increasingly in line with the user’s needs. The user has the right to withdraw his/her consent at any time.	C. The Company processes data for such purposes with the user’s prior consent only.
D. The Company processes user’s personal data in order to ensure that the Site is up to date and meets the users’ needs, to analyze, review and improve the products or services offered on the Site, to provide users with a user-friendly Site browsing experience, to ensure compliance with the Site’s terms of use, the security of the Site and its users and to protect the rights and/or assets of the Company. Information used for this purpose will be kept strictly anonymous and will not be used to identify any user nor will it be associated with users’ personal data.	D. For such purposes the Company processes data in order to pursue its legitimate interest in protecting its assets, its business and its rights.
E. The Company processes the user’s personal data in order to fulfil obligations deriving from the law, regulations or the EU legislation.	E. For such purposes the Company processes data for compliance with a legal obligation.

Categories	Types and name	Duration
Publisher’s cookies	ASP.NET_SessionId This cookie contains encrypted information about the logged user, checking if the same is authenticated	30 days
Publisher’s cookies	Login This cookie contains encrypted information about the logged user, checking if the same is authenticated	30 days
Publisher’s cookies	SSO This cookie verifies if the user has Single Sign On enabled	30 days
Publisher’s cookies	localStorage: preferences_{id_utente} This cookie contains the preference of a viewing mode of a user (grid, list, small)	30 days
Publisher’s cookies	Login.Trust Identification of the device considered safe to avoid repetition in the two steps verification.	1 year
Publisher’s cookies	This cookie keeps in the memory the status of the pop up with values 1- 0	3 days
Third party’s cookies	Google Analytics .ga; .gid https://www.google.com/intl/it_ALL/analytics/learn/privacy.html	2 years
Third party’s cookies	Zendesk Chat https://www.zendesk.it/company/customers-partners/privacy-policy/	unlimited
Third party’s cookies	Facebook Pixel Code https://www.facebook.com/policies/cookies/	90 days