Information regarding personal data under Law 21/12/2018, no. 171 – EU Regulation 2016/679


  1. Interested parties


This information concerns the processing of personal data of customers, suppliers, employees of customers, employees of suppliers, applicants for job positions, users of websites.


  1. Who is the Owner


The Data Controller of Personal Data is Armony S.r.l., 47891 Dogana (RSM), Via Fondo Ausa n. 58 – C.O.E. SM7609 (hereinafter referred to as “the Company“), which can be contacted at the following addresses: T. (+39) 0549 908006, e-mail


  1. What is a Personal Data and Processing


Personal Data” means any information that can identify, or make identifiable without any particular effort, a natural person.

On the other hand, “processing” activities include the operations mentioned in Article 2, letter b), Law no. 171 of 21 December 2018 and Article 4 no. 2 of EU Regulation 2016/679 (hereinafter “GDPR“), namely: collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.


  1. What Personal Data the Company processes


The Company processes the Personal Data of its customers and suppliers natural persons (common data) and those of the employees of its customers and suppliers legal entities, with whom it maintains communications (name, surname and e-mail).

The Company also processes the Data of the users of its website as well as any that may be created (hereinafter “the Website“).

The Company also processes the Data of the applicants for job positions in special curricula vitae got by e-mail.

Finally, the Company processes the personal data of persons who participate in promotional events that the Company carries out and on the occasion of which they are allowed to try its products.


  1. How Data are processed


The processing of Personal Data by the Company is based on principles of correctness, lawfulness, transparency, limitation of purposes, minimization, accuracy, limitation in storage, integrity and confidentiality.

Personal Data are processed both on paper and electronically and electronically.

In any case, the security, integrity and confidentiality of the data is guaranteed in compliance with the physical and logical organisational measures provided for by the provisions in force, so as to minimise the risks of destruction or loss, access NOT allowed, modification and unauthorised disclosure.

The Company does NOT carry out profiling activities, except for the use of cookies intended for this purpose, and in no case will the Data be disclosed without the prior consent of the person concerned.


  1. Why we process Personal Data


The Company collects Personal Data for the following purposes:

a) For the performance of the necessary pre-contractual activities (e.g. sending quotations, pre-contractual agreements) (legal basis implementation of pre-contractual measures);

b) To fulfil contractual and tax obligations towards the person concerned (legal basis contractual obligation);

c) For the protection of our assets and/or the defence of our rights on the basis of our legitimate interest (legal basis right of defence in court / legitimate interest);

d) To comply with legal obligations and requests of the authorities, as well as to meet the regulations for the prevention of fraud, money laundering, etc.. (legal basis legal obligation).

e) For marketing purposes, and in particular:

  • To send electronic communications (e-mail) relating to our services and/or products (direct marketing), where the person concerned has already purchased such services and/or products in the past through the use of an e-mail (so-called soft spamming) (legal basis legitimate interest). It will in any case be possible to oppose the receipt of the above communications by writing to the Company an e-mail, or through the OPTOUT procedure always available. Specific summary information, if necessary, will be reported or displayed on the web pages prepared for particular further services on request;
  • To make telephone calls and/or send sms and/or e-mails of a commercial nature relating to services and/or products of the Company, where the interested party has given his consent (legal basis consent of the interested party);
  • In order to carry out the necessary verification and verification activities towards those users who intend to participate in events organised in order to promote the Company’s products (legal basis legitimate interest);
  • To promote its products and services through the use of images and/or videos of promotional events organized by the Company (legal basis legitimate interest).

f) For the evaluation of the applicants’ profile and their recruitment, in the case of the spontaneous submission of curricula (legal basis for the implementation of pre-contractual measures);

g) In order to meet the requests made by site users (legal basis execution of pre-contractual measures);

h) To collect Data through the form on the Company’s Websites in order to transfer them to third parties providing insurance, guarantee and/or geolocation services (legal basis consent of the interested party).


  1. Obligation to provide Personal Data


The provision of data for the purposes referred to in points a), b), e), f), g), h) of the previous clause is NOT mandatory. However, in their absence, we will NOT be able to guarantee the implementation of the contracts and services requested.


On the other hand, processing for the purposes referred to in points c) and d) is compulsory.


  1. To whom we communicate Personal Data


Without the need for express consent, the Company may communicate the Data for the purposes indicated above to judicial authorities, to the Representative of the Company in the European Union, as well as to those parties to whom communication is required by law in order to fulfil the said purposes.

On the other hand, with the specific consent of the person concerned, the Company may communicate the common Data collected through a specific form on the Websites to third parties providing insurance, guarantee and/or geolocation services, who will process the Data as independent data controllers.


  1. Right to withdraw consent


Where consent has been given for a specific processing of Personal Data, this may be freely revoked at any time by the person concerned by sending an e-mail or a registered letter with acknowledgement of receipt to the numbers indicated in clause 18 below.

It is understood that the consent withdrawal will in no way affect any existing contractual relationship.


  1. Who accesses Personal Data


The Data may be made accessible for the purposes indicated above:

  • To employees and collaborators of the Company, in their capacity as authorised and/or internal data processors and/or system administrators;
  • To third party companies or other entities (by way of example, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) who carry out outsourcing activities on behalf of the Company, in their capacity as external data processors.


  1. Where we store and transfer Personal Data


The Data shall be processed and stored at the Company’s registered office at 47891 Dogana (RSM), Via Fondo Ausa n. 58, or at the offices of external parties involved in the processing pursuant to the preceding paragraphs.

Personal Data are stored on servers located within the Republic of San Marino or the European Union.

The Company assures from now on that the transfer of the Data abroad will take place in compliance with the applicable legal provisions, subject to the stipulation of specific contracts to protect the security of such data.


  1. As far as we store Personal Data


Personal Data will be stored in compliance with the principles of proportionality and necessity, and in any case until the purposes of the processing have been achieved. In any case, storage times vary according to the type of processing and the place of residence of the person concerned, as shown below.

a) Sending quotations: 6 (six) years;

b) Sale and purchase of products: for the duration of the contractual relationship;

c) Sale and purchase of products (once the relationship is terminated): 5 (five) years from the termination of the relationship for Data of persons resident in the Republic of San Marino and 10 years for Data of persons resident in Italy;

d) Protection of assets and defence in court: 5 (five) years from the termination of the relationship for Data of persons residing in the Republic of San Marino and 10 (ten) years for Data of persons residing in Italy;

e) Marketing activities: until the withdrawal of consent by the person concerned or the exercise of the OPT OUT procedure;

f) Verification and assessment activities for users’ participation in organised events: for the duration of the event;

g) Verification and assessment activities for the participation of users in organised events, once the event has ended: for the duration of the event: 5 years from the termination of the relationship for Data of subjects resident in the Republic of San Marino and 10 years for Data of subjects resident in Italy;

h) Sending curricula: 6 (six) months after receiving them;

i) Response to requests sent voluntarily by users: 6 (six) months;

j) Data collection through a special form on the website for the activation of insurance or geolocation services: 6 (six) months.

After the storage period, Personal Data will be deleted.


  1. Browsing data


The computer systems and software procedures used to operate the websites  acquire, during their normal operation, some Personal Data (such as IP addresses or domain names of the computers used by users, the pages visited and the date/time of the visit) whose transmission is implied in the use of Internet communication protocols.

This information is NOT collected to be associated with the parties concerned, but could, through processing and association with Data held by third parties, allow users to be identified for its own nature.

This data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning. The Data could be used for responsibility assessment in case of hypothetical computer crimes to the detriment of the site: except in this case the Data on web contacts do NOT persist for more than 30 days.


  1. Technical cookies that do NOT require consent


In order to browse this website more efficiently and immediately, to make some sections work, and to store some browsing preferences such as the choice of language or font size, some cookies may be installed on the browser: small text strings that allow you to store some useful information for a certain time.

Cookies do NOT record any personal information about a user and any identifiable Data will NOT be stored. If you wish to disable the use of cookies you must personalise your browser settings by setting all cookies to be deleted or by activating a warning message when cookies are stored.

The use of such cookies and the performance of processing related to them, does NOT require, under current regulations, any express consent.

It is possible that certain third party cookies may also be installed in your browser which are necessary to acquire or have our partners acquire anonymous and aggregated statistical information relating to your surfing on the pages of the Group’s sites.

These are, in particular, cookies relating to the following statistical analysis services:


  • Google Analytics

Google will NOT associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

For further information please refer to Google’s privacy policy page.
You can prevent Google from detecting a cookie generated by your use of this website (including your IP address) and processing this data by downloading and installing this browser plugin:

Also for the use of such cookies and for the processing of personal data related to it, your consent is NOT required, in accordance with current data protection regulations.


  1. Cookies for which consent is required


Furthermore, if the relative consent should be given through one of the simplified methods described in the brief information notice presented at the time of first access to this site, additional cookies, so-called profiling cookies, may be installed and/or left to be installed by the third companies indicated below, which are aimed to help the third companies listed below to collect information on interests and habits so as to suggest commercial communications, as far as possible, that are relevant to the user’s interests, or, in any case consistent with these interests.
For the processing of Personal Data that, with prior consent, third party companies may implement through cookies, click on the links below and opt to provide or NOT provide consent by following the relevant instructions, after reading the different information:


  • Facebook

Through this Site, Facebook, if you give your consent, may process Personal Data in order to allow a browsing experience enriched by social network functions and services 


Through this Site, Twitter, if you give your consent, may process Personal Data in order to allow a browsing experience enriched by social network functions and services

  • Youtube

Through this Site, Youtube, if you give your consent, may process Personal Data in order to allow a browsing experience enriched by social network functions and services

  • Google+

Through this Site, Google, if you give your consent, may process your Personal Data in order to allow you a browsing experience enriched by social networking features and services

  • Linkedin

Through this Site, Linkedin, if you give your consent, may process your Personal Data in order to allow you a browsing experience enriched by social network functions and services

  • Pinterest

Through this Site, Pinterest, if the relevant consent is given, may process Personal Data to allow a browsing experience enriched by social network functions and services;

  • Google Maps

Through this Site, Google Maps, if you give your consent, may process your Personal Data in order to allow a browsing experience enriched by social network features and services.



  1. Support in browser configuration


If you wish, you can also manage cookies directly via your browser settings. However, deleting cookies from your browser may remove the preferences you set for the site.
For more information and support you can also visit the specific help page of the web browser you are using:

  • Internet Explorer

  • Firefox  

  • Safari

  • Chrome 

  • Opera 

  1. What are the rights of each interested party


As an interested party, you are entitled to:

a) To know whether the Data Controller holds and/or processes its own Data, to obtain information on: origin, category, purposes and methods of processing, recipients to whom the Data may be communicated, the logic applied in the case of processing carried out with the aid of electronic instruments, the period of their storage; and to have full access to them, also by obtaining a copy (art. 15 Law 171/2018 and GDPR Right of access);

b) Obtain the rectification of inaccurate Personal Data concerning the person concerned and the integration of incomplete Personal Data (art. 16 Law 171/2018 and GDPR Right of rectification);

c) Obtain the cancellation of Personal Data held by the Owner if one of the reasons provided for by the new Law (art. 17 Law 171/2018 and GDPR Right to Cancellation) exists;

d) Ask the Data Controller to limit the processing only to certain Personal Data, if one of the reasons provided for by the new Law (art. 18 Law 171/2018 and GDPR Right to limit processing);

e) Know who the recipients have been notified of any corrections or cancellations or limitations of processing (art. 19 Law 171/2018 and GDPR Reg. Obligation to notify);

f) Request and receive all your Personal Data, in structured format, in common use and readable by automatic device or request transmission to another holder without hindrance (Art. 20 L. 171/2018 and GDPR Right to Portability);

g) Oppose in whole or in part the processing of Data for marketing purposes (sending advertising material, direct sales, market research and commercial communication) and for profiling purposes related to such marketing (art. 21 Law 171/2018 and GDPR Right of opposition).

You are finally entitled to make a complaint/appeal directly to the Guarantor Authority for the Protection of Personal Data, with registered office in San Marino (RSM), Via Scala Bonetti n. 2, tel. +378 0549.885476 or to the Guarantor Authority for Personal Data, with registered office in Rome, Piazza Venezia n. 11, tel. (+39) 06.696771 and Fax: (+39) 06.69677.3785.


  1. How you can exercise your rights


The exercise of the rights described in this paragraph is totally free of charge.

These rights may be exercised at any time by sending alternately:

  • A registered letter addressed to Armony S.r.l., 47891 Dogana (RSM), Via Fondo Ausa n. 58;
  • A Pec at: