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SANUSLIFE INTERNATIONAL explains on this page how it processes the data provided by the users who visit its website and how the cookies that are installed on this website work.

These data protection provisions are provided pursuant to Art. 13 GDPR 2016/679 (EU General Data Protection Regulation, Regulation of the European Union standardizing the rules for the processing of personal data), the Recommendation No 2/2001 of the Working Party pursuant to Art. 29 and the general resolution of the data protection authority on cookies No 229 dated May 8, 2014.

The following information shall apply to this website and to all sub-domains directly affiliated with it. The controller shall not be liable for such data and cookies that are inserted and/or installed by websites of third-party providers which may be consulted via links.

Information on the controller

The controller is SANUSLIFE INTERNATIONAL with registered office in Alte Tierserstrasse 18, I-39053 Karneid (BZ) and administrative headquarters in Negrellistr. 13/C, I-39100 Bolzano (BZ). To exercise the rights stipulated in the legal provisions, you have the option to contact the controller at its administrative headquarters by phone at 0471 / 97 99 98 or in writing to the e-mail address info@sanuslife.com.

Purpose and legal basis of data processing.

SANUSLIFE INTERNATIONAL shall process data the user enters for the following purposes:

a. Requests for information, response to contact requests or support requests

Entering the requested data is necessary to process your inquiry. The legal basis for processing is, pursuant to point (b) of Art. 6(1) GDPR, 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 as well as, pursuant to point (f) of Art. 6(1), the processing for the purposes of the legitimate interests pursued by the controller or by a third party. The data processed based on your inquiry shall be stored for a period of 6 months.

b. Registration and use of the platform (FREE User)

The transmission of the requested data is essential for creating your account and for enabling you to access our platform and to use our services (such as access to our online community SANUSWORLD, use of the SANUSMAP service, purchase of SANUSPRODUCTS and other goods in the SANUSSTORE). We also need these data for the processing in connection with the services (the collection of SANUSCREDITS, the use and acceptance of SANUSCOINS, the participation in events hosted by SANUSLIFE INTERNATIONAL, the participation in the courses provided by the SANUSACADEMY, etc.). As a registered user, you are authorized to invite other persons to register with the SANUSLIFE INTERNATIONAL platform. Pursuant to point (b) of Art. 6(1) GDPR, the legal basis for processing is 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. The data processed in connection with the registration shall be processed until the time you file a request for erasure and cancellation of your registration.

c. Establishing a business relationship/partnership (SANUSCOMPANIES)

The transmission of the requested data is essential for checking your inquiry regarding the establishment of a business relationship (partnership) and, after a positive result, for then giving you the option to advertise and/or market your products via the SANUSLIFE platform (e.g. by becoming a STORE PARTNER, MAP PARTNER or TRADING PARTNER); the establishment of such a partnership requires that SANUSLIFE INTERNATIONAL processes the data regarding the purchases and sales of the business partner both for the purpose of meeting accounting and fiscal obligations and for all purposes related to the realization of the business relationship. Pursuant to point (b) of Art. 6(1) GDPR, the legal basis for processing is 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. The data processed in connection with the registration shall be stored until the business relationship ends.

d. Fulfillment of obligations arising from a law, a regulation or a provision under Union law

The disclosure of data is mandatory for this purpose, and the legal basis is the compliance with a legal obligation to which the controller is subject, as set out in point (c) of Art. 6(1) GDPR. The user’s consent is not required for this kind of processing. Having in mind that each user of the SANUSLIFE services can accumulate, use and accept INTERNATIONAL SANUSCREDIT and SANUSCOIN, data processing shall also include such processing that is triggered by these transactions. The data so processed shall be stored for the period of time stipulated by the relevant provisions.

e. Statistical analyses on aggregated or anonymized data

This kind of processing does not allow the user’s identification and only serves to check the effectiveness of web marketing campaigns or to review the website’s correct functionality by monitoring the frequency of access. The data protection law’s scope of application does not extend to the processing of aggregated or anonymous data that does not enable any identification of the user; therefore, consent to the processing of such data is not required.

f. Newsletters and business communications (FREE User)

The entry of the requested data for the subscription to our newsletter or for the receipt of advertising messages or advertising materials is voluntary, and the legal basis for the related data processing is the data subject’s consent. The data processed for advertising and marketing purposes shall be stored by us until the consent is revoked, unless the consent is renewed. The requirement to obtain a voluntary and specific consent shall not apply to such operations that are used to inform the user about campaigns and news on the virtual notice board that can be accessed via the reserved area.

Methods of processing, automated decision-making processes and data retention periods

Your data is processed electronically, even though potential paper processing is not excluded. We shall not use any automated decision-making processes to process your personal data. Data collected by means of cookies shall be stored for the period of time set by the individual cookie.

Disclosure of data (recipient)

For ensuring our website’s functionality and for the flawless provision of its contents, we may use third-party services. Third parties shall include IT service providers, hosting service providers, telecommunication companies, external legal or tax advisors, transport companies, authorities and other public institutions, business partners (SANUSCOMPANIES), cryptocurrency service providers, etc. We would also like to inform you that, in addition to the already mentioned persons and institutions, such users that are within your upline (i.e. the chain of sales partners who enabled you and e.g. the partner immediately above you to register) are able to see the profiles of the users immediately associated with you. Furthermore, we may use third-party services (haulers, etc.) to fulfill the requested services, e.g. in connection with the purchase of products. 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. You have the right to contact SANUSLIFE at any time to obtain a list of such external persons and institutions who view and process your data.

Reference is made to the paragraph at the end of the document with regard to the use of cookies of third-party providers.

Transmission of data to third countries and international organizations

The data provided by you 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. The homepage is hosted within the European Union.

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.

2. 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;

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.

COOKIES USED ON OUR WEBSITE

Navigation data

This website implicitly collects some personal data of the users who access the website, such as IP address, domain names of the computers used by the users to access the website, MAC addresses that are allocated by the manufacturer to the network cards, WLAN, etc. through the use of Internet communication protocols for and during its normal operation.

This information is not collected to identify the users, which may, however, be the case through links and also through processing that is cross-linked with data of third parties. Statistical information on the use of the website and its functionality as well as further information regarding the identification of liabilities in computer-related crime is gained from such data.

What are cookies?

Cookies are small text files that are installed on your terminal by websites that you visit. These data sets are then relayed to the website that installed them if and when the user next visits the website. Any cookies sent by other websites or web servers that a user may receive when navigating the website are referred to as third-party cookies.

Cookies are installed for a variety of purposes, including in order to authenticate a user’s IT information, monitor website browsing sessions and to allow users to choose the language of the website.

First- and third-party cookies

Cookies that are directly installed by SANUSLIFE INTERNATIONAL are “first-party cookies”. However, cookies that are installed and collected by a website that is not the website the user navigates are called “third-party cookies”.

Third-party cookies include the social buttons (or social plug-ins) that enable the website to interact with the best-known social media such as Facebook, Instagram, LinkedIn, Twitter, etc., or the Google Analytics cookies and such that are required to implement YouTube frames, etc. With regard to third-party cookies, the third-party providers these cookies refer to are responsible for supplying the privacy notice and the information on the management of the collected data.

Types of cookies

Technical cookies

Technical cookies are usually installed directly by the website operator and are used to enable communication between website and user. They may be navigation or session cookies, which ensure normal navigation and use of the website. They are usually stored for the duration of the website navigation. Furthermore, there are functionality cookies, which allow a better use of the website, e.g. to enable the user to choose the language of the website, place selected products in the shopping cart, etc.

As these cookies are essential for the website’s functionality, their installation on the user’s terminal does not require his/her prior consent.

Analytical cookies

These cookies collect information about users, such as the number of users who visit the website and which pages they browse, more or less in aggregate form. One of the best-known tools to obtain this type of statistical information is the Google Analytics service provided by Google Inc.

Analytical cookies are similar to technical cookies if the information collected is in aggregate form and if it is not possible to identify the individual user’s behavior. With regard to Google Analytics cookies in particular, it is necessary, at least in part, to anonymize the IP address of the user who visits the website and to eliminate any disclosure of the data via Google. Where such anonymity and the prevention of disclosure is not possible, these cookies become profiling cookies.

Profiling cookies

These cookies are used to track a user’s preferences and offer him/her ads that are based on those preferences. These cookies are particularly invasive and require the user’s consent before they can be installed on the user’s terminal.

Banner displayed when first accessing the website

According to the resolution of the data protection authority of May 8, 2014, if cookies other than technical cookies are used, websites need to display a banner the first time the user accesses it (so-called brief statement) that gives the user a short summary of how the website uses cookies, including a reference to the full text of the privacy policy.

SANUSLIFE INTERNATIONAL has set up the aforementioned banner. If the user clicks the “Accept” button, he/she accepts that the cookies are installed and can continue to use the website. In addition, a specific cookie was designated that stores the user’s choice regarding the installation of cookies. This means that the user will see the cookie only once. Should he/she wish to change his/her mind later, he/she needs to follow the instructions in the section “How to disable cookies”.

List of cookies installed by SANUSLIFE INTERNATIONAL

Our website installs the following cookies:

Cookie’s name / description Path Duration Function Type of cookie (technical cookie, analysis cookie, profiling cookie)
CAKEPHP Sanuslife.com Session Cookie used for the current session Technical cookie
REALM Sanuslife.com Session Identifying the server that uses the current data. Technical cookie (performance cookie)
_ga Sanuslife.com 2 years This cookie collects information that is used for analysis purposes in relation with use of the website by the users. Analytical cookie
_gat Sanuslife.com 1 minute This cookie limits data collection if there are too many queries for a page. Some queries are blocked and the results of this operation can be extrapolated. Analytical cookie
_gid Sanuslife.com 1 day It registers a unique identifier that generates statistical data on the use of the website by the user. Analytical cookie
Accept Sanuslife.com 1 month Cookie for accepting the banner. Technical cookie
fr Facebook.com 90 days Used by Facebook to track both the browser and the user. Profiling cookie

How to disable cookies

Google Chrome: https://support.google.com/chrome/answer/95647?hl=it
Internet Explorer: https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies
Mozilla Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
Safari: https://support.apple.com/it-it/HT201265

Link to the privacy statements of third-party providers who install cookies

Facebook: https://www.facebook.com/policies/cookies/
Google, Youtube: https://www.google.com/intl/it_it/policies/technologies/cookies/