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Information on the controller.

The controller is SANUSLIFE INTERNATIONAL GmbH with registered office in Karneid (BZ), Alte Tierserstrasse 18, and administrative headquarters in Bolzano, Negrellistr. 13/C. To exercise the rights stipulated in the legal provisions, you can contact the controller at its administrative headquarters by calling 0471 / 97 99 98 or by e-mail to info@sanuslife.com.

Purpose and legal basis of data processing. The purpose of processing your general personal data (first name, surname, address, tax number, IBAN, etc.) is to enable you to achieve “Member” status and to receive such services and benefits that are reserved to that category of users. SANUSLIFE INTERNATIONAL offers members bonuses, personal discounts, a special program for collecting SANUSCREDITS and the option to receive payments stipulated in a remuneration plan that is reserved to you. The legal basis for the processing is the fulfillment of legal obligations to which the controller is subject, the processing for the performance of a contract to which the data subject is party or the taking of steps at the request of the data subject prior to entering into a contract.

Disclosure of data (recipient). To realize the business relationship between the parties, your data may be disclosed to the following persons/institutions: IT service providers, external legal or tax advisors, business partners (SANUSCOMPANIES), transport companies, banks and financial institutions, authorities and other public institutions, other users within the upline (the chain of sales partners you are a part of: the sales partner who is originally above you, the partner above that one, etc.). The legal basis for the transmission is the fulfillment of statutory and contractual obligations and the taking of steps at your request prior to entering into a contract. At any rate, only such data shall be disclosed that are essential for the fulfillment of the relevant service. If the transmission of anonymized data turns out to be adequate, only such data shall be transmitted. Your personal data shall only be disseminated upon your express consent.

Transmission of data to third countries and international organizations. Your personal data shall not be transmitted to third countries or to international organizations outside the European Union. As it is an online platform, the data can be viewed in all countries around the world.

Marketing. Your personal data may be processed for marketing purposes. This includes e.g. sending advertising materials (newsletters, flyers, advertising e-mails, etc.), which only happens upon your express consent. The consent constitutes the legal basis for processing in this connection. If you do not give your consent, this shall not affect the provision of the main service. Please note that messages you receive in connection with the marketing of our products (e.g. special discount campaigns, special bonuses, etc.) are essential for the performance of your tasks. Therefore, they are not subject to consent and are handled as service communications.

Methods of processing, automated decision-making processes and data retention periods. Your data may be processed both in paper form and through the use of IT in compliance with the technical and organizational measures according to the regulation on the protection of personal data (General Data Protection Regulation 2016/679). The data concerning you shall be stored for the entire duration of the contractual relationship between the parties and, at any rate, for the period of time stipulated under private and tax law, which may exceed the aforementioned duration.

Rights of the data subject and complaints lodged with the data protection authority.

You are at any time entitled to exercise the rights of the data subjects that are listed below. To do so, please contact the controller (SANUSLIFE INTERNATIONAL) using the details stated above. We will respond to you in writing within 30 days. In addition, and if you think that your data have been processed unlawfully, you can lodge a complaint with the responsible supervisory authority, the Italian data protection authority (Garante per la Protezione dei dati Personali) with registered office in Rome (Italy).

I. Right of access by the data subject

1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: a) the purposes of the processing; b) the categories of personal data concerned; c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; f) the right to lodge a complaint with a supervisory authority; g) where the personal data are not collected from the data subject, any available information as to their source; h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

2. Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

II. Right to rectification

1. The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

III. Right to erasure

1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing; c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2); d) the personal data have been unlawfully processed; e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

a) for exercising the right of freedom of expression and information; b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3); d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or e) for the establishment, exercise or defense of legal claims.

IV. Right to restriction of processing

1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims; d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

V. Right to data portability

1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where: a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and b) the processing is carried out by automated means.

2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

VI. Right to object

1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

VII. Automated individual decision-making, including profiling

1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

2. Paragraph 1 shall not apply if the decision: a) is necessary for entering into, or performance of, a contract between the data subject and a data controller; b) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or c) is based on the data subject’s explicit consent.

3. In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

4. Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.