Privacy Policy

Because this information

This statement is made in compliance with the provisions of Community legislation (EU regulation 679/2016 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, and the free movement of This data, hereinafter, for brevity, "GDPR") and from the applicable national legislation.


Holder of the treatment

The data controller is Hurlio S.R.L., in person of its legal representative P.T., with registered office in Molfetta at Via Adriano Olivetti, 26/A, (Email:, PEC:, Tel.: + 39 3939001564).


Data collected

Hurlio S.R.L. collects and/or receives information concerning the person concerned, such as:

Personal data: Name, surname, physical address, nationality, province and municipality of residence, fixed and/or mobile telephone, fiscal code, address (s)

Bank details: IBAN and bank/Postal data

Data traffic: Log, IP address of origin


Purpose of the treatment

The data are used by the owner to follow the requests contained in the modules for the following purposes:

Registry registration;

Contract for the supply of the chosen service and/or of the product purchased;

Management and execution of contact requests forwarded by the person concerned;

Provision of pre-and post-sales assistance;

Fulfilment of the statutory and regulatory obligations to which the holder is held in accordance with the activity exercised;

Direct marketing.

In no event shall the holder cede the personal data of the person concerned to third parties or use them for undeclared purposes. In particular, the data of the person concerned will be processed for: registration and contact requests and/or information material

The processing of the personal data of the person concerned is to give course to the preliminary activities and consequent to the request for registration, to the management of the requests for information and contact and/or sending of informative material, as well as for The fulfilment of any other obligations arising.

Legal basis: the fulfilment of the benefits inherent in the request for registration, information and contact and/or sending of informative material and compliance with statutory obligations.

Contract management and provision of pre-and post-sales assistance

The processing of the personal data of the person concerned is to give course to the preliminary activities and consequent to the purchase of a service and/or a product, the management of the relevant order, the delivery of the service itself and/or the production and/or the shipment of Product purchased, its invoicing and payment management, the handling of complaints and/or reports to the assistance service and the provision of assistance, the prevention of fraud and the fulfilment of any other obligation arising from the contract.

Legal basis: the fulfilment of the benefits inherent in the pre-contractual and contractual relationship and compliance with statutory obligations.

The personal data of the person concerned, excluding the particular ones (art 9 GDPR) or judicial (art 10 GDPR), will be treated to allow checks with the purpose of monitoring and prevention of fraudulent payments by software systems that carry out A verification in an automated manner and prior to the negotiation of services/products. Overstepping these checks will result in the inability to make the transaction.

In any case, the person concerned may express his or her opinion, obtain an explanation or dispute the decision by motivating his own reasons for the contact

Personal data collected for fraud purposes only, as opposed to the data necessary for the correct execution of the requested performance, will be immediately cancelled at the end of the control phases.

Direct Marketing

The personal data of the person concerned may also be treated for commercial promotion purposes, by profiling for promotional purposes, for surveys and market research with regard to services/products that the proprietor offers only if the person concerned has Authorized treatment and does not oppose this. This treatment can be done in an automated manner, with the following modalities: E-mail, SMS, telephone contact and can be carried out if the person concerned has not revoked his consent for the use of the data.

Legal basis: consent provided by the person concerned preliminarily to the treatment, which is revocable by the person concerned freely and at any time.

Retention Period

Unless expressly requested to remove them, the personal data of the person concerned shall be retained until necessary in respect of the legitimate purposes for which they were collected.

In particular, they will be kept for the duration of its registration and, in any case, not more than a maximum period of 24 months of inactivity, that is, if, within this deadline, the services and/or purchased products are not associated with The same data.

In the case of data provided for commercial promotion purposes for services other than those already acquired by the person concerned, for which he initially consented, they will be kept for 24 months, unless the consent has been revoked.

It is also necessary to add that, in the event that the person concerned provides the owner with unsolicited or unnecessary personal data for the purpose of performing the requested performance or the provision of a closely connected service, Hurlio s.r.l. does not It may be considered as the holder of these data and will cancel them as soon as possible.

Irrespective of the determination of the person concerned to their removal, the personal data shall in any case be kept in accordance with the terms set forth in the existing regulations and/or national regulations, in order to ensure the specific fulfilments Some services (but not limited to, certified e-mail, digital signature, substitute storage).

The personal data will in any case be kept for the fulfilment of the obligations (e.g. tax and accounting) that persist even after the termination of the contract (art. 2220 C.C.); For these purposes, the holder shall retain only the data necessary for his pursuit.

are without prejudice to the cases in which the rights arising from the contract and/or the registration, in which case the personal data of the person concerned, only those necessary for those purposes, will be treated for the time Indispensable to their pursuit.

How and where we treat the data of the person concerned

The processing of your personal data will be done through the use of appropriate security measures in order to preserve the confidentiality, integrity and availability of personal data of the person concerned, and shall impose on third parties suppliers and those responsible for similar measures of Security.

The personal data of the person concerned are stored in paper, computer and telematics archives located in countries where the GDPR (EU countries) is applied.

Nature of the bestowal and refusal

In the event that the person concerned does not provide his or her data identified as necessary for the performance of the requested provision within the abovementioned forms, the holder shall not be able to comply with the services related to the performance management Requests and/or the contract and the services/products connected to it, nor to the fulfilments which they depend upon.

In the event that the person concerned does not provide consent to the processing of personal data for commercial promotion activities on different services/products than those purchased, this treatment does not

It will happen for the same purposes, without affecting the provision of the requested services, nor for those for which he has already given his consent, if required. In the event that the person concerned has consented and should subsequently withdraw it or oppose the treatment for commercial promotion activities, his data shall not be treated any more for such activities, without any consequence or effect injurious to the person concerned and for the requested services.

Recipients of the data

They are recipients of the data collected and will therefore treat on behalf of the holders such data, the following subjects, pursuant to art. 28 of the regulation, as external managers of the treatment:

Suppliers who will take care of the administrative, accounting and related performance of the contract, as well as the provision of services (assistance, maintenance, delivery/shipment of products, provision of additional services, network suppliers and electronic communication services) related to the required performance;

Software house that delivers functional services for the above-mentioned purposes;

E-mail provider that delivers functional services for the above-mentioned purposes;

Credit and digital payment institutions, banking/postal institutions which will deal with the management of receipts, payments, financing and reimbursements related to the contractual performance;

Professionals/external consultants and consultancy companies for the fulfilment of statutory obligations, exercise of rights, protection of contractual rights, recovery of credit;

Communication and marketing companies;

Financial administration, public bodies, judicial authorities, supervisory and control authorities, for the fulfilment of statutory obligations and the defence of Rights; Lists and registers held by public authorities or similar bodies on the basis of specific regulations, in relation to contractual performance;

Transport companies;

Entities formally delegated or having recognized legal title as legal representatives, curators, guardians, etc.

The personal data collected are also processed by the authorized internal entities acting on the basis of specific instructions given in order to the purposes and modalities of the treatment itself.

Rights of the persons concerned – complaint to the control authority

In relation to the data subject to the treatment referred to in this information to the person concerned, the right to:

Ask the holder for access to his personal data and information relating to them (article 15 of the GDPR); The correction of inaccurate data or the integration of incomplete information (article 16 of the GDPR); The cancellation of the personal data concerning it (on the occurrence of one of the conditions indicated in article 17, par. 1 of the GDPR and in accordance with the exceptions provided for in paragraph 3 of the same item); The limitation of the processing of personal data (to the use of one of the hypotheses indicated in art. 18, par. 1 of the GDPR);

Request and obtain from the holder – in cases where the legal basis of the treatment is the contract or consent, and the same is done by automated means – his personal data in a structured format and readable by automatic device, even at Order to communicate this information to another data controller (i.e. the right to personal data portability – art. 20 of the GDPR);

To oppose at any time the processing of your personal data to the recourse of special situations that concern you (art. 21 of the GDPR);

Revoke the consent at any time, limited to assumptions in which the treatment is based on your consent for one or more specific purposes. The consent-based treatment and effected prior to the revocation of the same retains, however, its legality (article 7, par. 3, of the GDPR).

The appropriate application is submitted by contacting the owner by e-mail:, PEC:, tel.: + 39 3939001564 or registered letter A/R at Hurlio s.r.l., Via Adriano Olivetti, 26/A – Molfetta (BA) – 70056.

If the person concerned considers that the processing of his data is in breach of the provisions of the Regulation, he may submit a complaint to a supervisory authority (authority guaranteeing the protection of personal data –, as provided by Art. 77 of the GDPR, or to the appropriate judicial offices (art. 79 of the GDPR).