Smart Touch respects your privacy and is committed to protecting your personal data.
These privacy regulations describe the use of personal data by Smart Touch when we consult our site, interact with Smart Touch and purchase and use our products and services.
They also serve to make the user aware of the rights related to privacy and the related protection offered by the legal system.
We ask the user to read the present privacy regulations as well as the other privacy rules that we should provide to him, so as to be informed about the use of his personal data on our part.
These privacy policies have been updated on September 4th, 2018. You can contact us to get previous versions.
For any questions or to exercise a right related to privacy, please follow the instructions indicated in these privacy rules. See the section Contacting Smart Touch for a privacy question below.
2. Our services, the site and the company
Smart Touch takes care of production of software not related to the edition, customization of computer programs, according to customer needs, changes, configurations of existing programs.
With our products and services we try to create value-added B2B services for SMEs and innovative applications for users. The use of the site, control panels and in general our services is not intended for minors under the age of 18 and we do not intentionally collect data concerning them.
In particular, Smart Touch SRL offers the service called “SmartTouch Menu”. This is a self-ordering service (ordering autonomously), informative and promotional that allows you to send orders with your mobile device in the participating businesses through the downloadable application that can be used free of charge on your smartphone or tablet device. The “SmartTouch Menu” service allows end users to order with their smartphone or tablet and stay up-to-date on the latest news and promotions. The user can add or remove exercises from their favorites from the list in the App and every time he reads the code of an exercise it will be added to his favorites.
SmartTouch Menu also allows you to participate in games and sweepstakes, to send comments via social networks, to receive advertising and promotional information from Smart Touch or third parties.
The service is allowed only to registered users.
The registered office of Smart Touch Srl is located in:
via Roma, 54
21047 Saronno VA Italy
3. Personal data we can collect
Personal data, or personal information, is information related to any subject from which one can derive its identity. The data from which the user’s identity has been removed (anonymous data) is therefore excluded.
We collect a series of information relating to both our customers, typically the managers of businesses in the catering and entertainment, both related to our extraordinary users who are typically end users of services, the App and visitors to the site Smart Touch. These personal data are attributable to the following categories.
Identification data: include title, name, surname, user name or other identifying data as well as the encrypted version of the user’s login credentials. If the user communicates with us via social media, this category of data also includes the username used on this social media.
Contact details: e-mail address and telephone numbers.
Transaction data: include information relating to the user’s orders and in his favor as well as further information regarding products and services used by us and at participating establishments.
Profiling data: include user’s username and password, social accounts, purchases and orders made by them, their preferences, reviews and survey contributions, along with any profiling data we have added (for example, analysis and profiling) .
Technical data: include the IP address (internet protocol), the user access data, the type and version of the navigation program, the time zone and the location, the navigation program plug-ins and their versions , the operating system, the platform and any other technology that operates on the devices used by the user to access our services.
Usage data: include information on the use of our Apps, as well as our products and services.
Monitoring data: include information about the user that we, or third parties, collect from similar cookies and tracking technologies, such as web beacons, pixels and mobile device identification data.
Market data and commercial data: include preferences relating to the receipt of direct marketing communications from us and third parties and all preferences related to communications.
In addition, we collect, use and share aggregate data such as statistical and demographic data for any purpose. Aggregated data may derive from the user’s personal data even if they are not considered personal data according to the law as they do not reveal the user’s identity, directly or indirectly.
However, if by combining or linking the aggregated Data with the personal data of the user, they can directly or indirectly identify it, the combined data will be treated in the same way as personal data in accordance with these privacy rules.
We do not collect sensitive information about you (they include data revealing racial or ethnic origin, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, union membership, information about health status as well as genetic and biometric data). Furthermore, we do not collect the judicial data concerning the user.
Please also note that if the user wishes not to share certain personal data with us or refuses any contact from us, we may not be able to provide the requested products and services.
4. How is personal data collected?
Below are the different methods of data collection from the user and the user we use.
Direct interaction. The user decides to communicate the identification data, contact details or the social account with which he / she accesses our services with the acceptance of profiling in this way or the completion of a form or communicating said data by mail, telephone, e-mail or via chat or social media.
This includes personal data provided by the user when these:
sign up for our newsletter;
submits requests or requests receipt of information;
create an account on our website and / or App / WebApp;
authorizes access to any of our services and Apps via your social network account or email;
order our products or services;
requires commercial material;
contact us on social media;
take part in a competition, promotion or survey;
Contact Customer Service; or
post a comment or review regarding our products or services.
Technologies or automated interactions. When the user interacts with us, we may collect technical data related to his devices as well as actions and navigation templates. We may also collect monitoring data if you visit our site or when you click on our advertising (including those published on third party sites).
Third parties or sources of public domain. We may receive personal data about you from different categories of third parties, including:
technical and / or monitoring data from analysis service providers, advertising networks and search service providers;
contact, financial and transaction data from payment service providers as well as fraud prevention services;
identification and contact data from partners with whom we share data; is
data from any third party that has been authorized by the law or by the user to share with us the personal data of said user, for example via social media or review sites.
5. How we use your personal data
We use personal data within the limits set by law. In general we use personal data in the circumstances indicated below.
If we were to execute a contract in the process of conclusion or already concluded with the user. For example, the contract that consists of the purchase of a product by the user.
Where it is necessary to pursue our legitimate interests (or those of third parties) provided that the interests and fundamental rights of the user do not prevail over them.
Should we comply with obligations imposed by laws or regulations. For example, for storage of sales documentation for tax reasons.
In general, the legal basis on which we base the processing of personal data of the user does not include the consent of the same except where expressly provided for by law, for example for sending certain direct marketing communications. In cases where the legal basis is based on consent, the user has the right to withdraw consent at any time.
For more information please compare The legal bases on which we base ourselves for the processing of personal data with the legal basis on which we base the processing of personal data.
6. The legal bases on which we rely for the processing of personal data
The categories of personal data used are only those necessary for the relevant legal basis, for example to be registered as a new customer and therefore the execution of the service contract requires identification and contact data.
The user is aware of the fact that we may process your personal data based on different legal bases depending on the specific purpose of using the data.
Our decision-making process is not automated.
We invite the user to ask any questions about it. See the section Contacting Smart Touch for a privacy question below.
7. Advertising, marketing and user preferences in communications
We could use the identification, contact, technical, monitoring, use and profiling data to get an idea of what the user might want or that could serve him, or what might interest him. It is in this way that we decide which products, services and offers are relevant to the user and, as a result, we provide the relevant communications. It is the so-called direct marketing.
Our services also provide a platform for our customers (typically merchants) so that they can also do direct marketing actions on the end users of the App (or App) who have expressed willingness to stay informed about news and promotions of their own interest. In this case only useful and indispensable data for the provision of these services will be provided.
We could use direct marketing strategies through e-mail, phone, SMS, mail or InApp push messages. For example, the user is our customer and the end user of the App may receive messages on their device or the user can still receive our newsletter via his e-mail box or be notified of an extraordinary promotion in progress.
Where communication is functional and essential to the provision of the service itself, consent will be considered implicitly included in the use. For example, when the user uses the App to order and receive information on the status of their order may receive some communications through InApp messages that report the status of preparation and / or delivery of your order (“your order is ready “) or that they report the information of the update of the menu with new products. In these cases, the reception of messages is functional and fundamental to the service itself.
We make every effort to ensure that our Apps, our site, and our services always communicate clearly our activities and the type of messages delivered to the user, both when the user himself decides to receive our communications or communications from our customers, both when creating the account or the online purchase procedure. The user can change his mind at any time, thank and decide to unsubscribe. The easiest way to unsubscribe is via the appropriate link at the bottom of our communications, while the preferences of your profile in the App or on the site you can decide what types of messages to receive and if you do not receive more.
Obviously there are many other ways through which the user can be reached by our advertising, some of which do not provide for the use of personal data: we could for example buy the old advertising space in the real world, on sites and on social media. If the user then views a Smart Touch advertisement on a site or on social media, these communications may not be directly addressed to him. Smart Touch could simply have bought that space. Here, however, is a non-exhaustive list of communications that are directed to the user:
e-mail, for example the news letter;
SMS, containing for example discount codes;
InApp push messages containing merchant promotions or initiatives
mail promotions in paper format, with discounts on shipping costs, or sent by our trusted partner dealers; and / or
phone calls, to notify you of messages relevant to your business.
We also work with partners that allow us to increase the range of our advertising using analytical data and retargeting systems for this purpose. We use Tracking Data to provide online advertising that is relevant, including through websites and social media.
The monitoring data, and in particular cookies, help us to offer advertising on sites and social media that, we believe, are more interesting for the user and for potential customers. Cookies used for this purpose are often installed on our site by specialized companies. Among other things, this is the reason why when you visit our site you may again see some information about products, services that affect us and that you liked previously. Retargeting is inserted here.
Cookies also warn us of the possible visualization by the user of a specific advertisement, as well as of the time elapsed since the last display. These are important data for us because they allow us to monitor the effectiveness of our advertising campaigns and monitor the number of times that the same person appears to the same person (we do not want to be repetitive). Cookies also help us to understand if the user has opened a commercial e-mail, to avoid sending contents that are trashed.
For more information on tracking data, especially cookies, compare the Cookies section below.
Virtually all cookies related to advertising come from online advertising networks of third parties. For more information on how to decide which advertisements to display online, compare how to unsubscribe. We do not control cookies installed by advertising networks.
As can be inferred from the Advertising, Marketing and User Preferences section in the above communications, cookies are tools that we (and any subject that operates online) use for advertising purposes. This is just one of the uses of cookies. They are a very ingenious tool.
Cookies allow us to improve the functioning of our site and facilitate the online purchase process. The user would waste time behind countless steps if there were no cookies, such as during login and navigation between different sections of the site; cookies also allow you to save and keep in the shopping cart products even when the user has left a page or consult other pages of the site.
Other cookies collect information about how you use our site, for example which pages you visit most often, or if you receive error messages from certain pages. These cookies do not collect information through which the user can be identified. All information collected by these cookies are aggregated and used to improve the functioning of our services.
There are also cookies that allow you to remember the user’s choices (such as user name, language or geographical location) to make available to features not only better, but also customized. These cookies can also be used to remember user changes and other customizable preferences. They can also be used to provide user-requested services such as viewing a video or posting a comment on a blog.
These cookies collect information about the user’s browsing habits to provide relevant advertising to the user’s interests (compare Advertising, marketing and user preferences in the above communications). They are usually installed by advertising networks with our consent. These cookies store the site visited previously by the user and this information is shared with other companies, for example advertising. Cookies defined as “targeting cookies” or “advertising cookies” are linked to the functionality of the site provided by other companies.
When the user consults our site, the device or the navigation program used may install third-party cookies, for example when viewing embedded content or clicking on a link that links to a social network. N.B .: we have no access or control over cookies used by these companies or third party websites. We suggest the user to consult the third site for more information on its cookies and their management.
For more information on the cookies used by us here, including their origin, their ID and the purposes for which they are used. We also provide links to third party sites here to facilitate user consultation.
9. Disclosure of personal data
The user’s personal data may be shared with the subjects indicated below for the purposes set out in these privacy regulations. We may also share your personal data if it is otherwise provided for by law.
We reserve the right to share personal data with the following categories of third parties:
suppliers of products and services (for example, technology service providers, payment processing and fraud prevention, manufacturers, transport services and postal services);
- company of the Zucchetti S.p.A. Group;
- external auditors and professional consultants such as banking, legal, accounting and insurance consultants; and
- administrative, regulatory and law enforcement agencies.
We share personal data with third parties listed below.
NIM Wave S.r.l. with legal office in Corso Indipendenza 20, 20129 Milano MI (Italy) and head quarter in in Viale De Gasperi 17/19 20020 Lainate MI (Italy) and NETIFY SRL , with legal office in C.so Mazzini, 39 26900 Lodi (LO), are our partner for administration of some of our server, customer assistance and logistic for delivery some equipment, therefore, to carry out some maintenance and operational operations, they may come into contact with some of our customers’ data.
We share data with third parties operating in the advertising, retargeting and analysis sectors. For more information on the aforementioned third parties, please refer to the Cookies section above.
We also reserve the right to share personal data with third parties to whom we may decide to sell or transfer part of our business or assets or merge with them. Or, we may be able to acquire other companies or merge with them. Should a change to our activity occur, the new owners may use the personal data of the user according to the same rules set out in these privacy rules.
We require all third parties to respect the security of the user’s personal data and to manage them in accordance with current legislation. We do not allow third party service providers to use your personal data for their specific purposes, but we only allow them to process your personal data for the specified purposes and in accordance with our instructions.
10. Payment information
Zuccehtti Smart Touch uses the PayPal and Braintree external companies to process payments made for the purchase of our products and services via the Website. All online payments will be executed in compliance with the payment standards of the Payment Card Industry (PCI ), which are decidedly stringent, and the user billing information (used exclusively by fraud prevention processing companies) is encrypted before being communicated to them. Subject to the exceptions below, the user’s credit card details are communicated directly by the payment program to the payment processing companies: Smart Touch never (and never!) Has access to the Permanent Account Number (PAN) user. This means that the payment form is located outside the site or is displayed in a frame on the payment page.
For PayPal, we only store the tokens required to identify the transaction with PayPal, issue a refund and identify transactions made through PayPal.
11. International transfers
Any transfer of the user’s personal data outside the EEA will always occur in accordance with applicable data protection legislation. Here are some measures that we could decide to take in carrying out an international transfer.
The transfer of personal data of the user takes place to a country whose levels of protection of personal data have been officially recognized as satisfactory by the European Commission.
We may use specific contracts approved by the European Commission that offer personal data the same protection guaranteed in Europe (called “EU Model Clauses”).
If we use US service providers, we may transfer data to them if they adhere to the EU-US privacy shield, which requires them to provide personal data protection equal to that offered in Europe and the United States. If the supplier does not adhere to the EU-US privacy shield, we may use the EU Model Clauses.
We share your personal data within our providers, which involves the transfer of certain data beyond the European Economic Area. For this operation we use the EU Model Clauses.
Some of our external service providers are located in countries other than the EEA, so the processing of your personal data requires a transfer of data beyond the boundaries of the same.
12. Data security
We have established appropriate security measures to prevent the accidental loss of your personal data, as well as their use or access by unauthorized parties, as well as their alteration or dissemination. Furthermore, access to the user’s personal data is limited to employees, agents, contractors and other third parties who, for reasons connected with the conduct of their business, must necessarily know. The user’s personal data will be processed exclusively upon our instructions and these subjects are bound by the obligation of confidentiality.
We have set up procedures for the management of any personal data breaches and will take care to communicate such violations to you and to any supervisory authority if required by law.
13. Third party links
14. Data retention
We will store your personal data only for the time necessary to fulfill the purposes for which the data were collected, including the purposes related to the satisfaction of any legal, accounting or reporting obligation.
To determine the correct retention period of personal data, we consider the quantity, nature and degree of sensitivity of personal data, the potential risk related to possible damages due to unauthorized use or for the diffusion of personal data of the user, the purposes for which the treatment and the possible existence of alternatives take place, together with the applicable legal obligations.
For tax purposes, the law requires the retention of our customers’ basic information (including contact details, identifiers, financial details and transactions) for six years from the time the customer’s status becomes invalid.
In certain circumstances, the user can ask us to delete data concerning him; for more information, see the section The rights guaranteed by law below.
In some circumstances we may decide to anonymise your personal data (so that they are no longer associated with your identity) for research or statistics purposes. In these cases, we reserve the right to use this information indefinitely and without further notification.
15. The rights guaranteed by the law
If the European Data Protection Regulation is applied to the user if he resides in a country of the European Union, he is entitled to the following rights guaranteed by the privacy protection legislation with reference to his personal data.
Right to information – we have the obligation to inform you about the use of your personal data on our part (obligation that we comply with these privacy regulations);
Right of access – right to submit a “request for data access by the interested party” to obtain a copy of the personal data of the interested party filed by Smart Touch;
Right of rectification – right to demand correction of personal data if they were incomplete or incorrect;
Right of cancellation – also known as the “right to be forgotten” when, under certain circumstances, the user can request to delete the personal data concerning him (provided there is no provision for their maintenance and which prevails over the request) ;
Right to limit processing – the right to request, in certain circumstances, the suspension of the processing of personal data;
Right to portability – right to request a copy of the user’s personal data in a commonly used format (for example, a .csv file);
Opposition right – right to object to the processing of personal data of the user (for example, if the user does not allow the processing of data for direct marketing purposes); is
Rights related to automatic decisions and profiling – the right to demand transparency for any profiling carried out by us, or for any decision made with an automated procedure.
These rights are subject to certain rules that determine their exercise. For more information, you can consult the Guide to the application of the European Regulation on the protection of personal data.
You can contact us if you wish to exercise any of the aforementioned rights (see the section Contacting Smart Touch for a privacy question).
There are no costs for access to the user’s personal data (or for the exercise of the aforementioned rights). Nevertheless, we reserve the right to apply substantial costs if the request is clearly groundless, repetitive or excessive. Alternatively, and under these circumstances, we may refuse to comply with the user’s request.
We may request user-specific information to help us confirm your identity and ensure correct access to your personal data (or to exercise any of your rights). This security measure is necessary to ensure that personal data are not disclosed to any third party that does not have the right to receive them. We may also contact you to request additional information related to your request in order to speed up the process.
We do our best to answer all legitimate requests within a month. Sometimes it may take more than a month if the request is particularly complex or the user has submitted numerous requests. In these cases, it will be our concern to communicate the timing to the user and keep it updated.
If the user has further questions related to these privacy regulations, or intends to submit a request to exercise one of the rights guaranteed by law, he can contact us through the contact information in the section Contacting Smart Touch for a question about privacy below.
The user has the right to file a complaint at any time with the data protection authority. We hope, however, that the user wants to address his questions and complaints to us before contacting the guarantor.
16. How to contact Smart Touch for a privacy question
For any questions related to these privacy regulations, or if you intend to exercise any of your rights, you can send an email to firstname.lastname@example.org or a written request to the address: Smart Touch, via Roma 54, 21047 Saronno (VA)
For assistance with our products and services, or with reference to the site in general, you can contact us here: https://www.smarttouch.it/#contact
17. We will be very grateful if …
It is very important that the personal data concerning the user are always correct and updated. We therefore want to be informed if your personal information changes during the period in which you are in contact with us. You can notify us of changes simply by updating your account. Thank you!
18. Changes to these privacy policies