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Privacy policy

(art. 13 Regulation UE n. 2016/679)


TOOLS for SMART MINDS S.R.L. (below "T4SM") as Data Controller of your Personal Data, pursuant to and due to the object of EU Regulation no. 2016/679 (below "GDPR"), hereby informs You that the cited legislation provides for the protection of persons and other subjects regarding the processing of Personal Data and that this Treatment will be based on principles of Correctness, Lawfulness, Transparency and on the protection of your Privacy and your Rights.
Your Personal Data will be processed in accordance with the legislative provisions of the cited legislation and the confidentiality obligations laid down therein.


Purpose of the treatment

Your Data will be processed for purposes related to the implementation of the following obligations, related to legislative or contractual obligations:

  1. Purposes necessary to ascertain, exercise or defend a Right in Court or whenever the jurisdictional Authorities exercise their jurisdictional duties;
  2. Advanced navigation purposes or personalized content Management;
  3. Purposes relating to the execution of a Contract of which they are part, or to the execution of pre-contractual measures adopted upon your request, or to request for information about our products and services, or to subscribe to our Newsletter;
  4. Purposes of statistical research/analysis on aggregated or anonymous data, without the possibility of identifying the user, aimed at measuring the functioning of the Site, measuring traffic and evaluating usability and interest.
  5. Marketing purposes.

The processing of functional data for the fulfillment of these obligations is necessary for a correct management of the relationship and their conferment is obligatory to implement the purposes indicated above. The Data Controller also declares that any non-communication, or incorrect communication, of one of the obligatory information, may cause the Data Controller's inability to guarantee the adequacy of the processing itself.

Method of treatment

Your Personal Data may be processed in the following ways:

  • By means of electronic calculators using software systems managed by third parties;
  • By means of electronic calculators using software systems managed or programmed directly;
  • Temporary treatment in an anonymous form.

Each treatment takes place in compliance with the procedures required by the provisions of art. 32 of the GDPR 2016/679 regarding security measures.

The Data Controller will process Personal Data, pursuant to art. 5 GDPR 2016/679, for the time necessary to fulfill the purposes and in any case for no more than 10 years from the termination of the service purpose and not later than 2 years from the collection of data for the Marketing Purposes.


Your data will be stored at our office and will be communicated exclusively to the competent subjects for the performance of the services necessary for a correct management of the relationship, with a guarantee of protection of the rights of the interested party.
Your data will be processed only by personnel expressly authorized by the Owner and by the following categories of persons in charge:

  • Marketing office;
  • Programmers and Analysts;
  • Customer care;
  • Administration, accounting office.

Your data may be disclosed to third-party companies or other entities carrying out outsourcing activities on behalf of the Data Controller, in their capability as External Data Controllers.


Your Personal Data will be disclosed in any way.
Your Personal Data will be stored on servers in European Union. In any case, if necessary, the Data Controller will have the right to move the servers even outside the UE.
T4SM ensures that the electronic and paper Treatment of your Personal Data by the Recipients takes place in the respect of the applicable Regulation. Transfers are based on an adequacy decision on the Standard Model Clauses approved by the European Commission.

Nature of the conferment of Personal Data and consequences of the decline

Conferment of Personal Data for the Purposes listed above is obligatory. In their absence, we cannot guarantee Services or Information requested by you.


Cookies Management 

If You have any doubts or concerns about the use of Cookies, you can always intervene to prevent them from being set and read, for example by changing the Privacy Settings in your Browser to block some types of them.
Since each browser - and often different versions of the same browser - also differ significantly from each other, if you prefer to act independently through the preferences of your browser you can find detailed information on the procedure required in the guide of your browser. For an overview of the mode of action for the most common browsers, you can visit the address
Advertising companies also allow you to give up on receiving targeted ads if desired. This does not prevent the setting of cookies but interrupts the use and collection of some Data by these companies.
For more information and cancellation options, visit


Content generated by third parties

In the blog section of this website it is possible to insert comments, which will be inserted by third parties. Even if they are manually approved, in order to avoid any negative repercussions for the website, each author is responsible for what is written.

When visitors leave comments on the site, the data shown in the comments form and the visitor's IP address are collected to facilitate spam detection.

Furthermore, the comments will be approved, or not, at the discretion of the website manager.

Comments or content generated by third parties will certainly not be published in the following cases:

  • They are clearly self-promotional;
  • They are not relevant to what is written;
  • Generate hatred;
  • That directly or indirectly damage, with no reason, the image of the company;
  • That contain any type of non-legal information.


Right of the Data Subject

In your capability as a Data Subject, you have the rights set forth in art. 15 GDPR and precisely the rights to:

  1. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
  2. obtain the indication: i) of the origin of personal data; ii) of the purposes and methods of the processing; iii) the logic applied in case of treatment carried out with the aid of electronic instruments; iv) of the identification details of the owner, the managers and the designated representative pursuant to art. 3, paragraph 1, GDPR; v) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the territory of the State, managers or agents;
  3. obtain: i) updating, rectification or, when you have the interested, integration of data; ii) cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; iii) the attestation that the operations referred to in number i) and ii) have been brought to the knowledge, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfilment it proves impossible or involves a use of means manifestly disproportionate to the protected right;
  4. object, in whole or in part: i) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; ii) to the processing of personal data concerning you for sending advertising material or for carrying out market research or commercial communication, by e-mail and/or through traditional marketing methods by telephone.

Where applicable, you also have the rights referred to in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

How to exercise your rights

You can exercise your rights at any time by sending:

  • an e-mail to This email address is being protected from spambots. You need JavaScript enabled to view it.
  • through PEC at This email address is being protected from spambots. You need JavaScript enabled to view it.


Data Controller, Data Processor

The Data Controller, under the EU Regulation, is TOOLS for SMART MINDS S.R.L. (Via Padania, 16 25030 Castel Mella BS); e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.; telephone +39 030 2681510 in the person of its legal Representative.
The updated list of Data Processors is kept at the registered office of the Data Controller.


The contents of T4SM (as a non-exhaustive example: photographs, works, images, videos, drawings, documents, logos and any other material, in any published format, including colors) are protected by the copyright and any other intellectual property right. Reproduction, in whole or in part, in any form without express written consent, is prohibited. T4SM has the exclusive right to prohibit or authorize reproduction in whole or in part of the contents of its website. Our sites may contain hyperlinks to other websites, due to the nature of the technology used we are not responsible for the content of the sites we propose links to. Please pay attention when external sites are reached by following the links of our sites. Read carefully the terms of use and privacy regulations. Our policy is to allow the activation of links to our customers. We reserve the right to oppose the activation of direct links to our websites and the right to request their removal. T4SM has taken every precaution to assure its users that the contents of its websites are accurate and do not contain incorrect or outdated information. However, no responsibility is assumed about users for the accuracy and completeness of the published contents without prejudice to their liability for willful misconduct and gross negligence and except as otherwise provided by law. Although in its own interest, due to the nature of the internet, T4SM cannot guarantee its users that the website operates continuously, without interruptions and in the absence of errors or malfunctions due to the connection to the Internet. In case of difficulty, please contact our customer service.

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