1.         Introduction

2.         Data controller and supervisor

3.         Nature of the data processed

4.         Purpose, duration and method of treatment

5.         Cookies

6.         Processing aims and methods

7.         Obligation or Power To Provide Data

8.         Scope of Knowledge Of Your Data

9.         Security and quality of personal data

10.         Communication of personal data to third countries and transfer abroad

11.       User’s rights

1. Introduction

Sovrana snc as data controller with this document (« Privacy Policy ») concerning its website, available also in an optimized version for mobile phones at the same address, want to inform users about how Sovrana handles their personal data, when they visit the website.

The Privacy Policy has been drafted in compliance with D. Lgs. 196/2003 subsequent amendments and integrations (“Privacy Code”) together with Recommendation no. 2/2001, adopted on 17 May 2001 by the Working Group on Data Protection – Art. 29, in relation to the minimum requirements for online data gathering within the European Union. In addition, it represents the policy for all those involved, in accordance with Article 13 of the Privacy Code. The Privacy Policy specifies who the data controller is, who controls and manages the personal data gathered and handled through the website, which personal information is gathered, for which purposes it is gathered and the methods used to handle the personal data. It also defines the extent of their communication to third parties, the security measures adopted to protect and safeguard said data, and the means by which users can verify the handling of their data, and exercise the rights acknowledged by the Privacy Policy.

We inform you that, for the establishment and execution of contractual relations with you, our company is in possession of you data, acquired verbally, directly or through third parties, qualified as personal by the Europe Regulation 2016/679 of the (GDPR).

According to this regulation this treatment will be based on principles of correctness, lawfulness, transparency and protection of your privacy and your rights. According to article 13 of the GPDR we inform you that:

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2. Data controller and supervisor

The data controller is Sovrana Snc owned by Spini and Guadagnini, based in Via Beltrami, 6 - 24030 Mapello; e-mail: The data supervisior for Sovrana is the legal representative based at the company headquarters. 

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3. Nature of the data processed

We process your personal, business and financial data necessary for the performance of contractual relationships, current or future, with your company as well as to achieve an effective management of business relationship.
The data will be processed without your consent (article 24 letters a and e GDPR) only and exclusively for the following Service Purposes: fulfill the pre contractual obligations arising from existing relationships with you; fulfill obligations provided for by law, by a regulation, by Community Legislation or by an order of authority; exercise the owner’s rights, for example the right of defense in court.
We also process other data as those of particular or judicial nature (article 9 and 10 of the GDPR).

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4. Purpose, duration and method of treatment 

Personal data collected through the website are stored in an informatics system managed by Sovrana or by third parties that supply technical services. The data will be treated by authorized personnel only, including those who are in charge of extra-ordinary operation for website maintenance.

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5. Cookies

5.1 What is a “cookie”?

A cookie is a fragment of text that is transferred to the hard drive of the user’s device (such as computer, tablet, smartphone) from the server of the web page when he visits Sovrana’s on-line service through his browser. It can be subject to the user’s consent. A “cookie” enables to identify the device that contains it as long as the “cookie” is registered or valid.

When visiting Sovrana’s on-line service, the activity on the website will be registered by the “cookies” stored in the device. During the first visit, the user will be informed about the use of “cookies” through a banner with a security informative. If the user proceeds with the activity on the website after reading the banner, he agrees to the use of cookies.

Further information regarding cookies are described below.

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5.2 Type of cookies

Sovrana uses cookies for the following aims:

• carry out statistics, monitor the traffic and weigh the use of each section of the website (e.g. titles and contents visited, flow of clicks,..) in order to improve the efficiency of its services;

• personalize the design of the website and its configuration (language, screen resolution, operating system, ..) during the user’s visit according to the hardware, software, video software of his device;

• store the information included in the forms filled in on the website and those regarding the products and services selected through the website ( e.g. services subscribed by the user, products in the cart,..);

• allow entering protected and personalized areas, such as the personal account, on the basis of username and password, to which the user previously granted Sovrana the access;

• implement security measures (for example in order for the user to be recognized through log-in during new visits to the website within a certain period of time).

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5.3 Cookies related to the integration of applications from third parties

Sovrana may decide to add to the website software applications from third parties, that will allow the user to share the contents of the website with other users or to inform them about his visit and opinion about it. In particular, this regards the “Like” and “Share” buttons on Social Networks (e.g. Facebook, Twitter..) Social Networks that provide these buttons may use them to identify the user, even when he has not clicked on them during his visit to the website. In fact, this sort of buttons may allow Social Networks to trace their activity on the website, only because the user was logged into his Social Network account from his device (open session) while visiting the website. Sovrana doesn’t have any control over the processes operated by Social Networks to collect information about the user’s visit to the website and over any related personal data. Please take a look at the data protection policy of these Social Networks in order to understand why they collect such data through that buttons, especially in regards to advertising. 

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5.4 What to do with cookies

There are various ways to deal with cookies. The user’s configuration may influence his experience and the condition of access to some services that use cookies. As described below, it is always possible to express and change one’s choices regarding the use of cookies.

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5.4.1 Browser setting

It is possible to set a browser to agree, completely decline or decline only a certain number of cookies. Moreover, it is possible to set the browser so that the user will have the chance to accept or refuse a cookie before installing it. For further information see section c) How to set a browser.

(a) Agreeing to cookies

The user can decide whether to agree or decline to install cookies on his device. The user is free to take his choice and change it whenever he wants to through the browser settings of the device. If the browser is set to agree to store cookies in the device, the cookies used by the webpages visited by the user will be temporarily stored in a special area of the user’s device. Only those who have installed the cookies will be able to read them.

(b) Turn off the cookies 

If the user decides to decline to install cookies on his device, or if he removes those that have already been memorized, he will not be able to access many features needed to use some sections of the website. For example, he will not be able to use those services that require him to log-into them. Moreover, regarding the technical compatibility it may be impossible to determine what type of browser the user is using, the default language, or the country he is connected from. If the browser is set to decline to install cookies on the device, Sovrana refuse to take any responsibility regarding the inefficiency of certain services derived from the impossibility to keep the information needed for a proper function of the website.

(c) How to set a browser

Every browser offers different ways of handling cookies and their setting. You can learn more about the browser setting and cookies by clicking on the “Help” menu from the toolbar, where you will be also able to change the cookies setting.

For Internet Explorer™:,

For Safari™:,

For Chrome™:,

For Firefox™:,

For Opera™:

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5.4.2 “Flash”© cookies using “Adobe Flash Player”™

“Adobe Flash Player”™ is an application that consents to watch quickly dynamic contents using the informatics language “Flash”. This and other similar application memorize configurations, preferences and user data through a technology similar to that of cookies. However “Adobe Flash Player”™ processes these information through an interface different from the user’s browser. If the device used by the user uses a Flesh technology, please access its cookies informative through the Adobe website

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5.5 Terminal shared with other people

If the device used is shared with other people, or if the same devise has more than one browser, it is not possible to tell whether the services and the advertisement that appear on the device depend on the user or others. In this case, the customer only is responsible for sharing the device with others and for the browser settings regarding cookies.

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6. Processing aims and methods

Sovrana collects and processes personal data (voluntarily provided by users when interacting with the website or legally acquired from third parties) to perform the following activities: supervise registrations and the purchase of products on the website (including all the activities related to the sale and after-sale services, such as fraud prevention, returns, guarantee, customer assistance, interaction with client service), control of the participation to promotions and other initiatives promoted by the website (for example contests and similar initiatives), use of the Customer’s Opinion service and control of requests of information, questions, communications and feedbacks. Moreover, Sovrana treats users’ personal data in order to fulfill the obligations outlined by laws, regulations and EU Legislation and to establish or defend a legal claim. In this regard, the data provision is mandatory and the denial to provide personal data will prevent users to register to the website, the newsletter and to proceed with a purchase.

Sovrana may use personal data for statistics researches, market analysis, creation of personal profiles (profilation) and marketing. Having before granted express consent, the personal data of users may also be processed for the purpose of sending communications with informative or promotional, by using automated and non-automated systems, via phone, mail and email.

For on-line purchases you may consult General Selling Conditions, available on

Sovrana mainly process personal data through electronic and computerized systems, according to the abovementioned procedures and aims.

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7.  Obligation or Power To Provide Data 

Your data is processed for the duration of the contractual relationship and also subsequently, for contractual requirements, and related legal and tax obligations,and for an effective management of financial and commercial relationships, operations described in article 4 number 2) of the GDPR.
The owner will process personal data for the time needed to fulfill the aforementioned purposes and for no more than ten years from the termination of the relationship for service purposes. 
The treatment will be carried out with manual and / or computerised, telematics tools with organizational and processing logics strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security, integrity and confidentiality of the data in compliance with organizational and physical measures and logics provided for by the provisions in force.  

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8. Scope of Knowledge Of Your Data

The following categories of subjects may become aware of your data, as managers or processors of the data, appointed by the undersigned data controllercompany: managers(Spini Fabio and Guadagnini Giovanni), accounting and billing clerks, external manager (Delcarro Roberto) and web consultants (Soriani and Brivio Monza)

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9. Security and quality of personal data

The User’s personal data are processed by Sovrana in compliance with current safety regulations in order to avoid data loss, the unlawful use or abuse of data and unauthorized access to data, with special regard to Attachment B of the Privacy Code (regarding technical regulations for security measures). In addition, information systems and computer programs are designed to minimize the use of personal and identification data, which are used only when necessary for specific processing purposes pursued. For example, personal data are recorded and stored on controlled secure servers, only open to duly authorized staff. Furthermore, specific encryption technologies are used for the transmission of some data via the Internet. Given the state of technology, especially the one used by telecommunication networks, Sovrana is not able to guarantee the confidentiality, integrity and authentication of e-mails and messages.

The user directly provides the necessary changes by logging into his/her personal profile on the Site.

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10. Communication of personal data to third countries and transfer abroad

We will never disseminate your data to indeterminate subjects through their availability or consultation. The data may be communicated by us, as far as their respective and specific competence is concerned to public and / or private bodies, towards whom we have an obligation (recognised by law, secondary or community regulations) or we have the need to communicate oralso to our consultants, within the limits necessary to carry out their duties at our organization, prior to our letter of assignment that imposes the duty of confidentiality and security.

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11. User’s rights

At any time, you can exercise the rights provided for in articles 15 / 22 of the GDPR; precisely the rights:

  • i) obtain from the controller confirmation as to whether or not personal data concerning you are being processed, and their communication in an intelligible form;
  • ii) obtain information about: a) the origin of personal data; b) purposes and methods of treatment; c) process followed in case of data processed with the support of electronic devices; d) details about the owners, the data responsible and the designated controller according to article 3, paragraph 1 of the GDPR; e) individuals or group of individuals who could be communicated or come across the data as designated controller in the state area, managers or agents;
  • iii) obtain: a) the update, rectification or integration of data; b) the erasure of restriction of data unlawfully processed, including those the controller no longer needs for the purposes of the processing; c) the confirmation that the operations referred to in a) and b) were communicated to those who the data had been communicated, including those concerning their content, unless the provision of such information proves impossible or would involve an effort disproportionate to the right it should preserve;
  • iv) object, partially or totally: a) on grounds relating to his or her particular situation, to processing of personal data concerning you, even though they are necessary for the data collection; b) to data processing aimed at direct marketing purposes, including advertising, market research or commercial communication, using automated calling systems, emails and/or through traditional marketing systems by telephone and/or paper mail.

Where possible you will also have the rights referred to in articles 16-21 of the GDPR (Right of Rectification, Right to be Forgotten, Right of Restriction of Processing, Right to Data Portability, Right of Object), as well as the right of complaining to the authorizing authority. At any time, you can obtain confirmation of the existence or not of personal data concerning you and the communication of such data and the purposes on which the treatment is based. Furthermore, you can obtain cancellation, transformation into anonymous form or blocking of unlawfully treated data, as well as updating, correcting or, if there is an interest on the matter, the integration of data. We kindly ask you to promptly report to the office of reference any variations of your personal data, in order to comply with article 11, letter (c) as this regulation requires that the collected data be accurate and therefore updated.

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The Privacy Policy is subject to amendments and updates, and the version currently in force is the one published on the Website. Amendments made to the Privacy Policy are published on the Website. Sovrana recommends the user to check the Privacy Policy periodically in order to remain up-to-date regarding any change introduced.

This Privacy Policy is applied since June 20, 2015

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