GENERAL CONDITIONS OF USE AND PRIVACY (CGUP)
Below are the terms and conditions of IF S.R.L. (SILOC), as well as information on the privacy policies and use of cookies of the domain https://siloc.it/ and linked landing pages. IF S.R.L. provides the user with a large amount of information because it wants the latter to have the maximum possible knowledge about what IF S.R.L. puts at your disposal. In this way, in fact, the processes and procedures used by IF S.R.L. are clear and there are no uncertainties about the purposes of the interactions between IF S.R.L. and users. The explanations provided are very detailed, in order to be actually understandable. The user is invited to read the terms below, as acceptance is required in order to proceed in accordance with them.
General terms of service of IF S.R.L. – SILOC
Last update: 02.05.23
Introduction to the Terms and Services of IF S.R.L. – SILOC
By accessing or using the websites and online and otherwise any software, service, functionality, product, program and element provided by or on behalf of IF S.R.L. on or in connection with such services or websites (collectively the “Services”), including, without limitation, any products, programs and services described in these Terms of Service, you (a) acknowledge that you have read and understand the Cookie Policy and Privacy Policy and (b) declares that you accept the terms and conditions of these Terms of Service (the “Agreement”) currently in effect with the following entities:
For real estate agencies, real estate professionals, banks, insurance companies, owners and tenants:
- If the user is located in Italy the service is provided by IF S.R.L. VAT no.:12162420017
All references to “IF S.R.L.” in this contract are related to the applicable subject, as indicated above.
The Service is made available for use solely by real estate agencies or real estate professionals (“agencies”), individuals and/or organizations such as credit institutions and insurance and reinsurance companies seeking information relating to the payment of past rents of rental of people and/or organizations (VAT number) looking for a rental who wish to make available information relating to current residence, position and work remuneration, payments and non-payments of past rentals already in our database, therefore personal and non-personal data, capable of determining conditions of economic sustainability or otherwise of the possible lease subject to the proposal.
You acknowledge and agree that your license to use the Service automatically revokes any attempt to use the Service for any other purpose not stated in the license. By accessing or using the Service as an employee or other representative of an "agency", you agree to this Agreement on your own behalf and on behalf of such "agency", as applicable, and you represent and warrant that you have the authority to bind such “agency,” as applicable, to this Agreement. You acknowledge that IF
S.R.L. owns the copyright relating to the IF S.R.L. Site and services, including the compilation of the information available through them.
IF S.R.L. may modify this Agreement by communicating such modifications through any reasonable means, including by posting a revised Agreement on the Site. Such modifications will not apply to any request made prior to the date on which the revised Agreement in accordance with such modifications is posted, or on which such changes were otherwise communicated. Access to or use of the Site/Service following any changes to this Agreement will constitute acceptance of such changes.
The wording “Last updated” in each section of the terms and conditions indicates the date the Agreement was last modified.
IF S.R.L. has the right, at any time and without any liability, to modify or discontinue, in whole or in part, the Site/Service (including access to the Site through third-party links); apply, modify or exempt from any charge required for the use of the Site/Service, or offer opportunities to some or all users thereof.
IF S.R.L. is committed to eliminating any form of modern slavery or human trafficking in its production chains or in every aspect of its activities.
This Agreement refers to all additional terms and conditions published by IF S.R.L. through the Site or otherwise made available to the user by IF S.R.L.. In particular:
· By accessing or using the SILOC SERVICE), you agree to be bound by the SILOC SERVICE Terms
· For all other uses of the Site, the user agrees to be bound by the general Terms of Service of IF S.R.L..
· For further information on the IF S.R.L. Terms, contact info@siloc.it
A/b. Terms of Service for REAL ESTATE AGENCIES AND PROFESSIONALS, OWNERS AND DRIVERS
For the purposes of this section A of the general Terms of Service of SILOC - IF S.R.L. , the term "user" indicates the individual or organization who accesses this service as a USER ENABLED BY SILOC - IF S.R.L.. As an ENABLED USER, the user is authorized to use the SILOC DI IF S.R.L. service. and the related contents exclusively for the purposes of this contract OR obtain a Report from IF SRL on the possible economic sustainability of the rental subject to the request to obtain the report and enter rental contracts to register the subjects in the SILOC database for information positive or negative.
1. REQUEST SILOC REPORT
IF S.R.L. makes available through documents protected by a password given to the user after enabling, a report on the possibility of financially supporting or not the rental subject to the proposal made by the tenant to the tenant. The reports are developed following a careful check of the documentation provided through the "agency" and based on the data already in possession of SILOC - IF S.R.L.. The SILOC - IF S.R.L. report it does not replace the owner's decision on whether or not to rent the property in any way, but provides a report containing information useful for making more informed decisions.
SILOC – IF S.R.L. assumes no responsibility for incorrect reports due to incorrect information provided to/by the "agency".
2. ACTIVATION OF THE REPORTING SERVICE
For each rental contract duly signed and entered by the qualified professional in SILOC, the owner can always report through the agency in case of delays, defaults on rent, expenses and damage to the property by notifying the tenant via registered mail and/or or PEC of the imminent report or delegating IF S.R.L. to communicate the imminent report to the tenant with 30 days' notice.
The cost of the service will be paid by the agency to SILOC - IF S.R.L. subject to final balance by the 5th of each month on the previous month and an invoice will be issued in the current month within 12 days after payment.
The Agency has the right to resell “SILOC” - IF S.R.L. as a service. to the renter and driver with a mark-up of up to a maximum of double the list price applied by SILOC - IF S.R.L..
For each report with a result lower than 50, no cost will be applied except in the case of a "review" that gives a result higher than 60; in this case the price foreseen for the service with REVIEW will be applied.
The cost of the annual agreement and reports are NOT contestable in the monthly proforma.
When uploading the rental contract to the portal, the agency can request registration of the latter with the Revenue Agency. The service has a one-off cost of €19.90 and involves only the FIRST REGISTRATION and no subsequent obligations. Registration of the contract in AdE is provided EXCLUSIVELY for contracts uploaded to SILOC.
For agencies with more than 15 annual rental contracts uploaded to SILOC, the uploading service to RLI is free. If 15 contracts entered in SILOC are not reached, the amounts will be invoiced at the end of 12 months.
REPORTING CONTRACTS ALREADY ACTIVE
For contracts stipulated with the agency's mediation before the activation of the agreement, it is possible to activate the reporting and monitoring service of the rental contract using a specific space within the agency portal.
The Service gives access to monitoring and reporting. The service will be available on the portal and active from 1.03.2023 indefinitely.
IF S.R.L. will proceed with the insertion of the contracts only after having viewed and received the documentation relating to the rental and privacy contract accompanied by a declaration of regular progress of the payments of the payment fees by the owner who will in no way have the right to report non-compliance by the tenant prior to the signatures and the inclusion of the contract in SILOC (risk centre). The contract will actually be inserted into SILOC only after appropriate checks.
3. REPORTS AND STORAGE TIMES
Each report must be made from the agency portal against the required documentation and SILOC - IF S.R.L. avails itself of the right to verify the authenticity of the report before inserting it into the database.
If the data and documents prove to be false or incorrect SILOC - IF S.R.L. will obscure the position and provide information regarding the injured party without assuming any responsibility.
The agency takes note and communicates from time to time to all interested parties (owner(s), tenant(s), guarantor(s)) of the storage times indicated in the privacy documents provided within the portal itself and always updated.
SILOC ONE +
Whenever the SILOC ONE+ guarantee is activated, it will be liable for the maximum amount indicated in the guarantee for the monthly payments of the contract indicated by the agency during the request phase, which may be extended through the automatic communication carried out by IF S.R.L. 6 months before the indicated contractual deadline and only in case of perfect fulfillment up to that date.
SILOC ONE+ is regulated by the contractual conditions indicated within the SILOC portal and appropriately updated.
The guarantee will be active from the first day of the contract appropriately loaded into the SILOC risk center.
The general conditions are available to any AUTHORIZED SILOC AGENCY.
Activations of the SILOC ONE guarantee are always subject to automatic or manual reporting of missed payments.
Each negative report is subject to the notice of imminent report sent to the recipient through certified channels such as PEC / Registered mail / hand delivery.
The tenant's data will be communicated according to the authorizations granted at the time of signing the data processing authorizations also for marketing purposes (in case of consent), to all collaborators of IF SRL (real estate agencies, credit institutions, companies insurance and reinsurance).
WHO HAS ACCESS TO THE DATA PRESENT IN SILOC?
The data will be made available to credit institutions and insurance and reinsurance companies as well as real estate agencies authorized and enabled to request reports. Partners such as credit institutions and insurance and reinsurance companies are made public through visibility in the PARTNER section of the site https://www.siloc.it/ and upon request via email addressed to info@siloc.it .
4. OBLIGATIONS AND REQUIREMENTS OF THE AGENCY/CUSTOMER
The agency as a professional authorized by IF S.R.L. assumes full responsibility for the legal obligations regarding the collection of data, the authenticity of the signatures placed in the presence of the agent and the appropriate checks regarding negative reports.
The agency undertakes to recognize what is indicated in the service activation order at the time of signing the collaboration contract attached to the latter.
The agency communicates an estimate of the annual rentals and IF S.R.L. makes use of the right to refuse the request for agreement and collaboration or to apply ad hoc prices in particular cases such as, for example, agencies with multiple offices and extremely high numbers of collaborators and locations.
The agent MANDATORY undertakes not to give up or allow anyone other than himself and his company to use the service.
The agency acknowledges that the information present in the SILOC reports is absolutely private and for exclusive use for the owner's choice in leasing the proposed property.
IT IS FORBIDDEN TO DISTRIBUTE the information provided by the SILOC reports in any way and it is necessary to delete the data and documents obtained from your storage systems upon expiry of the validity of the report.
If the agency wishes to terminate the relationship with a property owner it is required to notify IF S.R.L. to take the necessary precautions for the continuation of the object of our database. In the event of termination of the agreement by the agency, all participants in the database will be managed to ensure the continued use of SILOC (database).
The agent acknowledges that in the event of unauthorized transfer of the service and anything connected to it, he assumes all criminal liability and consequent immediate termination of the service without the possibility of requesting reimbursement for amounts already invoiced.
The agency also undertakes towards the owner to promptly insert the report of non-payment of rent as soon as communication is received.
The membership contract is considered to be tacitly renewed only and exclusively in the case of monthly payments for 12 months. It is not necessary to cancel in case of payment of the annual agreement if the payment was made with a lump sum payment or with payment in 3 KLARNA installments.
5. OWNER'S OBLIGATIONS
The owner therefore undertakes to communicate the report regarding the unpaid fees no later than 60 days from the first non-payment through the trusted real estate agent.
The owner therefore acknowledges that it will not be possible in any way to report unpaid monthly payments beyond 90 days and that if the driver proves that he has paid the monthly payment subject to the report within the regular deadline, the report will not be inserted or in any case obscured in the event of a report. occurred; furthermore, if this were to happen more than 3 times, the possibility of reporting the tenant will be revoked by contract.
6. SERVICES AVAILABLE TO THE OWNER AND TENANT
In the event of a delay/unpaid rent regularly reported to IF SRL/SILOC, the tenant information service will be automatically activated and 2 phone calls will be made to communicate the imminent report and the reported report.
Furthermore, the owner can at any time request to info@siloc.it to be transferred to another authorized agency.
The owner can request to use the rental contract registration service of IF S.R.L. at the Revenue Agency directly at the affiliated agency (The service exclusively involves the first registration and subsequent obligations).
7. RIGHTS OF THE TENANT
The tenant can at any time request the existence of negative reports on the rental at that current moment to ordini@siloc.it.
To obtain a detailed report it will be necessary to request the MYSiLOC service from IF S.R.L.
The driver exempts SILOC therefore IF S.R.L. from any responsibility for data incorrectly communicated by himself or the owner and agency.
The driver therefore renounces taking action against IF S.R.L. about the data communicated incorrectly by third parties and the reports resulting from the latter.
8. DISPUTES AND JURISDICTION
This Agreement and any dispute arising from it, connected to the latter or related in any way to the Service ("dispute") will be governed by Italian law and the Court of Turin with reference to each topic, including, by way of example, the validity, interpretation and execution of the Contract.
9. PAYMENT TERMS
The agency is required to pay in the times and ways set out in the agreement contract. In case of non-payment after 15 days from the expiry of the 1st unpaid invoice or extension installment, the service will be suspended and the owners and tenants active on that date and activated in the past will be notified of the suspension of the agency's authorization.
Furthermore, the suspension procedure will be activated on the SITE in the section dedicated to professionals active as an agency "SUSPENDED" for 6 months and then cancelled.
The tenants and owners have no payment obligations towards SILOC – IF S.R.L.
10. RESOLUTION
Either party may terminate these Terms and end the cooperation. In the event of termination of the contract with deferred payment, it will be the customer's duty to pay the remaining amount in full.
11.CONFIDENTIALITY
The report provided by IF S.R.L. it is valid for 30 days and the data provided are available to the agency and the owner; any dissemination of the report is strictly prohibited.
12.QUESTIONS AND COMPLAINTS
In case of questions or complaints, contact info@siloc.it.
13. LIMITATION OF LIABILITY
THE SITE AND ALL CONTENT, PRODUCTS, FEATURES AND SERVICES AVAILABLE ON OR THROUGH THE SAME ARE PROVIDED “AS IS”, WITHOUT ANY WARRANTIES, EXPRESS OR IMPLIED. THE USER USES SILOC - IF S.R.L. AND THE SERVICE IS AT YOUR SOLE RISK. IF S.R.L., ITS AFFILIATES AND THEIR RESPECTIVE THIRD PARTY LICENSORS EXPRESSLY WAIVE, TO THE FULLEST EXTENT PERMITTED BY LAW, ALL WARRANTIES, WHETHER EXPRESS, IMPLIED, STATUTORY OR OTHERWISE, INCLUDING, WITHOUT LIMITATION, WARRANTIES OF MERCHANTABILITY, FITNESS À FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT OF THIRD PARTY PROPRIETARY RIGHTS, TITLE, QUALITY OF SERVICE AND THE WARRANTY THAT THE SITE AND THE SERVICES PROVIDED WILL ALWAYS BE SECURE OR FREE FROM INTERRUPTIONS AND ERRORS. IF S.R.L., ITS AFFILIATES AND THEIR RESPECTIVE THIRD PARTY LICENSORS DISCLAIM ALL WARRANTIES REGARDING THE SECURITY, RELIABILITY, TIMELINESS AND OPERATION OF THE SITE AND ALL CONTENT, PRODUCTS, FUNCTIONS AND SERVICES AVAILABLE ON OR THROUGH THE SITE.
YOU UNDERSTAND AND AGREE THAT YOU DOWNLOAD OR OTHERWISE OBTAIN ANY MATERIAL OR DATA THROUGH THE USE OF THE SITE AT YOUR OWN DISCRETION AND RISK AND THAT YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOADING OR OBTAINMENT OF ANY MATERIAL OR DATA.
IN NO EVENT WILL IF S.R.L., ITS AFFILIATES OR THEIR RESPECTIVE THIRD PARTY LICENSORS BE LIABLE TO USERS REGARDING THEIR USE, EVEN INCORRECT, OF THE SITE AND/OR THE SERVICE OR THEIR RELIANCE ON THE SAME. THIS LIMITATION OF LIABILITY APPLIES TO AVOID THE RECOVERY OF INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY AND PUNITIVE DAMAGES, REGARDLESS OF WHETHER THE CLAIM IS BASED ON WARRANTY, CONTRACTUAL LIABILITY, TORT (INCLUDING NEGLIGENCE), INDEMNITY OR OTHERWISE, EVEN IF IFS.R.L., ITS AFFILIATES, OR THEIR RESPECTIVE THIRD PARTY LICENSORS AWARE OF THE LIKELIHOOD OF SUCH DAMAGES, AND NOTWITHSTANDING ANY FAILURE OF ESSENTIAL PURPOSE OF ANY REMEDY. THIS LIMITATION OF LIABILITY APPLIES IN THE CASE OF DAMAGES RESULTING FROM USE, EVEN IMPROPER, OF THE SITE AND FROM RELIANCE ON IT AS WELL AS TO DAMAGES CAUSED BY INFORMATION PUBLISHED ON THE SITE AND FROM REPORTS RESULTING FROM THE DATA PRESENT IN THE DATABASE, FROM THE INABILITY TO USE THE SITE /SERVICE OR THOSE RESULTING FROM THE INTERRUPTION, SUSPENSION OR FAILURE OF THE SITE (INCLUDING DAMAGES SUFFERED BY THIRD PARTIES). THIS LIMITATION ALSO APPLIES WITH RESPECT TO DAMAGES INCURRED IN RESPECT OF OTHER SERVICES OR GOODS RECEIVED THROUGH THE SITE OR ADVERTISED ON IT OR RECEIVED THROUGH LINKS MADE AVAILABLE ON THE SITE. THIS LIMITATION ALSO APPLIES TO THE COSTS OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, LOST REVENUES OR LOSS OF DATA, AND THE PERFORMANCE OR NON-PERFORMANCE OF THE SITE OR INFORMATION OR MERCHANDISE APPEARING ON OR IN ANY MANNER LINKED OR RELATED TO THE SITE . THIS LIMITATION SHALL APPLY NOTWITHSTANDING THE FAILURE OF ESSENTIAL PURPOSE OF ANY LIMITED REMEDIES AND TO THE MAXIMUM EXTENT PERMITTED BY LAW. TO THE EXTENT PERMITTED BY LAW, THE MAXIMUM AGGREGATE LIABILITY OF IF S.R.L., ITS AFFILIATES AND THEIR RESPECTIVE THIRD PARTY LICENSORS FOR ALL DAMAGES, LOSSES AND CAUSES OF LEGAL ACTION, WHETHER FOR BREACH OF CONTRACT OR TORT INCLUDED) OR FOR OTHER REASON, IT WILL BE LIMITED TO THE AMOUNT THAT THE USER HAS PAID TO IF S.R.L. FOR THE USE OF THE SITE/SERVICE.
14. RESERVATION OF RIGHTS
You acknowledge and acknowledge that IF S.R.L., its affiliates or their respective licensors own all right, title and interest in and to the Site/Service and all property rights associated therewith. IF S.R.L. reserves any other rights not expressly granted herein. You may not alter any copyright notices, proprietary notices, trademark and service mark attributions, patent markings, or other proprietary notices on materials accessible through the Site/Service other than Your Content . Any use of content or descriptions, any derivative use of the Site or its content, or the use of data mining, robots, or similar data gathering and extraction tools is strictly prohibited. Under no circumstances is it permitted to frame parts of the Site or materials contained therein.
The content of the Site and the information provided through the REPORT is provided with “restricted rights”. Use, duplication or disclosure is subject to limitations established by applicable laws and regulations.
Cookie Policy
Data processing contract
Addendum on data processing from owner to data controller
This Data Processing Addendum (“Addendum“) between you and IF S.R.L., acting as data controller pursuant to applicable data protection law, forms an integral part of the Terms of Service of IF S.R.L. - SILOC and finds application exclusively in limited situations in which IF S.R.L. acts as data controller of customer personal data on your behalf (as data controller).
The user (or "customer") and IF S.R.L. are referred to, jointly, as Parties” and, individually, as “Party.”
1. DEFINITIONS
Terms and expressions used but not defined in this Addendum will have the same meaning given to them in the GDPR, unless otherwise specified in this document. Where applicable data protection law gives such terms and expressions a different meaning to the GDPR, such different meaning will apply for the purposes of compliance with such applicable data protection law. The following definitions apply to this Addendum unless otherwise specified herein.
Affiliate means any entity that, directly or indirectly, controls IF S.R.L., is controlled by it or is subject to a joint control regime with IF S.R.L.. For the purposes of this definition,
“control” means the direct or indirect ownership or control of more than 50% of the voting interests of the controlled entity.
Applicable data protection law means any laws, regulations and other legal requirements relating to the following: (i) privacy, data security, consumer protection, text messages, emails and other promotional and marketing; (ii) use, collection, storage, storage, security, disclosure, transfer, deletion and other processing of personal data applicable to the processing of customer personal data under the Agreement, including, without limitation, the General Data Protection Regulation 2016/679 (“GDPR”), the Federal Data Protection Act of 19 June 1992 (Switzerland), the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), as well as any binding guidelines and/or codes of conduct issued by a competent supervisory authority under applicable law (as defined in the GDPR) or by the European Data Protection Board.
Business Contact Information means the names, postal and email addresses, and telephone numbers of the other Party's employees, officers, suppliers, agents and customers, maintained by a Party for business purposes as further described herein. following.
Customer Personal Data means personal data owned or controlled by Customers and provided to IF
S.R.L. or to an affiliate or subcontractor of IF S.R.L. by the user or on behalf of the same so that they are processed through the use of the services pursuant to the Contract. Unless prohibited by applicable data protection law, customer personal data must not include anonymized, aggregated and/or compiled generically based information or data that does not name or identify a specific person.
The term consent includes all consents, permissions, communications and authorizations necessary for the purposes of processing or subsequent transfer by IF S.R.L. of customer personal data required for the performance of the services, including the transfer of customer personal data outside the country of origin and any following, as applicable, by employees or third parties; valid consents from relevant interested parties or communications to them; authorizations from supervisory authorities, employee representative bodies or other applicable third parties.
Data controller means the subject who, as a legal person, establishes, alone or with others, the purposes and means of the processing of personal data.
The terms and expressions concerned, treat (and derivatives thereof), and supervisory authority must be given the same meaning as in the GDPR, except where applicable data protection law provides for such terms and expressions different meanings compared to the GDPR; in such case, such terms and expressions will have the same meaning given to them under applicable data protection law for the purposes of compliance with such law.
IF S.R.L. indicates the subject IF S.R.L. that contracts with you under the Agreement together with all relevant affiliates.
Personal Data Breach means a confirmed and actual breach of security of Customer Personal Data resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, of such Customer Personal Data transmitted, stored or otherwise processed by a Party under the terms of this Agreement, as well as accidental or illicit access to the same.
Data controller means the person who processes personal data on behalf of the data controller. The definition of data controller includes, without limitation, a “business” as defined in the CCPA, a “service provider” as defined in the CCPA, and a “business operator that handles personal information” in light of the definition referred to in the APPI. For the purposes of this Addendum, this entity corresponds to IF S.R.L..
By standard contractual clauses, we mean the following: (i) where the GDPR applies, the contractual clauses attached to the Implementing Decision 2021/914 of the European Commission of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council (the “EU SSCs“); (ii) where the UK GDPR applies, the standard data protection clauses adopted under Article 46(2)(c) or (d) of the UK GDPR (the UK SSCs“) ; (iii) where the Federal Data Protection Law of Switzerland applies, the standard data protection clauses issued, approved or otherwise recognized by the Swiss Federal Data Protection and Information Commissioner (“FDPIC“) (the “Swiss SCCs“) By sub-processors, we mean the affiliates of IF S.R.L. and the third parties authorized, under the terms of this Addendum, to access customers' personal data and process them in order to provide part of the services. The sub-processors of data processing do not include employees, external collaborators and consultants of IF S.R.L..
Main Contract means the SILOC (IF S.R.L.) Terms of Service, available on , and other applicable contracts entered into by SILOC (IF S.R.L.) and the supplier in relation to the services.
By technical and organizational security measures, we mean measures aimed at protecting personal data from accidental or unlawful destruction or from accidental loss, alteration, disclosure or unauthorized access, in particular when the processing involves the transmission of data via a network, as well as from any other form of unlawful processing.
For the purposes of this Addendum, all references to the "user" or "customer" indicate the user, natural person or organization accessing this SILOC - IF S.R.L. Site/Service. as a real estate agent/agency or other "qualified professional" body and the data controller and owner of the personal data (based on the definition above).
2. Representations and warranties
2.1 Each Party represents and warrants that it will comply with the requirements of applicable data protection laws to the extent relevant to that party in relation to the processing of customer personal data.
2.2 Each Party represents and warrants that it has no reason to believe that data protection laws prevent it from providing any of the services.
2.3 The user declares and guarantees to IF S.R.L. That:
2.3.1 will comply with and perform all of its obligations under this Addendum in light of industry best practices;
2.3.2 you have no reason to believe that applicable data protection law prevents you from entering into this Addendum;
2.3.3 has all necessary authorizations that allow it to enter into this Addendum or legitimize it to do so, including, without limitation, instructions, communications, licenses and consents; such authorizations have been obtained, are in full force and effect and will remain valid and effective at all times during the existence of this Addendum;
2.3.4 will only provide lawful instructions for processing;
2.3.5 neither the execution and performance of this Addendum nor the fulfillment of any obligation under it constitutes a violation of any (a) law to which the Party is subject; (b) decision or provision by which the Party is bound; (c) deed of incorporation or other equivalent constitutional document; (d)other contract or instrument binding on the Party or its assets.
2.3 Before transmitting customers' personal data to IF S.R.L., the user is required to inform IF S.R.L. of any requirement relating thereto.
2.4 IF S.R.L. declares and guarantees to the user that:
2.4.1 will process customers' personal data (as established in Appendix A) exclusively in accordance with the user's instructions for processing, documented and with subsequent amendments (including as provided for in the Contract and this Addendum), except where otherwise provided by law;
2.4.2 has the corporate capacity and authority to fulfill its obligations under this Addendum;
2.4.3 will promptly inform the user if it believes that the processing instructions violate any applicable data protection law (it being understood that nothing herein obliges IF S.R.L. to provide legal or legal advice or to monitor applicable law in the matter Of
data protection as regards its application to the user).
2.5 Except where otherwise established in the Contract and in this Addendum, (i) IF S.R.L. is a service provider and/or processor with respect to your personal data and (ii) you are the owner/data controller or service provider/processor, as the case may be, of the data customers' personal data.
3. Disclosure and processing of customer personal data
3.1 The Parties recognize that, during the performance of the services and for the purposes of this Addendum and the Contract, (i) the user acts as data controller and (ii) IF S.R.L. acts as data controller, pursuant to applicable data protection law.
3.2 When providing or making available customers' personal data to IF S.R.L., the user must disclose or transmit only those necessary for IF S.R.L. can carry out the necessary services.
3.3 Following the expiry or termination of the provision of services relating to the processing of customers' personal data or at the user's request, IF S.R.L. will promptly and securely delete (or return to you) all customer personal data (including existing copies) and will ensure that
its sub-processors also act in this sense, except where otherwise provided for by current laws.
3.4 The entire staff of IF S.R.L., including subcontractors, authorized to process customer personal data will be subject to confidentiality obligations and/or an adequate confidentiality obligation required by law.
3.5 The user expressly acknowledges and accepts that, in the course of providing the services, IF S.R.L. may anonymize, aggregate and/or otherwise anonymize customer data (“anonymous data”) and subsequently use and/or disclose such anonymous data for research, benchmarking,
improvement of IF S.R.L.'s offer in general or for other commercial purposes permitted by applicable law on data protection, without prejudice to implementation by IF S.R.L. of technical safeguards and business processes designed to prevent accidental re-identification or disclosure of anonymous data.
4. Security measures
4.1 Each Party is required to implement adequate technical and organizational security measures aimed at protecting customers' personal data from unauthorized or unlawful processing, as well as from destruction, loss, alteration, damage or disclosure. The Parties agree as follows:
4.1.1 taking into account the evolving state of technological development, the costs of implementation and the nature, scope, context and purposes of the processing of customer personal data as well as the likelihood and severity of the risk to natural persons , the implementation of the security measures referred to in Appendix B and compliance with the same by IF S.R.L. (“technical and organizational security measures”) are sufficient to provide a level of security commensurate with the risk in relation to the processing of customers' personal data;
4.1.2 the technical and organizational security measures implemented pursuant to this Article 4 and Appendix B are subject to technical progress and development and IF S.R.L. periodically reviews and may update or modify them to ensure that the processing of customer personal data is done in light of this Addendum and in accordance with applicable data protection law.
4.2 Breach of personal data
If IF S.R.L. becomes aware of an actual or suspected breach of customer personal data,
will inform the user without unjustified delay. IF S.R.L. will provide you with information, assistance and cooperation and, given the nature of the services provided and the information available to you, will take commercially reasonable actions to: (i) investigate and mitigate the data breach
personal data and (ii) assist you in relation to your breach notification obligations under any applicable data protection law. The Parties agree to coordinate in good faith regarding the development of the content of any related public statement and any necessary communications to data subjects and/or the competent supervisory authority in relation to a personal data breach, provided that nothing in this article prevents the Parties from complying with their obligations under applicable data protection law.
5. Audits and inspections
Upon written request, IF S.R.L. will make available to the user the information reasonably necessary to demonstrate the compliance of IF S.R.L. its obligations under this Addendum and under applicable data protection law and will submit to an audit or inspection (no more than once per year) by you (or an auditor third party validly designated by the user) based on a mutually agreed process at least 90 (ninety) days before the start of the audit. The Parties agree that such audit or inspection will be conducted during normal hours
working in a period of time not exceeding 3 (three) working days and will not unreasonably interfere with the business activities of IF S.R.L.. It is solely up to the user to establish whether the services and security measures of IF S.R.L. set out in Appendix B meet your needs, including in relation to any data protection laws.
6. Requests from interested parties and supervisory authorities
In accordance with the law and given the nature of the services provided, IF S.R.L. undertakes to:
6.1 Provide you with such assistance as is reasonably necessary in relation to your obligations to comply with requests from data subjects to exercise their rights under applicable data protection law. IF S.R.L. will promptly inform you upon receipt of any request from a data subject to exercise his or her rights under applicable data protection law.
data regarding the personal data of customers. IF S.R.L. will not respond independently to such requests from the user's interested parties, except where otherwise provided by applicable law on the protection of personal data;
6.2 Inform the user of all requests or communications received from IF S.R.L. by a competent supervisory authority relating to the personal data of customers processed in relation to the provision of services and on the basis of this Addendum, except in the case in which IF S.R.L. is prohibited from doing so by law or by a supervisory authority. You are responsible for any communication or correspondence with the relevant supervisory authority in relation to your role as data controller of customer personal data under applicable data protection law and to the extent permitted by law.
7. Privacy impact assessments and prior consultation
In accordance with the law and in consideration of the nature of the services provided and the information available to IF
S.R.L. as well as to the extent that the user does not otherwise have access to the relevant information, IF S.R.L. will provide assistance to you as reasonably necessary in relation to your obligations to conduct privacy/data protection impact assessments relating to the processing of customer personal data in accordance with applicable data protection law.
8. Sub-processors
The user grants IF S.R.L. a general authorization to contact sub-processors; a list of existing sub-processors may be made available to the user upon request (to the extent that sub-processors are used). IF S.R.L. will stipulate with each sub-
data controller a contract that provides for the same data protection obligations imposed on IF S.R.L. pursuant to this Addendum. If a sub-processor fails to fulfill its obligations in relation to the protection of personal data under this contract, IF S.R.L. will be liable to you for the acts or omissions of its sub-processor to the same extent as if it were directly providing the relevant services under this Addendum. IF S.R.L. will inform the user in writing of any planned change to the list of authorized sub-processors or of any planned appointment of a new external sub-processor and the user is required to communicate in writing to IF S.R.L. promptly, and in any case within 10 working days, any reasonable opposition to such change/appointment. You acknowledge that the sub-processors are essential in order to provide the services and that if you object to their use by IF S.R.L., notwithstanding any contrary provision in the Contract, IF S.R.L. will have no obligation to provide the user with the services for which he uses this sub-
data controller. If your objection is based on anything other than the inability of the proposed sub-processor to comply with its agreed obligations in relation to data protection, any amendment requested by you will be at your expense. Any disagreement between the Parties will be resolved through the contractual dispute resolution procedure.
9. Use of Company Contact Information
Each Party agrees to the other's use of its business contact information for contract management, payment processing, service provision and business development purposes, including business development with partners, and other such purposes established by the Party's global privacy policies (copies of which will be made available upon request). For these purposes, and notwithstanding any other provision of the Agreement or this Addendum with respect to customer personal data generally, each Party will be deemed to be an independent data controller with respect to the other Party's business contact information and will have ability to transfer such information to any country where that Party's global organization operates.
10. Disclaimer
IF S.R.L. will not be responsible for any claim made by an interested party arising from, or related to, an act or omission of IF S.R.L. or its affiliates to the extent that IF S.R.L. has acted according to the user's instructions.
11. Applicable Terms
11.2 This Addendum constitutes the entire agreement between the Parties in relation to the relevant subject matter and excludes any previous declarations, agreements and statements.
11.3 for the avoidance of doubt and without prejudice to the rights of interested parties set out below, this Addendum and any other standard contractual clause (or other data transfer agreement) that the Parties or their affiliates may enter into in relation to the services provided pursuant to the Contract will be considered part of the same and the conditions of liability provided will apply to all claims arising therefrom.
11.4 In the event of ambiguity or conflict between the terms of this Addendum and those of the Agreement,
the terms of the Addendum will prevail. In the event of any ambiguity or conflict between the terms of this Addendum and those of the Standard Contractual Clauses, the terms of the Standard Contractual Clauses shall prevail. All other terms and conditions of the Contract remain unchanged and are in full force and effect.
12. Counterparties
This Addendum may be executed in two or more copies or duplicates (including by electronic signature), each of which will be deemed to be the original; jointly, they will constitute a single and identical instrument.
13. Divisibility
Each provision of this Addendum is separate and distinct from the others and if, at any time, any provision of this Addendum is or becomes illegal, invalid or unenforceable under the laws of any jurisdiction, this shall not repercussion or affect the legality , the validity or enforceability in that jurisdiction of any other provisions of this Addendum.
14. Communications and variation
Any notice, consent, request and other communications required or permitted to the Parties under this Addendum must be in writing. No modification of this Addendum will be effective unless made in writing and signed by both Parties.
15. Changes in law
In the event of (i) the entry into force of any new applicable data protection law, (ii) any amendment to an existing applicable data protection law (including generally accepted interpretations thereof), (iii) any interpretation of a new or existing applicable data protection law by you or (iv) any new or emerging serious cyber threat that, individually or jointly, requires a change in the way in which IF S.R.L. provides services to the user, the Parties must agree in writing how this will affect the provision of services by IF S.R.L. and make fair changes to the terms of the Agreement and the services in light of any modification procedure as may be agreed upon by the Parties.
16. Applicable law and jurisdiction
16.1 The jurisdiction of this Agreement will correspond to that of the main Agreement.
ATTACHED
STANDARD CONTRACTUAL CLAUSES
1. The standard contractual clauses of the data controller and data processor are available by writing to the address: info@siloc.it
2. For the purposes of stipulating the standard contractual clauses:
1. optional clause 7 does not apply;
2. the description of the transfer of personal data referred to in Appendix A of this Contract is to be considered inserted in place of Annex I of the standard contractual clauses;
3. Appendix B of this Contract is to be considered inserted in place of Annex II of the standard contractual clauses.
APPENDIX A
A. PARTS LIST
Data exporter(s)/customer:
First name:
Address:
Name, Position, Contact Details:
Relevant activities:
Roles:
Data importer:
First name:
IF SRLS
Address:
VIA GUGLIELMO MARCONI 16 10060 CASTAGNOLE PIEMONTE (TO)
Contact:
IF SRLS
ATTN: Data Protection Officer
VIA GUGLIELMO MARCONI 16 10060 CASTAGNOLE PIEMONTE (TO) ITALY
Relevant activities:
IF S.R.L. provides reports based on statistical data and data stored in its own database called SILOC where it collects and stores data on rental payments to help tenants rent out their properties more easily and helps tenants obtain rental properties more quickly .
Role:
data controller
B. DESCRIPTION OF THE TRANSFER
Categories of interested parties
The personal data transferred concern the following categories of interested parties: natural persons whose personal data are provided to IF S.R.L. through the Services by (or at the direction of) Customer, which may include, without limitation, Customer's or its affiliates' employees, contractors and end users.
Purpose of the transfer
The transfer takes place for the purposes described below. IF S.R.L. will exclusively process the customer's personal data as data controller for the following purposes and only when necessary and commensurate with the purpose of complying with the customer's instructions: provision and updating of the services as licensed, configured and used by the customer and by its users, including through the customer's use of IF S.R.L. settings, administrator controls or other features of the services; security and real-time monitoring of services; resolution of problems, bugs and errors; delivery to the customer
of the assistance requested, including the application of the knowledge obtained from the requests for assistance of the individual customer for the benefit of all IF S.R.L. customers, but only to the extent that such knowledge is made anonymous as provided for by the Contract and by this Appendix A which illustrates the object, nature, purpose and duration of the processing of personal data by the controller to the controller; any other documented instructions provided by the customer and recognized as such by IF S.R.L. for the purposes of this Addendum.
Categories of personal data
Depending on the services used by the user, the personal data transferred may mainly concern the following categories of data:
IF S.R.L. account information: data associated with the IF S.R.L. agreement end user, password, company name and customer preferences. This includes: unique IF S.R.L. user ID, social media login (optional) and display name.
Customer Authentication Data: This may include your username and password, except when using Single Sign On (SSO).
Tenant and tenant materials: data disclosed to tenants by potential tenants during the tenancy decision-making process. Such data may include data regarding work, income, family status and documents certifying these conditions (pay slips, identity documents or other documents requested from time to time for the aforementioned purpose)
Data relating to user satisfaction and feedback: this may include plain text ratings and feedback on how IF S.R.L. can improve its services.
Frequency of the transfer (for example, whether the data transfer is a one-time operation or occurs on an ongoing basis)
Special categories of personal data (if appropriate)
No special categories are required to use the services. Such special categories of data include, but are not limited to, personal data containing information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic or biometric data, data concerning the health or sexual orientation of the user. The extent to which such confidential data is sent is determined and controlled by the customer in its sole discretion.
Duration of treatment
The period of effectiveness of the Main Contract, except where otherwise provided by law.
Nature and object of the treatment
IF S.R.L. will process the customer's personal data in order to provide services to the customer in compliance with the Addendum.
Retention period (or, if it is not possible to establish it, criteria used to define this period)
The period of effectiveness indicated in the main Contract, except where otherwise provided by law.
C. COMPETENT SUPERVISORY AUTHORITY
Identify the competent supervisory authorities pursuant to clause 13 of the SCC:
The competent supervisory authority, pursuant to clause 13 of the EU SCC, must correspond to (i) the supervisory authority applicable to the data exporter in the relevant EEA country in which it is incorporated or, (ii) where
the data exporter is not incorporated in the EEA, the supervisory authority applicable to the EEA country where the European representative of the data exporter has been appointed pursuant to Article 27(1) of the GDPR or, (iii) if the data exporter is not required to appoint a representative, the supervisory authority
applicable to the EEA country in which the relevant data involved in the transfer is located.
APPENDIX B
TECHNICAL AND ORGANIZATIONAL SAFETY MEASURES
In compliance with the Contract, the data controller will adopt and maintain, in the context of the processing of personal data, adequate security measures (including technical and organisational) aimed at
protect against accidental or unlawful access, loss, alteration, disclosure or destruction of such data, in particular where processing involves transmission of data over a network, and against any other unlawful form of processing.
As part of the definition of the technical and organizational security measures envisaged by the Contract, the
data controller will take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risk of different levels of probability and severity for the rights and the freedoms of natural persons.
The data controller will implement the following specific security measures, as applicable:
relevant employees and external collaborators must be trained on technical and organizational security measures;
· personal data must be stored on secure servers and protected by a firewall;
· servers must be monitored using industry-standard network monitoring tools to detect potential security breaches;
· company systems and databases must be password protected;
· direct access to the network or via VPN must be limited to authorized devices;
· Two-factor authentication is required for VPN access;
· passwords must be hashed and salt encrypted and stored in a separate database;
· employee access authorizations must be separate and limited;
· Active and automated monitoring of critical access logs and anomaly detection is required;
· critical access logs must be retained according to applicable retention procedures;
· Pseudonymisation and encryption methods are required;
· systems are needed to promptly restore the availability and access to personal data in the event of physical or technical accident;
· processes are necessary for the regular execution of tests, analysis and evaluation of the effectiveness of technical and organizational measures in order to guarantee the safety of the processing.
Cookie Policy
Last updated: May 2, 2023
Using or accessing the websites of IF S.R.L. (the “Site”), the user accepts IF's use of cookies
S.R.L. as described below.
The brands governed by these Cookie Policy include: SILOC, IF S.R.L. (collectively “SITES/SERVICE” or “IF S.R.L.”).
Terms such as jobseeker, employer and personal data have the same meanings under the Privacy Policy.
1. Introduction: what is a cookie?
This Cookie Policy helps clarify the circumstances and reasons why cookies may be sent to visitors to the Sites. “Cookies” are text-only information that a website transfers to a user's hard drive or other data processing equipment. browsing the web for record keeping purposes. Cookies allow the Sites to store important information that allows the user to navigate more easily. Typically, a cookie contains the name of the domain from which it comes, the "lifetime" of the cookie and a unique number or other randomly generated value. Some cookies will be used on the Sites even if the user is not logged in to their account.
Session cookies are temporary information that remain in the cookie file of the user's browser until the user leaves the Site. Persistent cookies remain in the cookie file of the browser
of the user for a longer period (the duration depends on the useful period assigned to the specific cookie). IF S.R.L. uses session cookies to keep track of the total number of visitors to the Sites. IF S.R.L. may also use cookies to store the user's computer when they return to the Sites to personalize their experience. In these cases IF S.R.L. can associate personal data with a cookie file.
2. How IF S.R.L. uses cookies
IF S.R.L. uses cookies, web beacons and other similar technologies, also provided by third-party partners such as Google and Facebook, for service measurement, improving advertising targeting and marketing purposes. This happens through the Sites, when the user downloads or installs an IF S.R.L. app. and through some of the advertisements of IF S.R.L. on third-party websites.
These cookies, web beacons and other similar technologies allow IF S.R.L. to show its promotional material on other Internet sites visited by the user and to put him or her in contact with a greater number of customers and/or suppliers of statistical data essential to pursuing the object of IF S.R.L.'s activity. - SILOC. IF S.R.L. may also share information about user behavior on the Sites with third parties (including third-party website operators and/or social networking sites) to display targeted ads and other content personalized to the user.
Purposes
Like IF S.R.L. uses cookies
Analytical purposes: IF S.R.L. and its affiliates (as defined in Article 4.14 of the Regulations on
Privacy) use cookies to analyze user activity in order to improve the Sites and websites of IF S.R.L. affiliates. For example, IF S.R.L. may use cookies to identify aggregate patterns such as the average number of searches performed by users. IF S.R.L. may use these analyzes to understand how to improve the functionality of the Sites and the user experience.
Preferences and user experience: IF S.R.L. and its affiliates use cookies to collect certain information
on users, including browser type, server, preferred language and country setting, for the purpose of storing user preferences across the Sites to make their experience more convenient and uniform. For example, IF S.R.L. can store in a cookie the recent searches carried out by the user so that the latter, when he returns to visit the Sites, can repeat these searches in a simplified way or in order to provide suggestions on the information in the profile when the user registers or requests a service from IF S.R.L.
Furthermore, IF S.R.L. uses cookies to keep you logged in when you visit the Sites repeatedly. IF S.R.L. may also use your IP address to determine your geographic location at the city or postal code level in order to present the most relevant search results.
Measurement of services, better level of Target and Ads and marketing: IF S.R.L. uses cookies, web beacons and others
similar technologies from third-party partners, such as Google, for service measurement, improving ad targeting and marketing purposes. These operations are performed when the user visits the Sites. These cookies, web beacons and other similar technologies allow you to view IF S.R.L. promotional material. (which may include a particular service announcement available on the Sites) on other Internet sites visited by the user.
IF S.R.L.'s third-party advertising partners they can also use these technologies to identify the user's browsing interests over time and across different websites, and therefore offer targeted advertisements and other personalized content.
IF S.R.L. may also share information about your behavior on the Sites with third parties (including third-party website operators) in order to show targeted ads and other personalized content
The user has the right to object to the use based on legitimate interest of personal data for marketing purposes. To oppose the collection and use of
information for targeting ads or to exercise other rights, the user can follow the procedure described in article 10 of the Privacy Policy.
Referral tracking: IF S.R.L. uses cookies, web beacons and other similar technologies, including from
third-party partners, to associate the user's activity with the third-party website that referred the user to the Sites, or to associate the user's activity with the IF S.R.L. website. who referred you to a third-party site. Some of these third-party websites are partner websites that receive credit for the activity of users whose IF S.R.L. to the Sites or assign credit to IF S.R.L. for the activity of users referred to such third-party sites.
IF S.R.L. may, however, use these technologies to share limited information about user activity with employers, such as which users have viewed a particular job posting, Company Page, Hiring Event or other posting on the Sites, as well as the Site third-party website on which the user has interacted with a link to a job offer, a Company Page or a Hiring Event or other advertisements on the Sites. IF S.R.L. also uses cookies and the aforementioned technologies to associate the user's activity with the email campaign
who directed him to our Sites.
Security purposes: IF S.R.L. uses cookies to limit certain types of cyber attacks.
Purpose of testing, usability and performance improvement: IF S.R.L. uses cookies to ensure consistency
of the user experience when carrying out A/B tests on certain aspects of the Sites and for the purpose of improving the offering of its products. Furthermore, IF S.R.L. uses cookies to improve the
performance and reliability of the Sites.
Fraud and spam prevention: IF S.R.L. uses cookies during fraud analysis and investigations. Some of the
Cookie and device tracking activities are performed through third-party providers such as Sift Science, while in other cases IF
S.R.L. uses its own indices to identify activities related to specific cookies.
Compliance: IF S.R.L. uses cookies to anonymize traffic and activity data collected in connection
to the use of the Sites and can insert a cookie called Opta non Consent to memorize the consent status when the user interacts with the cookie banner.
3.Which cookies does IF S.R.L. use?
On each of the Sites, IF S.R.L. uses first and third party cookies differently in order to provide the user with its numerous products and services. If you use one of the sites listed in the table below, please follow the brand-specific links below to view the full list of cookies used on the Sites. All other visitors can view the list of third-party cookies parts in the second table below.
Brand: List of cookies
Currently not existing Currently non-existent
IF S.R.L. may allow third parties to use cookies on their Sites in order to improve and provide their services to the user. The use of these cookies may vary depending on the site and market. If your use of our Sites is not covered in the table above, please check your browser settings to obtain a list of all cookies stored on your device. The following list specifies all our third-party cookie provider partners in use on the date of entry into force of this Cookie Policy. For more information on the privacy practices adopted by these partners, visit their respective websites:
Third-party cookie providers Third Party Websites
Facebook https://www.facebook.com/
Instagram https://instagram.com/
Microsoft (Bing) https://ads.microsoft.com/
YouTube https://www.youtube.com/
Google (Ads) https://ads.google.com/
4. User control over the use of cookies by IF S.R.L.
The tables above may provide users with options regarding cookie settings in some markets. Other forms of control available to users include:
– Browser and device specific controls
The user's browser may provide the ability to block some cookies, such as third-party cookies. Some browsers also offer the ability to examine and manage individual cookies. IF S.R.L. encourages users to review their browser settings and documentation for more information on any control tools offered by their browser and how they work. By deleting a cookie used by IF S.R.L. from your device or browser. on our Sites, your browser or device is not set to block third-party cookies and the same cookie may be installed during a subsequent visit. Some third-party cookies are also an integral part of the services provided by IF S.R.L. on their Sites. By blocking third-party cookies, the user may not be able to use all the features available on the Sites.
5.Modification of the Cookie Policy
Check the words "Last updated" at the beginning of the Cookie Policy to find out the date of the last modification of the document. Any changes will come into force from the date indicated in the "Last updated" section indicated above. Your use of the Sites or your provision of information to IF
S.R.L. following the changes reported will be interpreted as the user's consent to the changes made to the Cookie Policy. If IF S.R.L. d must use the personal data acquired through the Site in a substantially different way from that indicated at the time of acquisition, must notify the user by email and/or by publishing a specific communication on the IF S.R.L. Site. during the 30 days preceding said use or by making use of other means to the extent provided by law.
Frequently asked questions relating to the treatment of privacy by IF S.R.L.
The Privacy Policy fully describes how IF S.R.L. processes user data. . For further information on the IF S.R.L. approach to privacy, contact IF S.R.L. to info@siloc.it
If you have any questions regarding the Privacy Policy, please send an email to info@siloc.it
UPDATE 02/05/2023
