Privacy Policy

Last updated: May 15, 2025

1. Data Controller

The Data Controller for personal data collected through this website is:

SURGYHUB S.R.L.

Registered office:
Via Eleonora Duse 26/B, 80126 Naples (NA), Italy

Tax Code: 123456789

VAT Number: 123456789

REA: NA-123456

PEC: surgyhub@pec.it

2. Types of Data Collected

The site collects and processes the following categories of personal data:

Browsing Data

IP address, browser type used, detailed device information, access times, pages visited, and navigation path within the site.

Identification Data

Information voluntarily provided by the user: name, surname, email address, phone number, shipping and billing address, necessary for order management.

Payment Data

Managed exclusively through secure and certified payment platforms (PayPal, Apple Pay, Google Pay, banking gateways). Our site never stores sensitive payment data.

3. Purpose of Processing

Personal data collected is processed for the following specific purposes:

Commercial Management

Order processing, shipping management, and after-sales services

Invoicing

Invoice issuance, accounting management, and customer support

Direct Marketing

Newsletter and promotional communications (only with prior consent)

Statistical Analysis

Aggregated and anonymous data via Google Analytics

Legal Obligations

Tax, accounting, and regulatory compliance

4. Legal Basis for Processing

In accordance with GDPR, data is processed based on the following legal bases:

Contract Performance

Online purchases, shipments, and related services

User Consent

Newsletter, marketing, and advertising profiling

Legal Obligations

Invoicing, tax and accounting compliance

Legitimate Interest

Performance analysis and site security

5. Data Retention

Personal data will be retained for the periods strictly necessary for processing purposes:

10
years

Tax and Accounting Purposes

Retention for mandatory regulatory compliance

24
months

Marketing Purposes

Unless consent is withdrawn earlier by the user

MIN
necessary

Technical Purposes

Strictly necessary time (e.g., sessions, technical cookies)

6. Data Subject Rights

In accordance with GDPR, users can exercise the following rights at any time:

Right of Access

View all personal data being processed

Rectification

Correct inaccurate or incomplete data

Erasure

Request deletion of data

Objection

Object to processing for legitimate reasons

Restriction

Request suspension of processing

Portability

Receive data in structured format

To exercise your rights

Send a detailed request to our PEC address:

surgyhub@pec.it

7. Disclosure to Third Parties

Personal data may be disclosed exclusively to the following categories of third parties:

Logistics Services

Couriers and suppliers for shipping and delivery

Payment Processors

PayPal, Apple Pay, Google Pay, banking gateways

Professional Consultants

Accountants, tax and legal consultants

Technical Providers

Hosting services, cloud computing, and IT support

Google LLC

For Google Analytics service (anonymous data)

Security guarantees: All third-party suppliers are bound by strict contractual confidentiality obligations and GDPR compliance.

8. Transfers to Non-EU Countries

The use of Google Analytics may involve the transfer of some aggregated data to the United States of America.

Safeguards Implemented

The transfer takes place based on Standard Contractual Clauses (SCC) approved by the European Commission, which guarantee a level of data protection equivalent to European standards.

9. Security Measures

We adopt adequate and up-to-date technical and organizational measures to protect personal data from:

Unauthorized access

Accidental loss

Destruction

Improper use

Guaranteed security: We use SSL/TLS encryption protocols, redundant backup systems, and strict access controls to ensure maximum protection of personal data.