Privacy Policy

We at ELITE want to offer our customers the best possible experience by constantly seeking the most advanced technical solutions to offer a competent and innovative service. Among our goals is also that of being as transparent as possible with our users and customers, including with reference to the data we collect and process to provide a constantly improving service that is increasingly tailored to their needs.

In this regard, consistent with the entry into force and direct applicability of the new European Regulation (EU Regulation 679/2016) on the protection of personal data (General Data Protection Regulation - GDPR), we have made all necessary changes and additions to our data processing system to better protect the personal data we process. These changes and improvements reflect, in particular, the requirements for greater transparency, simplicity, accessibility, and correct design introduced by the GDPR.

We therefore consider it important to inform users of all the information related to the management of personal data collected and used, included in our new Personal Data Processing Notices, which will provide further indications regarding:

• privacy rights and how to exercise them,
• methods of collection, use, sharing, and protection of personal data,
• the legal bases on which the processing of personal data takes place.

This page therefore describes the processing methods of the personal data of users who: utilize our apps (My Real Video, My E-Training, Rizer, Upgrado, Square), utilize our Shopify e-commerce, interact with our digital services, including newsletters and promotional communications,    consult our websites accessible via electronic means at the following addresses:

• www.elite-it.com
• myetraining-download.realaxiom.com
• forum.elite-it.com 
• support.elite-it.com
• www.fuoripista.it
• novecolli.elite-it.com
• redeem.elite-it.com
• elitecustombottles.com

This information does not concern other sites, pages, or online services reachable via hypertext links that may be published on the sites but refer to resources external to the ELITE domains.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will notify you of any changes by updating the "Last updated" date of this Policy. Any changes or modifications will be effective immediately upon publication of the latest updated version on the Site. The user is therefore invited to periodically review this Privacy Policy to check for any updates.

Before starting, what is a personal data?

The law defines “personal data” as any information relating to an identified or identifiable natural person, even indirectly, by reference to any other information, including a personal identification number.

Who is the data controller of the data collected in this way?

The "controller" of personal data processing is the company Elite S.r.l. SB (Padova Companies Register/Tax Code/Intrastat VAT IT 04342350289), with registered office in Fontaniva (PD), via Fornaci, 4/1, in the person of its legal representative; email: privacy@elite-it.com.

Why do we collect and process your personal data?

Your personal data is processed to execute the contract you have signed with Elite or following a direct request from you to obtain information about the services, or based on legal provisions, including those concerning data protection.

How long do we retain your personal data?

Your personal data is processed only for the time necessary to satisfy the purposes listed below and in accordance with current laws.

With whom do we share your personal data?

Your personal data may be shared with certain service providers or agents and with IT service providers. Any third-party providers used by Elite S.r.l. SB will be obliged to treat your personal data in strict compliance with current regulations.

How do we protect your rights?

As detailed in the notices, you have the right to access your personal data undergoing processing and to receive a copy thereof, subject to certain exceptions provided for by law. Furthermore, you have the right to object to the collection and subsequent processing of your personal data. You also have the right to request the limitation of any processing, the correction, if necessary, of your personal data, or, in certain circumstances, their cancellation. 

In particular, the data subject has the right at any time to obtain confirmation as to whether or not personal data concerning him/her exist, even if not yet recorded, and their communication in intelligible form. The data subject also has the right to obtain indication of: a) the origin of the personal data; b) the purposes and methods of the processing; c) the logic applied in the event of processing carried out with the aid of electronic instruments; d) the identification details of the Controller, the processors and the designated representative pursuant to Article 5, paragraph two; e) of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, as processors or persons in charge of processing. The data subject has the right to: a) obtain the updating, rectification or, where interested therein, integration of the data; b) obtain the erasure, transformation into anonymous form or blocking of data processed in violation of the law, including those for which retention is not necessary in relation to the purposes for which the data were collected or subsequently processed; c) obtain certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right; d) in the presence of conditions specifically provided for by law, to receive in a structured, commonly used and machine-readable format the personal data concerning him/her provided to a Data Controller and has the right to transmit such data to another Data Controller without hindrance from the Data Controller to whom they were provided, including by direct transmission (so-called right to data portability); e) withdraw the consents provided, without this affecting the processing previously authorized; f) lodge a complaint with the Data Protection Authority The data subject has the right to object, in whole or in part: a) on legitimate grounds to the processing of personal data concerning him/her, even if relevant to the purpose of the collection; b) to the processing of personal data concerning him/her for the purpose of sending advertising materials or direct selling or for the performance of market research or commercial communication. These rights may be exercised by writing to the Data Controller at the addresses indicated. Finally, you may object at any time to the processing of your personal data for direct marketing purposes.

Data Security

While reminding that no computer system is absolutely immune and secure, Elite constantly strives to maintain very high technical security standards, including through the adoption of firewalls, adequate software, antivirus, filtered navigation, encryption, and any other system available according to current technology.

Who can you contact?

If you wish to exercise any of your rights or if you have questions regarding this personal data processing policy, please write to privacy@elite-it.com.

Subjects involved in the personal data processing

“Data subjects” of the processing in question are, pursuant to law, all users of the websites indicated in the preamble who utilize the contact forms provided on the various sites, the support section and who make purchases on the online shop.

Personal data subject to processing

The processing will concern the following categories of personal data of the data subjects that may be freely provided and collected directly from them, through the completion of the fields present in the registration screens of the aforementioned application:

Identification and contact data: currently including name, surname, email address, country, and city, which are essential for handling requests for information or after‑sales assistance submitted through the contact form or via the forum section. For online‑shop users, the identification and contact data collected will also include the shipping address (street, city, province, postal code, etc.) and the billing address.

• Account data, including your username, password, security questions, preferences, and settings.

• Financial and billing data (for online‑shop users): financial information such as details relating to your payment method (e.g., valid credit card number, card brand, expiration date, transaction details, payment method, payment confirmation, and other payment‑related details) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site. All financial information is stored by our payment processor, Shopify, and we invite you to review their privacy policy and contact them directly for any questions you may have.

• Transaction information (for online‑shop users), including the items you view, place in your cart, add to your wishlist, or purchase, return, exchange, or cancel, as well as your past transactions.

• Communications with us, including the information you include in communications with us, for example when you submit a customer service request.

• Device information, including information about your device, browser, or network connection, your IP address, and other unique identifiers.

• Usage information, including information about your interaction with the Services, such as how and when you interact with or browse the Services.

Personal data of the data subjects collected for marketing purposes, as described in the following paragraph, are freely provided, and therefore collected, directly from the individuals themselves by filling out the fields in the 'Subscribe to the Newsletter' section on this website.

Purposes of personal data processing of data subjects

The personal data provided may be processed for the following purposes, all legitimate under the current personal data protection regulations:

• Management of requests for information and customer after‑sales assistance: providing the data necessary for these purposes is optional. However, refusal to provide the data in the fields marked as mandatory will make it impossible to obtain the requested information. Legal basis: performance of pre‑contractual measures or performance of the contract and the resulting fulfilment of the legal obligations incumbent upon the data controller. In the event of a dispute, the data will be processed to bring or defend a claim in court, which corresponds to the legitimate interest of the data controller.
• Purchase and shipment of the purchased product: providing the data necessary for these purposes is optional. However, refusal to provide the data in the fields marked as mandatory will make it impossible to complete the purchase. The data are also necessary for the fulfilment of legal obligations (including accounting and tax obligations) or for handling disputes raised concerning the proper performance of the contract. Legal basis: performance of a contract and the resulting fulfilment of the legal obligations incumbent upon the data controller. In the event of a dispute, the data will be processed to bring or defend a claim in court, which corresponds to the legitimate interest of the data controller.
• Marketing: Sending promotional-advertising communications on products, services, and activities of Elite S.r.l. SB, with automated contact methods or electronic communications using email and messages of the type sms, is, mms; market research and detection of appreciation and satisfaction with the services rendered to the data subjects. The provision of data necessary for these purposes is optional. Any refusal to provide them, in the fields not marked as essential, does not lead to any consequence in relation to access to Elite S.r.l. SB products and services, but precludes the possibility of carrying out the processing for marketing purposes. Through express consent for these purposes, the data subject also consents to the receipt of the aforementioned informative, commercial, and advertising communications through traditional contact methods (paper mail or telephone calls). Legal basis: Consent of the data subject pursuant to Art. 6, para. 1, letter a) GDPR.
  The consent, collected through the cookie settings on our website, may be withdrawn at any time by using the unsubscribe functions or preference‑management tools available on the website itself.
• Profiling: automated processing of personal data collected through browsing on the website (IP address, user agent, operating system, browser, screen resolution, language, date and time of access, referrer URL, pages visited, time spent on page, scroll depth, clicks on elements, navigation path, downloads performed, products viewed, internal searches performed, cookie IDs, advertising IDs, CRM IDs (if logged in), retargeting pixels, and any cross‑device identifiers) and for purchases made on the online shop (name, surname, email, telephone number, shipping/billing address, customer/account ID, products viewed, pages visited, time spent on page, cart, additions/removals, cart abandonment, clicks on banners/offers, traffic source – ads, social, organic – purchased products, purchase frequency, payment method (without storing complete card details), returns), aimed at analyzing user behavior and personalizing the shopping experience, content, and commercial offers. Legal basis: consent of the data subject pursuant to Art. 6, para. 1, letter a) GDPR. Consent, collected through the cookie settings on our website, may be withdrawn at any time by using the unsubscribe functions or preference‑management tools available on the website itself. Under no circumstances will profiling be used for discriminatory purposes or for automated profiling activities producing legal effects concerning the data subject.
• Providing, Personalizing and Improving the Services: we use your personal information to provide you with the Services, including fulfilling our contract with you, processing your payments, fulfilling your orders, remembering your preferences and items of interest, sending you account‑related notifications, processing purchases, returns, exchanges or other transactions, creating, maintaining and otherwise managing your account, arranging shipment, facilitating any returns and exchanges, enabling you to post reviews, and creating a personalized shopping experience for you, such as recommending products related to your purchases. Legal basis: performance of a contract and the resulting fulfilment of the legal obligations incumbent upon the data controller, and the data controller’s legitimate interest pursuant to Art. 6, para. 1, letters b), c), f) GDPR.
• Security and Fraud Prevention: we use your personal information to authenticate your account, provide a secure payment and shopping experience, detect, investigate or take action regarding potentially fraudulent, illegal, unsafe, or harmful activities, protect public safety, and safeguard our services. If you choose to use the Services and register an account, you are responsible for keeping your login credentials secure. We strongly recommend that you do not share your username, password, or other login details with anyone. Legal basis: performance of a contract and the resulting fulfilment of the legal obligations incumbent upon the data controller pursuant to Art. 6, para. 1, letters b), c) GDPR.
• Legal Purposes: we use your personal information to comply with applicable law or respond to valid legal processes, including requests from law enforcement or government agencies, to investigate or participate in civil investigations, potential or actual legal proceedings, or other adversarial legal processes, and to enforce or investigate potential violations of our terms or policies. Legal basis: performance of a contract and the resulting fulfilment of the legal obligations incumbent upon the data controller pursuant to Art. 6, para. 1, letters b), c) GDPR.

Methods of personal data processing

In relation to the purposes indicated in the "Purposes of personal data processing of data subjects" paragraph, the processing of personal data is carried out using computer, telematic, and manual tools (e.g., on paper support), according to logic strictly related to the purposes themselves and in any case with tools capable of guaranteeing the security and confidentiality of the data themselves. The processing is carried out by authorized personnel assigned to carry out these tasks, constantly identified, appropriately instructed, and informed of the constraints imposed by the personal data protection regulations and with the adoption of the security measures currently most suitable to avoid accidental loss, accidental destruction, unlawful or incorrect use, and unauthorized access. Personal data will be retained for the time necessary to pursue the intended purposes and until a request for cancellation by the data subject. The processing of personal data implies knowledge of the same by those authorized to process it (for example: those in charge of IT systems, the administrative office, marketing, communication, and logistics). For purchases made through the online shop, the data will be disclosed to Shopify, as an independent controller, for the management of the e‑commerce platform and the processing of orders, and to our marketing agency for activities related to user behavior analysis, profiling, remarketing, and personalization of commercial offers.

Personal data may be communicated to third parties, to whom the communication is necessary to technically pursue the purposes analytically described in the "Purposes of personal data processing of data subjects" paragraph. If any of these entities operate an information infrastructure located, even partially, outside the territory of the European Union, the disclosure shall be subject to the existence of adequate safeguards for the transfer (including with regard to any international conventions) or to the prior approval by the competent supervisory authority of binding corporate rules applicable to the entity in question.
The complete list of these subjects is available by contacting the data controller at privacy@elite-it.com.

Retention period

Your personal data are processed only for the time necessary to fulfil the purposes listed above and in accordance with applicable laws, without prejudice to the data subject’s right, with regard to processing for marketing purposes related to the receipt of the newsletter, to unsubscribe from the mailing list at any time by clicking the dedicated link/button located at the bottom of each message, or by exercising their data‑protection rights by writing to the email address privacy@elite-it.com; and, with regard to processing for profiling purposes, to manage the preferences available on the website.

How We Disclose Personal Information
In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

• With Shopify, providers, and other third parties that perform services on our behalf (e.g., IT management, payment processing, data analytics, customer service, cloud storage, order fulfillment, and shipping).
• With business and marketing partners to provide marketing and advertising services. For example, we use Shopify to support personalized advertising with third‑party services based on your online activity with various merchants and websites. Our business and marketing partners will use your information in accordance with their own privacy policies. Depending on where you reside, you may have the right to tell us not to share information about you for targeted advertising and marketing based on your online activity with different merchants and websites. 
• When you instruct, request, or otherwise consent to our disclosure of certain information to third parties, such as to have products shipped to you or through your use of social media widgets or login integrations.
• With our affiliates or otherwise within our corporate group.
• In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligation (including responding to subpoenas, search warrants, and similar requests), to enforce applicable terms of service or policies, and to protect or defend the Services, our rights, and the rights of our users or others.

Relationship with Shopify
The Services are hosted by Shopify, which collects and processes personal information about your access to and use of the Services in order to provide and improve the Services for you. The information you submit to the Services will be transmitted to and shared with Shopify, as well as with third parties that may be located in countries different from where you reside, in order to provide and improve the Services for you. Furthermore, to help protect, grow, and improve our business, we use certain advanced Shopify features that incorporate data and information obtained from your interactions with our Store, together with other merchants and Shopify. To provide these advanced features, Shopify may use personal information collected about your interactions with our store, other merchants, and Shopify. In these circumstances, Shopify is responsible for processing your personal information, including responding to your requests to exercise your rights regarding the use of your personal information for these purposes. To learn more about how Shopify uses your personal information and about any rights you may have, you may visit the Shopify Consumer Privacy Policy. Depending on where you live, you may exercise certain rights regarding your personal information here via the Shopify Privacy Portal.

Third‑Party Websites and Links
The Services may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated with or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of the information found on them. Information you provide in public or semi‑public locations, including information you share on third‑party social networking platforms, may also be viewable by other users of the Services and/or users of such third‑party platforms without limitations on their use by us or by others. Our inclusion of such links does not, by itself, imply any endorsement of the content of such platforms or of their owners or operators, except as disclosed within the Services.

Subjects involved in the personal data processing

The users—i.e., the operators—of the “My RealVideo” application, available for Android and iOS operating systems, are the "data subjects" of the processing in question.

Personal data subject to processing

The processing will concern the following categories of personal data of the data subjects that may be freely provided and collected directly from them, through the completion of the fields present in the registration screens of the aforementioned application:

• Identifying and contact data: name, surname, email address, as data essential for the use of the application.
• Location data: This data, processed by the Data Controller exclusively to allow the user to use the Application, currently includes the route taken during training for the reconstruction of the altimetric profile and for the toponymic visualization on the map. All data relating to the positioning of the devices outside of training sessions are not acquired, processed, or transmitted to the servers in any way by the application. The location of the devices is not continuously tracked by the application. Location data may be disclosed solely by the user themselves who publishes the content related to the Application to share it with other users.

Methods of personal data processing

In relation to the purposes indicated in the "Purposes of personal data processing of data subjects" paragraph, the processing of personal data is carried out using computer, telematic, and manual tools (e.g., on paper support), according to logic strictly related to the purposes themselves and in any case with tools capable of guaranteeing the security and confidentiality of the data themselves. The processing is carried out by authorized personnel assigned to carry out these tasks, constantly identified, appropriately instructed, and informed of the constraints imposed by the personal data protection regulations and with the adoption of the security measures currently most suitable to avoid accidental loss, accidental destruction, unlawful or incorrect use, and unauthorized access. Personal data will be retained until a request for cancellation of the user profile by the data subject. The processing of personal data implies knowledge of the same by those authorized to process it (for example: those in charge of IT systems, the administrative office, marketing, communication, and logistics). Personal data may be communicated to third parties, to whom the communication is necessary to technically pursue the purposes analytically described in the "Purposes of personal data processing of data subjects" paragraph. If these include subjects whose information infrastructure is located, even only in part, outside the territory of the European Union, the communication will be subject to the presence of adequate guarantees for the transfer (also with regard to any international conventions) or to the prior approval by the competent supervisory authority of binding corporate rules applicable to the subject in question. The complete list of these subjects is available by contacting the data controller at the address indicated above.

Purposes of personal data processing of data subjects

The personal data provided may be processed for the following purposes, all legitimate under the current personal data protection regulations:

1. Use of the application: The provision of data necessary for these purposes is optional. Any refusal to provide them, in the fields marked as essential, makes it impossible to continue to use some or all features of the application.
2. Marketing: Sending promotional-advertising communications on products, services, and activities of Elite S.r.l. SB, with automated contact methods or electronic communications using email and messages of the type sms, is, mms; market research and detection of appreciation and satisfaction with the services rendered to the data subjects. The provision of data necessary for these purposes is optional. Any refusal to provide them, in the fields not marked as essential, does not lead to any consequence in relation to access to Elite S.r.l. SB products and services, but precludes the possibility of carrying out the processing for marketing purposes. Through express consent for these purposes, the data subject also consents to the receipt of the aforementioned informative, commercial, and advertising communications through traditional contact methods (paper mail or telephone calls). Under no circumstances will consumer profiling activities of the data subjects be carried out, in any way or form.

Subjects involved in the personal data processing

The users—i.e., the operators—of the “MyEtraining” application, available for Android and iOS operating systems, are the "data subjects" of the processing in question.

Personal data subject to processing

The processing subject to this notice will concern the following categories of personal data of the data subjects that may be freely provided and collected directly from them, through the completion of the fields present in the registration screens of the aforementioned application.

Identifying and contact data:

• name, surname, email address, as data essential for the use of the application;
• date of birth, required for the use of some application features;
• full address of domicile or residence, as essential data in case of direct invoice issuance by Elite S.r.l. SB.

Data capable of revealing the state of health (health data):

• heart rate;
• weight.

Location data 

Location data processed by the Data Controller exclusively to allow the user to use the Application currently includes:

• route taken during training for the reconstruction of the altimetric profile and for the toponymic visualization on the map.

All data relating to the positioning of the devices outside of training sessions are not acquired, processed, or transmitted to the servers in any way by the application.
The location of the devices is not continuously tracked by the application.
Location data may be disclosed solely by the user themselves who publishes the content related to the Application to share it with other users.

Methods of personal data processing

In relation to the purposes indicated in the "Purposes of personal data processing of data subjects" paragraph, the processing of personal data is carried out using computer, telematic, and manual tools (e.g., on paper support), according to logic strictly related to the purposes themselves and in any case with tools capable of guaranteeing the security and confidentiality of the data themselves. The processing is carried out by authorized personnel assigned to carry out these tasks, constantly identified, appropriately instructed, and informed of the constraints imposed by the personal data protection regulations and with the adoption of the security measures currently most suitable to avoid accidental loss, accidental destruction, unlawful or incorrect use, and unauthorized access. The systems with which the data capable of revealing the state of health will be processed are configured in such a way as to avoid the use of personal data or, as the case may be, the identifiability of the data subjects, when they are not strictly necessary in relation to the purpose pursued, with their consent, by the processing. Personal data will be retained until a request for cancellation of the user profile by the data subject. 
The processing of personal data implies knowledge of the same by those authorized to process it (for example: those in charge of IT systems, the administrative office, marketing, communication, and logistics). Personal data may be communicated to third parties, to whom the communication is necessary to technically pursue the purposes analytically described in the "Purposes of personal data processing of data subjects" paragraph.
If these include subjects whose information infrastructure is located, even only in part, outside the territory of the European Union, the communication will be subject to the presence of adequate guarantees for the transfer (also with regard to any international conventions) or to the prior approval by the competent supervisory authority of binding corporate rules applicable to the subject in question. The complete list of these subjects is available by contacting the data controller at the address indicated above.

Purposes of personal data processing of data subjects

The personal data provided may be processed for the following purposes, all legitimately under the current personal data protection regulations:

• Use of the application: The provision of data necessary for these purposes is optional. Any refusal to provide them, in the fields marked as essential, makes it impossible to continue to use some or all features of the application.
• Marketing: Sending promotional-advertising communications on products, services, and activities of Elite S.r.l. SB, with automated contact methods or electronic communications using email and messages of the type sms, is, mms; market research and detection of appreciation and satisfaction with the services rendered to the data subjects. The provision of data necessary for these purposes is optional. Any refusal to provide them, in the fields not marked as essential, does not lead to any consequence in relation to access to Elite S.r.l. SB products and services, but precludes the possibility of carrying out the processing for marketing purposes. Through express consent for these purposes, the data subject also consents to the receipt of the aforementioned informative, commercial, and advertising communications through traditional contact methods (paper mail or telephone calls). Under no circumstances will consumer profiling activities of the data subjects be carried out, in any way or form.

Subjects involved in the personal data processing

The users—i.e., the operators—of the application, available for Android and iOS operating systems, are the "data subjects" of the processing in question.

Personal data subject to processing.
The processing covered by this notice will concern the following categories of personal data of the data subjects, which may be freely provided and collected directly from them through the completion of the fields in the registration screens of the aforementioned application.

Identification and contact data
Identification and contact data currently include: first name, last name, and email address, which are essential for the use of the application.
In addition to these, the app will only record technical data related to product updates.

Methods of personal data processing

In relation to the purposes indicated in the "Purposes of personal data processing of data subjects" paragraph, the processing of personal data is carried out using computer, telematic, and manual tools (e.g., on paper support), according to logic strictly related to the purposes themselves and in any case with tools capable of guaranteeing the security and confidentiality of the data themselves. The processing is carried out by authorized personnel assigned to carry out these tasks, constantly identified, appropriately instructed, and informed of the constraints imposed by the personal data protection regulations and with the adoption of the security measures currently most suitable to avoid accidental loss, accidental destruction, unlawful or incorrect use, and unauthorized access. Personal data will be retained until a request for cancellation of the user profile by the data subject. The processing of personal data implies knowledge of the same by those authorized to process it (for example: those in charge of IT systems, the administrative office, marketing, communication, and logistics). Personal data may be communicated to third parties, to whom the communication is necessary to technically pursue the purposes analytically described in the "Purposes of personal data processing of data subjects" paragraph. If these include subjects whose information infrastructure is located, even only in part, outside the territory of the European Union, the communication will be subject to the presence of adequate guarantees for the transfer (also with regard to any international conventions) or to the prior approval by the competent supervisory authority of binding corporate rules applicable to the subject in question. The complete list of these subjects is available by contacting the data controller at the address indicated above.

Purposes of personal data processing of data subjects

The personal data provided may be processed for the following purposes, all legitimately under the current personal data protection regulations:

1. Use of the application: The provision of data necessary for these purposes is optional. Any refusal to provide them, in the fields marked as essential, makes it impossible to continue to use some or all features of the application.
2. Marketing: Sending promotional-advertising communications on products, services, and activities of Elite S.r.l. SB, with automated contact methods or electronic communications using email and messages of the type sms, is, mms; market research and detection of appreciation and satisfaction with the services rendered to the data subjects. The provision of data necessary for these purposes is optional. Any refusal to provide them in the fields not marked as essential, does not lead to any consequence in relation to access to Elite S.r.l. SB products and services, but precludes the possibility of carrying out the processing for marketing purposes. Through express consent for these purposes, the data subject also consents to the receipt of the aforementioned informative, commercial, and advertising communications through traditional contact methods (paper mail or telephone calls). Under no circumstances will consumer profiling activities of the data subjects be carried out, in any way or form.

Subjects involved in the personal data processing

The users—i.e., the operators—of the application, available for Android and iOS operating systems, are the "data subjects" of the processing in question.

Personal data subject to processing.
The processing described in this notice will concern the following categories of personal data of the data subjects, which may be freely provided and collected directly from them through the completion of the fields in the registration screens of the aforementioned application.

Identification and contact data
Identification and contact data currently include: first name, last name, and email address, which are considered essential for the use of the application.

Methods of personal data processing

In relation to the purposes indicated in the "Purposes of personal data processing of data subjects" paragraph, the processing of personal data is carried out using computer, telematic, and manual tools (e.g., on paper support), according to logic strictly related to the purposes themselves and in any case with tools capable of guaranteeing the security and confidentiality of the data themselves. The processing is carried out by authorized personnel assigned to carry out these tasks, constantly identified, appropriately instructed, and informed of the constraints imposed by the personal data protection regulations and with the adoption of the security measures currently most suitable to avoid accidental loss, accidental destruction, unlawful or incorrect use, and unauthorized access. Personal data will be retained until a request for cancellation of the user profile by the data subject. The processing of personal data implies knowledge of the same by those authorized to process it (for example: those in charge of IT systems, the administrative office, marketing, communication, and logistics). Personal data may be communicated to third parties, to whom the communication is necessary to technically pursue the purposes analytically described in the "Purposes of personal data processing of data subjects" paragraph. If these include subjects whose information infrastructure is located, even only in part, outside the territory of the European Union, the communication will be subject to the presence of adequate guarantees for the transfer (also with regard to any international conventions) or to the prior approval by the competent supervisory authority of binding corporate rules applicable to the subject in question. The complete list of these subjects is available by contacting the data controller at the address indicated above.

Purposes of personal data processing of data subjects

The personal data provided may be processed for the following purposes, all legitimately under the current personal data protection regulations:

• Use of the application: The provision of data necessary for these purposes is optional. Any refusal to provide them, in the fields marked as essential, makes it impossible to continue to use some or all features of the application.
• Marketing: Sending promotional-advertising communications on products, services, and activities of Elite S.r.l. SB, with automated contact methods or electronic communications using email and messages of the type sms, is, mms; market research and detection of appreciation and satisfaction with the services rendered to the data subjects. The provision of data necessary for these purposes is optional. Any refusal to provide them in the fields not marked as essential, does not lead to any consequence in relation to access to Elite S.r.l. SB products and services, but precludes the possibility of carrying out the processing for marketing purposes. Through express consent for these purposes, the data subject also consents to the receipt of the aforementioned informative, commercial, and advertising communications through traditional contact methods (paper mail or telephone calls). Under no circumstances will consumer profiling activities of the data subjects be carried out, in any way or form.

Data collected

No personal data of users is collected by the Square app. Only technical data is recorded also through the Sentry framework, used only to diagnose and resolve any malfunctions.

Last update 24/03/2026