Privacy policy

Privacy Notice pursuant to Article 13 of Regulation (UE) 2016/679 (“GDPR”).
For UNOX S.p.A. (“UNOX”), your privacy and the security of your personal data are very important. This Privacy Notice explains how UNOX collects, stores, and uses your personal data when using the application called “Combiguru Challenge” (the “App”), and in the context of your possible participation in the “Combiguru Challenge” initiative in all its phases (the “Competition”), pursuant to Regulation (EU) 2016/679 (the “GDPR”) and in compliance with any other applicable European Union or Member State legislation on privacy (together, the “Privacy Legislation”).

Data Controller

The Data Controller is UNOX, with registered office at Via Majorana 22, 35010 Cadoneghe (PD), Italy. For any information or request regarding the processing of your personal data, you may contact us at privacy@unox.com or by phone at +39 049 8657 530.


What data do we process and why?

UNOX requires certain personal data (name and surname, email address, ID) to allow you to use the App and, where applicable, to participate in the Competition, to create or modify your user profile, to process and respond to your requests, and to enable you to contact our customer support service. In these cases, the processing of your personal data is necessary for the performance of a contract to which you are party or for the implementation of pre-contractual measures taken at your request. Only with your specific consent, UNOX may process your personal data for the purpose of sending you marketing communications. In addition, UNOX may process your personal data to comply with legal obligations and any requests received from public authorities, or for its legitimate interests, such as fraud prevention activities. Where processing requires your consent for one or more purposes, please note that consent may only be given if you are at least 14 years old. If you are under 14, consent must be provided by a parent or by the holder of parental responsibility (in such case, UNOX will take all reasonable steps to verify that consent has been given or authorised by the parent or legal guardian). If we become aware that personal data has been collected from a person under the age of 14 without parental consent, we will delete such data and close the relevant account as soon as possible. If, within the “Introduce a Customer” section of the App, you intend to provide us with identification and contact details of third parties, you may only do so if such third parties have been previously informed by you and have explicitly given their consent to the transfer of their data to us via the App. Your data may be processed in electronic and/or paper format.


Is it mandatory to provide personal data?

The provision of your personal data is optional. However, if you do not provide your data, we may not be able to provide you with the requested services, such as enabling you to use the App and participate in the Competition. The provision of data for marketing communications is optional and requires your prior consent. In any case, even without such consent, you may still use the service, but UNOX will not be able to send you marketing or promotional communications.


How long do we retain your data?

We retain your personal data as long as necessary to comply with legal obligations and obligations related to the use of the App and participation in the Competition, and in any case for no longer than 10 years from the termination of the contract (i.e. from your last use of the App or the end of the Competition, if you participated). To ensure your intention to remain an active user, we may request confirmation of your continued interest. If no response is received, this will be considered as lack of interest. At the end of this period, your data will be deleted or anonymised.


Who receives and processes your data?

Your personal data is processed by authorised UNOX personnel who have been specifically trained.

In addition, your data may be disclosed to the following categories of recipients:

  • Third parties performing activities related or instrumental to UNOX’s business, acting as external data processors or independent data controllers (e.g. IT system maintenance and development providers, IT and telecommunication service providers, archiving providers, and entities involved in the organisation and execution of the Competition);
  • Public authorities, law enforcement bodies or judicial authorities, where disclosure is required by law or necessary for UNOX to establish, exercise or defend a legal claim.

A full and updated list of such recipients is available at UNOX’s registered office upon request. Your data will be disclosed where required by law or where photographic, audiovisual, or textual materials related to your participation in the Competition are produced and distributed. In such case, upon your request, we will delete any data or information relating to you contained in such materials. Your data may be transferred outside the European Economic Area (EEA). In such cases, UNOX will ensure that the destination country is deemed adequate, or that the recipient is certified under appropriate privacy frameworks, or that appropriate contractual safeguards or binding corporate rules are in place. A copy of the appropriate safeguards adopted is available at UNOX’s registered office and may be requested at any time.


Your rights

You may exercise the following rights at any time:

  • Right of access to personal data;
  • Right to rectification or erasure;
  • Right to restriction of processing;
  • Right to object, on grounds relating to your particular situation, to processing based on UNOX’s legitimate interests, unless overriding legitimate grounds apply or processing is necessary for legal claims;
  • Right to object at any time to processing for direct marketing purposes;
  • Right to object at any time to processing of data for the offer of products or services similar to those already purchased;
  • Right to data portability (to receive your data in a structured, commonly used format and transmit it to another controller);
  • Right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise your rights, you may contact UNOX at: privacy@unox.it

You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).