Privacy Policy

Privacy Policy

DATA CONTROLLER S.P. International S.R.L. Via Giuseppe di Vittorio 33, 50145 Florence Tax ID and VAT No.: 04594180483 Business Registry: 04594180483 Florence REA: FI-463940 Share capital: €10,400.00 fully paid-in Paid-in share capital: 10,400 Certified email address: spinternationalsrl@cert.cna.it

This notice, regarding our privacy policy and the protection of your personal data (hereinafter referred to as the Privacy Policy), explains how S.P. International S.R.L. uses and manages the information you provide to us, including your personal data and any special categories of data (formerly known as sensitive data) that will be collected via the sphelmets.it website in order to provide you with the requested services.

Below are the methods proposed by the website through which users can contact S.P. International S.R.L. by providing their personal data (hereinafter collectively referred to as “contact methods”). The individual contact methods are described in detail later in this document. To go directly to the description of a specific contact method, click on its name below:

CONTACT OPTIONS OFFERED BY THE sphelmets.it WEBSITE

  • PHONE, FAX, EMAIL, AND MAILING ADDRESSES
  • CONTACT US FORM (REQUEST MORE INFORMATION)

This notice will also explain your options and rights regarding the data you provide to us; without this information, S.P. International S.R.L. may not be able to provide you with its services, either in whole or in part.

Reproduction of the contents of this document, in whole or in part, in any form, is prohibited.

In order to offer you Klarna’s payment methods, we may share your personal information—such as your contact details and order information—with Klarna during checkout so that Klarna can assess your eligibility for its payment methods and customize those payment methods for you. The personal information we share is processed in accordance with Klarna’s privacy policy.

Privacy Notice Regarding the Processing of Personal Data Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) and Article 13 of Legislative Decree No. 196/2003 (Privacy Code, as amended)

We wish to inform you that Legislative Decree No. 196 of June 30, 2003 ("Personal Data Protection Code" or "Privacy Code"), as well as Regulation (EU) 2016/679 (GDPR), provide for and guarantee the right to the protection of personal data processed by third parties, based on the principle that everyone has the right to the protection of personal data concerning them and to the processing of such data in a manner that respects fundamental rights and freedoms, as well as the dignity of the data subject, with particular reference to confidentiality and personal identity.

For the purposes of this privacy policy, the following terms are defined as:

  • "module": refers to the interface of a website or application that allows the client user to enter and submit one or more pieces of data freely typed by the user to the web server; it is also called a form or, more commonly, a form;
  • "processing": any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction;
  • "personal data": any information relating to an identified or identifiable natural person ("data subject"); a natural person is considered identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity;
  • "identifying data": personal data that allows for the direct identification of the data subject based on the criteria set forth above;
  • "special categories of data" (formerly " sensitive data" ): personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, and data concerning a person's health, sex life, or sexual orientation;
  • "data controller": a natural person, legal entity, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data;
  • "data processor": a natural person, legal entity, public authority, agency, or other body that processes personal data on behalf of the data controller;
  • "processors" (or authorized persons): natural persons authorized by the controller or the processor to carry out processing operations;
  • "data subject": the natural person to whom the personal data relate;
  • "disclosure": the communication of personal data to one or more specific recipients other than the data subject, the data controller’s representative within the territory of the State, the data processor, and persons in charge of processing, in any form, including by making the data available or allowing access to it;
  • "disclosure": the act of making personal data known to an unspecified group of people, in any form, including by making such data available or accessible;
  • "anonymous data": data that, either originally or as a result of processing, cannot be linked to an identified or identifiable data subject;
  • "blocking": the retention of personal data with the temporary suspension of all other processing operations;
  • "database": any organized collection of personal data, divided into one or more units located at one or more sites;
  • "Data Protection Authority": the Italian Data Protection Authority, established by Law No. 675 of December 31, 1996;
  • "minimum security measures": the set of technical, IT, organizational, logistical, and procedural security measures that constitute the minimum level of protection required in relation to the risks identified in Article 31 of the Privacy Code and Article 32 of the GDPR.

In accordance with Article 5 of the GDPR, the processing we will carry out on the data you provide will be based on the principles of lawfulness, fairness, and transparency and will be conducted in accordance with the principle of data processing necessity, configuring our IT systems and programs so that the use of personal and identifying data is minimized, thereby excluding such processing when the purposes pursued, in individual cases, can be achieved through, respectively, anonymous data and appropriate methods that allow for your identification only when necessary.

Data Controller: S.P. International S.R.L. Via Giuseppe di Vittorio 33, 50145 Florence Tax ID and VAT No.: 04594180483 Company Registration No.: 04594180483 Florence REA: FI-463940 Share capital: €10,400.00 fully paid-in Paid-in share capital: 10,400 Certified email: spinternationalsrl@cert.cna.it

Information collected from the website sphelmets.it and, therefore, by S.P. International S.R.L.

While browsing the sphelmets.it website, you will have the opportunity to contact S.P. International S.R.L., including by non-electronic means.

With regard to the information that may be requested of you or that you may provide voluntarily, we wish to inform you that the provision of such data may be optional in some cases and mandatory in others; in the latter cases, any refusal to provide such data could result in the failure to perform or the partial performance of the agreement.

The processing of data may also involve personal data falling within the category of "special categories of data," as defined above, in which case S.P. International S.R.L. will take all necessary precautions and comply with all requirements set forth in the GDPR (Article 9) and the Privacy Code.

Below is a list of the contact methods through which the sphelmets.it website may collect your personal information, or through which you may contact S.P. International S.R.L. by providing your personal data yourself. This information may be collected directly from the sphelmets.it website through services set up and managed directly by S.P. International S.R.L., or collected through third-party services. For each method of contact, detailed information is provided below to indicate who collects your information, the purposes for which it is collected, the legal basis for data processing, and, in the event of disclosure to third parties, the categories of third parties to whom it may be disclosed.

Ways to contact the site through which users may provide their personal information:

Phone, fax, email, and mailing addresses

  • Provider and Operator of the Contact Method: The service is provided and operated directly by this Application.
  • Purpose of Collecting Personal Data: The service collects personal data for the following purposes: To respond to requests for information; To respond to your requests.
  • Legal Basis for Data Processing: The legal basis for data processing, pursuant to Article 6(1)(a) of the GDPR, is the consent you have provided for the processing of your personal data for one or more specific purposes. Alternatively, for contractual relationships, Article 6(1)(b) (performance of a contract) may apply.
  • Disclosure of Collected Data to Third Parties: The data collected by this service will be disclosed to the following categories of third parties: Partners.
  • Service Description: As you browse the site, you will find our phone numbers, fax numbers, email addresses, and mailing addresses so you can contact us.

Contact Us Form (Request More Information)

  • Provider and Operator of the Contact Method: The service is provided and operated directly by this Application.
  • Purpose of Collecting Personal Data: The service collects personal data for the following purposes: To respond to requests for information.
  • Legal Basis for Data Processing: The legal basis for data processing, pursuant to Article 6(1)(a) of the GDPR, is the consent you have provided for the processing of your personal data for one or more specific purposes.
  • Disclosure of Collected Data to Third Parties: The data collected by this service will be disclosed to the following categories of third parties: Partners.
  • Service Description: If you contact S.P. International S.R.L., you may be asked to provide us with information necessary to continue our relationship through "open-ended" request fields (such as submitting forms, sending emails, or other types of contact). In this specific case, you are free to send us additional information, which will always be processed in accordance with current privacy protection regulations. It is important to note that, in certain cases, if the information we request is not provided, we will not be able to offer our services, either in whole or in part.

How does S.P. International S.R.L. store your personal information, and under what circumstances does it share it?

All data you provide to us while browsing the sphelmets.it website will be processed, subject to your express consent regarding the processing as a whole or one or more specific processing operations, by the data controller, the data processors (if appointed by the data controller), and/or the persons appointed by the data controller and/or the data processors.

Any special categories of personal data you may provide may only be processed with your explicit consent (Art. 9 of the GDPR), in accordance with the conditions and limitations set forth in the GDPR, as well as applicable laws and regulations.

All operations performed on the data you provide will be carried out with the utmost care and attention and will be conducted in a manner that safeguards your privacy. The processing operations will involve the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction, as well as the combination of two or more of the aforementioned activities.

The data you provide will be processed manually and/or automatically, in paper and/or digital format (using electronic means owned by us and/or provided by third parties). It will be safeguarded using appropriate technical, IT, organizational, logistical, and procedural security measures, which constitute at least the minimum level of protection required in relation to the risks pursuant to Article 32 of the GDPR and Article 31 of the Privacy Code, and in any case comply with the principles of:

  • lawfulness, fairness, and transparency toward the data subject;
  • Purpose limitation (data will be collected for specific, explicit, and legitimate purposes, and subsequently processed in a manner that is not incompatible with those purposes);
  • data minimization (the data collected will be adequate, relevant, and limited to what is necessary in accordance with the purposes for which it is processed);
  • accuracy (the data will be updated and, if necessary, corrected in a timely manner);
  • limitation of storage (data will be stored in a form that allows for the identification of data subjects for a period no longer than is necessary to achieve the purposes for which they are processed; for example, contact information will be retained for 24 months from the date of collection or the last contact, unless otherwise required by law);
  • integrity and confidentiality.

We will process only those of your personal data that are strictly relevant, complete, and not excessive in relation to the purposes associated with the services for which they are collected or subsequently processed, and we will store them in a form that allows for your identification for a period of time no longer than is necessary for the purposes for which they are collected or subsequently processed, except where longer periods are required by law or to defend our legal rights.

Over time, the security measures implemented by S.P. International S.R.L. may be updated from time to time in light of the regulations in effect at that time and technical developments in the industry and/or in data storage and archiving technologies.

The data controller(s) and the persons and entities appointed by S.P. International S.R.L. will be properly trained, with particular emphasis on regulations and the implementation of minimum security measures, for the sole purpose of ensuring the confidentiality and security of the data. Under no circumstances will personal data be disclosed to third parties without your prior consent.

The personal information you provide through the sphelmets.it website is transmitted and may be stored on servers located both within the European Union and elsewhere. For transfers outside the EU, we implement appropriate safeguards such as standard contractual clauses or adequacy decisions by the European Commission (Articles 44–49 of the GDPR).

Any personal information you provide through your use of the sphelmets.it website may be disclosed by us to other companies within the S.P. International S.R.L. group and/or to third parties as described in the scenarios outlined below.

Disclosure of your data to third parties

All data processing operations described in this privacy policy may require that the information collected by S.P. International S.R.L. be shared with our affiliates, including those located abroad, as well as with our partners, suppliers (e.g., financial institutions, freight forwarders, logistics companies), consultants, any joint ventures, and any future owner of the website or our business, in connection with the provision of the services you have requested.

We may disclose your personal data to other companies in connection with any potential or actual reorganization, merger, sale, divestiture, transfer, or other disposition of our business or any part thereof, our assets, or our shares.

We may also engage and/or use the services of other companies or individuals to perform actions and functions on our behalf, including, for example, providing services, sending correspondence, providing marketing support, analyzing data, providing customer support, and for accounting, financial, commercial, administrative, billing, legal, and tax purposes, etc.

In order to carry out the tasks assigned to them, the individuals or companies mentioned above may process your personal information either as data processors appointed by us or as independent data controllers. We will disclose to these companies or individuals only the personal information that is strictly necessary for the specific performance of their duties.

Upon specific request, we may cooperate with any court, tribunal, administrative authority, law enforcement agency, or other similar authority in any investigation or proceeding that may concern you or relate to your use of the sphelmets.it website. Such cooperation may involve disclosing personal information about you to the authorities upon their explicit request.

Although our company takes appropriate measures to protect the personal information or any special categories of data that you provide, have provided, or will provide to us while using the sphelmets.it website, no transmission over the internet can, by definition, be guaranteed to be 100% secure.

Please keep in mind, therefore, that it is not possible—and we are therefore unable—to guarantee the absolute security of any personal information you transmit to us via the internet through the use of the sphelmets.it website or email services.

Plugins and Widgets

The website sphelmets.it, owned by S.P. International S.R.L., may use plugins provided by third parties.

When you visit a page on our website that contains one or more of these elements, your browser will display content (text and/or images) provided and/or determined by the plugin owner. These plugins may also install cookies (third-party cookies).

Our website is therefore not responsible for such content; please refer to the plugin owner’s privacy policy.

Our website may use social plugins from the following social networks, including but not limited to: facebook.com ("Facebook"), plus.google.com ("Google+"), the microblogging service twitter.com ("Twitter"), etc.

In the future, we may add plugins from other websites and/or social networks to the pages of our website.

Use of Cookies and Other Tracking Tools

Cookies are small text files that websites visited by the user send to their device, usually to the browser, where they are stored and then sent back to those same websites the next time the device visits them. This website, owned by S.P. International S.R.L., uses technical cookies. These cookies do not allow for the collection of personal data that identifies the user.

This section is updated in accordance with the Guidelines of the Italian Data Protection Authority on cookies and other tracking tools dated June 10, 2021 (web doc. no. 9677876), effective as of January 9, 2022, and confirmed by subsequent measures, such as those dated July 17, 2025 [web doc. 10174517] and July 10, 2025 [web doc. 10162286], which reaffirm the requirement for valid and revocable consent, prohibiting pre-flagging and unlawful cookie walls.

We use CookieYes as our Consent Management Platform (CMP) to ensure compliance with the GDPR and Italian regulations. CookieYes manages the cookie banner, automatically blocks non-technical cookies until explicit consent is given, records consent in a granular, revocable, and traceable manner (with logs retained for at least 6 months), and supports geolocation to apply EU-specific rules. Consent is collected in a valid manner: prior, informed, unambiguous, free, and specific. The banner presents equally prominent and accessible options for acceptance, refusal, or customization (e.g., buttons of the same size and neutral color); closing with an 'X' or continuing to browse implies implicit refusal of non-technical cookies. We do not repeat the banner for at least 6 months unless there are significant changes (e.g., new trackers) or revocation. We do not use cookie walls that make access to the site conditional on consent, unless equivalent free alternatives are offered. You can revoke your consent at any time via the dedicated link in the site footer, with immediate effect.

What Are Cookies? Cookies are small text files that websites visited by the user send and store on their device, to be sent back to those same websites on the next visit. Thanks to cookies, the website remembers the user’s actions and preferences so that they do not have to be re-entered when the user returns to visit the site or navigates from one page to another within it. Cookies, therefore, can be used to perform user authentication, track sessions, and store information regarding the activities of users accessing a website. They may also contain a unique identifier to track the user’s activities within the website for statistical or advertising purposes.

While browsing a website, users may also receive cookies on their devices from websites or web servers other than the one they are visiting (so-called “third-party” cookies). Certain operations could not be performed without the use of cookies, which are therefore technically necessary in some cases for the website to function properly.

Types of Cookies There are various types of cookies, depending on their characteristics and functions, and these may remain on the user’s device for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; and so-called persistent cookies, which remain on the user’s device until a predetermined expiration date.

Under current Italian law (Article 122 of the Privacy Code and the ePrivacy Directive 2002/58/EC), the user’s express consent is not always required for the use of cookies. In particular, so-called “technical” cookies do not require such consent; that is, those used solely for the purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user. These are cookies that are essential for the functioning of the website or necessary to perform activities requested by the user.

Among technical cookies, which do not require explicit consent for their use, the Italian Data Protection Authority (see Guidelines of June 10, 2021, and subsequent measures) also includes:

  • Analytics cookies, when used directly by the website operator to collect aggregated information on the number of users and how they visit the site, provided that the data is anonymized (e.g., IP masking).
  • Browsing or session cookies that ensure the normal browsing and use of the website (allowing you, for example, to make a purchase or log in to access restricted areas).
  • Functionality cookies, which allow users to navigate the site based on a set of selected criteria (such as language or products selected for purchase) in order to improve the service provided to them.

In contrast, so-called profiling cookies—that is, those designed to create user profiles and used to send advertisements tailored to the preferences the user has expressed while browsing the web—require the user’s prior consent.

What types of cookies does this website use? This website uses technical cookies—specifically, navigation or session cookies—which are strictly necessary for the website to function or to allow users to access the content and services they request. It also uses analytics cookies, which help us understand how users interact with the website. These cookies do not collect information about the user’s identity or any personal data. The information is processed in aggregated and anonymized form. Functionality cookies, i.e., cookies that allow the user to navigate based on a set of selected criteria (e.g., language, products selected for purchase) in order to improve the service provided. Third-party cookies, i.e., cookies from websites or web servers other than this one, used for purposes specific to those third parties. For further information on the processing of personal data pursuant to Article 13 of the GDPR, please refer to the specific Privacy Policy.

How to Manage Cookies in Major Browsers Users can enable, block, or delete (in whole or in part) cookies using the specific settings in their web browser. However, if all or some of the cookies are disabled, the website may become inaccessible, certain services or specific features of the website may not be available or may not function properly, and/or you may be required to manually modify or enter certain information or preferences each time you visit the website.

For more information on how to set your cookie preferences in your web browser, please refer to the instructions by clicking on the links below:

  • INTERNET EXPLORER
  • FIREFOX
  • CHROME
  • OPERA
  • SAFARI

Third-party cookies used by this website Third-party profiling cookies are cookies designed to create user profiles and are used, for example, to send advertising messages tailored to the preferences the user has expressed while browsing the web. Third-party cookies are cookies from websites or web servers other than this one, used for purposes specific to those third parties. We have no specific control over these entities and their cookies. To obtain information about these cookies, their characteristics, and how they work, and to provide your specific consent, please contact these third parties directly.

Users can typically disable third-party cookies using the appropriate setting in their web browser; please refer to the instructions provided above. Additional tools and information to help manage consent regarding third-party cookies can be found at http://www.youronlinechoices.com.

Third-party services used by this website that may place cookies, including profiling cookies, on your device:

Google Analytics (Anonymized)

  • Service Description: Google Analytics is a web analytics service provided by Google Inc. (“Google”). Through this service, Google collects a set of personal data from website visitors and uses it to track and analyze how they use the website. This version of Google Analytics is “anonymized,” meaning that visitor data is sent to Google, but their IP addresses are anonymized and therefore cannot be traced back to a specific individual visitor. The service may install third-party cookies.
  • Useful links: Google Inc. Privacy Policy, How Google Uses Cookies, Opt-Out.

Implementation of Regulation (EU) 2023/2854 (Data Act)

The EU Data Act, effective as of September 12, 2025, regulates access to and the sharing of data generated by connected products (IoT) and related services. For the sphelmets.it website, which primarily sells non-connected helmets, the Data Act has a limited impact. If we offer connected products (e.g., helmets with sensors or integrated apps), we guarantee:

  • Free, real-time access to the data generated (Sections 3–5 of the Data Act);
  • Data portability (Art. 6);
  • Transparency regarding the generation and use of data;
  • Prohibition of unfair contract terms (Art. 13). For mixed personal data, the Data Act supplements the GDPR, with the GDPR taking precedence on privacy matters (Art. 35 of the Data Act). If applicable, we will conduct impact assessments and notify users. Otherwise, this section does not apply.

Implementation of Law No. 132 of September 23, 2025 (Artificial Intelligence Act)

The Italian AI Act (No. 132/2025), effective as of October 10, 2025, complements the EU AI Act and strengthens the GDPR with regard to the use of AI. The sphelmets.it website does not currently use AI systems (e.g., for recommendations or automated analysis). If such systems are introduced:

  • We adhere to the principles of privacy by design and by default (Article 25 of the GDPR and the AI Act);
  • For automated decisions, we guarantee human intervention and the right to object (Art. 22 GDPR; Art. 5 of the AI Act);
  • We will conduct data protection impact assessments (DPIAs) for high-risk AI (Article 35 of the GDPR);
  • Transparency regarding training data and algorithms (Art. 13 of the GDPR and the AI Act);
  • We comply with restrictions on manipulative or discriminatory AI. In the absence of AI, this section is for informational purposes only.

Your rights under Articles 15–22 of the GDPR and Article 7 of Legislative Decree No. 196/2003

If you have any questions, comments, or requests for clarification regarding the privacy policy of S.P. International S.R.L. or this notice, if you wish to exercise your privacy rights or other rights related to your personal data, or if you have any other questions or requests, please contact us using the contact information provided on the website or by using the following details:

S.P. International S.R.L. Via Giuseppe di Vittorio 33, 50145 Florence Tax ID and VAT No.: 04594180483 Business Registry: 04594180483 Florence REA: FI-463940 Share capital: €10,400.00 fully paid-in Paid-in share capital: 10,400 Certified email: spinternationalsrl@cert.cna.it

We are happy to accommodate your requests; however, we cannot always delete information related to past interactions, transactions, and/or reservations.

It is important and necessary that you be informed of your rights as set forth in Articles 15–22 of the GDPR and Article 7 of Legislative Decree 196/2003:

  • the right to obtain confirmation as to whether or not personal data concerning you are being processed and to receive such data in a comprehensible form;
  • the right to obtain information regarding the purposes of data processing, the categories of personal data involved, the recipients or categories of recipients to whom the personal data have been disclosed, the retention period for the personal data or the criteria used to determine it, the existence of the right to request the rectification or erasure of the data or the restriction of processing, the right to lodge a complaint with a supervisory authority, the existence of automated decision-making, and meaningful information regarding the logic involved;
  • the right to obtain, without undue delay, the updating, rectification, or, where it is in your interest, the completion of the data; taking into account the purposes of the processing, you also have the right to have incomplete personal data completed, including by providing a supplementary statement;
  • the right to erasure ("right to be forgotten"), to have data anonymized, or to have data processed in violation of the law blocked, including data that no longer needs to be retained for the purposes for which it was collected or subsequently processed; confirmation that the above operations have been brought to the attention, including with regard to their content, of those to whom the data have been disclosed or disseminated, except where this proves impossible or involves a manifestly disproportionate effort compared to the right being protected;
  • the right to have processing restricted when you contest the accuracy of your personal data (for the period necessary to verify its accuracy), when the processing is unlawful, or when the data is necessary for the establishment, exercise, or defense of legal claims;
  • the right to receive your personal data in a structured, commonly used, and machine-readable format, without any hindrance from S.P. International S.R.L., provided that the processing is based on your consent and is carried out using automated systems (right to data portability);
  • the right to object, in whole or in part, on legitimate grounds, to the processing—including profiling—of your personal data carried out for the purposes of sending you advertising or direct sales materials, or for conducting market research or commercial communications;
  • the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent given prior to withdrawal.

You also have the right and obligation at any time to visit the section of the website designated for you—accessible once you log in to your account—to update any of your personal data held by us that is out of date or incorrect.

If you would like to obtain a copy of your personal data, notify us of any inaccuracies or errors in the information we hold about you, exercise your rights, or if you have any questions regarding our privacy policy, please contact us.

Requests addressed to the data controller or data processor may also be submitted by certified mail, fax, or email, unless the Data Protection Authority adopts a different method in light of new technological solutions. In any case, you may exercise your rights under Article 7, paragraphs 1 and 2, of the Privacy Code by making a request verbally; in such cases, the request will be briefly recorded by the data subject or the data processor.

You also have the right to file a complaint with the Italian Data Protection Authority (www.garanteprivacy.it) if you believe your rights have been violated.

Third-party websites and hyperlinks

Our website, sphelmets.it, may contain hyperlinks and/or advertisements to other websites that are neither owned nor controlled by S.P. International S.R.L.

Please note that this Privacy Policy applies solely and exclusively to the personal information we collect through our website, and we cannot be held liable in any way for personal information collected, stored, or used by third parties through their websites.

S.P. International S.R.L. recommends that you read the privacy policy of every website you visit.

Minors

By providing your personal data, you represent and warrant that you are at least 18 years of age. S.P. International S.R.L. does not intend to collect any personal data from individuals under the age of eighteen. Where necessary, we will specifically instruct children not to provide their data through our websites and/or take reasonable measures to ensure parental or guardian oversight of such data collection.

Parents and guardians should be aware that our privacy policy governs the use of personal data, but information voluntarily provided by minors—or by others—in comments or similar posts may be used by third parties to send unsolicited communications.

We encourage all parents and guardians to teach their children how to use their personal data safely and responsibly while browsing the internet, and to exercise appropriate oversight as they deem necessary.

In the event of a data breach

In the event of a personal data breach, S.P. International S.R.L. will notify the Data Protection Authority of such breach without undue delay, in accordance with Article 33 of the GDPR, and where possible within 72 hours of becoming aware of it. Such notification will be made in all cases, unless it is unlikely that the personal data breach poses a risk to the rights and freedoms of natural persons. If the personal data breach is likely to pose a high risk to the rights and freedoms of natural persons, S.P. International S.R.L., the data controller, will notify you of the breach without undue delay (Article 34 of the GDPR).

Changes to our Privacy Policy

Given that the current state of development of automated control mechanisms means they are not yet free from errors or malfunctions, we reserve the right to make, without prior notice, any changes to this privacy policy that we deem necessary or that are required by law or other regulatory sources. You should take care to check this privacy policy regularly, as you will be deemed to have accepted any changes and updates if you continue to use the site after they have been published.

Last updated: December 12, 2025.