This policy is written according to Art. 13 of EU Regulation 2016/679 (GDPR), under Art. 13 of the Italian d.lgs. n. 196/2003 (Codice in materia di protezione dei dati personali) to the user accessing the website and it concerns all personal data treated within the following.


Data Controller of the collected personal data is SmartUp Engineering s.r.l. (from now on: SMARTUP), which legal premise is located in Via del Rione Sirignano 7, 80121, Napoli (Italy), and he can be contacted at the email address privacy [at] smartup-engineering [dot] com


Personal data are collected when provided automatically or directly by the data subject.

Data directly provided by the data subject are all personal data that are provided to the Data Controller with any method, directly from the data subject. In particular, the following data are collected and processed:

  • Name
  • Email
  • Any other personal data released by the data subject

Data automatically collected are website navigation data. These data, even if not aimed to identify the user, may indirectly allow his/her identification, by means of processing with other data collected by the Data Controller. In particular:


Personal data are exclusively processed for the following purposes:

  • answer your requests by email, phone, or other method
  • only in case of specific content by the user, to enable specific services like marketing communications.

The conferral of the data listed in the section "Collected data" for the above stated purposes is mandatory to allow the user to access the service. For this reason, the consent is mandatory and the eventual refusal to the processing or the failure, inaccurate or partial conferment of the data could result in the impossibility of a correct delivery of the service.

The conferral of data for the purpose of sending newsletters for promotional, informative or research purposes is optional and the refusal to give the relative consent to the data processing will give rise to the impossibility to be updated about commercial initiatives and/or promotional campaigns, to receive offers or other promotional material and/or to send personalized offers to the user. SMARTUP does not provide any user information to third parties without the consent of the data subject, unless required by law.

SMARTUP doesn’t collect personal data for profiling the user nor make profit by selling, publishing, or processing personal data in any way. In any case, the dissemination and transfer of personal data outside the EU area is excluded.


The data subject may immediately withdraw his/her consent to receive of marketing communications, sending such request at the email address privacy [at] smartup-engineering [dot] com, or by clicking at the unsubscribe hyperlink that will be found at the footer of any marketing email received.


Personal data are processed electronically for the time necessary to comply to the purpose which they were collected, provided in any case the annual check of the stored data to erase those recognized as obsolete, except those archived under law terms.

Data processing is usually performed at SMARTUP legal or operative premises, by trained personnel or external collaborators designed as processors. The complete list of the personal data processors may be obtained by sending such request at the email address privacy [at] smartup-engineering [dot] com.

Data processing concerning website activities are supposed valid until unsubscription by the user or after 12 months from the last communication with evident direct interaction (click, answer, and so on).

Collected personal data will be stored on local hard drive, in an electronic file protected by password and/or cryptography to avoid illicit uses and unauthorized access. Such file may be archived as backup on a cloud system, with the same level of protection, to avoid data loss. Any other data provided by the user as external files or physical document, as well as any item delivered to SMARTUP, may be subject to a non-disclosure agreement by the parts.


Under Art. 13 of EU Regulation 2016/679 (GDPR) and under Art. 7 of the Italian d.lgs. n. 196/2003 (Codice in materia di protezione dei dati personali), the data subject has the right to obtain confirmation of the eventual existence of his/her personal data, even if not yet collected, and their statement in intelligible form.

In detail, the data subject has the right to obtain from SMARTUP:

  1. the source of the personal data;
  2. the purposes and methods of data processing;
  3. the logic applied in case of processing performed with electronic/informatic tools;
  4. the identification of data collector, data processors, and eventual designated representatives;
  5. the subjects and categories of persons to whom the data may be communicated or which may be known to it as a designated representative in the territory of the State, of persons responsible or appointees.

Moreover, the data subject has the right to obtain from SMARTUP:

  1. the update, the rectification, or the integration of his/her data;
  2. the cancellation, the pseudonymization or the blocking of the data processed in violation of the law;
  3. the access his/her data and the confirmation of data processing;
  4. the limitation of treatment,
  5. the data portability, i.e. the right to receive in structured format the personal information concerning him/her;
  6. the right of complaint to the supervisory authority.

Finally, the data subject has the right to oppose, in whole or in part, for legitimate reasons to the processing of personal data concerning him/her, even if relevant to the purpose of the collection. In particular, the data subject has the right to oppose the processing of personal data relating to him/her for the purposes of sending commercial or direct selling advertising material or for the completion of market research or commercial communication. The requests referred to the preceding points must be sent by email to the address privacy [at] smartup-engineering [dot] com.


The SMARTUP website uses cookies, as almost all websites do, to help provide you with the best navigation experience. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Our cookies help us:

  • Make our website work as you would expect
  • Save you having to login every time you visit the site
  • Remember your settings during and between visits
  • Improve the speed/security of the site

We do not use cookies to:

  • Collect any personally identifiable information (without your express permission)
  • Collect any sensitive information (without your express permission)
  • Pass data to advertising networks
  • Pass personally identifiable data to third parties
  • Pay sales commissions

If the settings on the software that you are using to view this website (your browser) are adjusted to accept cookies we take this, and your continued use of our website, to mean that you are fine with this. Should you wish to remove or not use cookies from our site you may consult the documentation of your browser, however doing so will likely mean that our site will not work as you would expect.

This website makes use of technical cookies to:

  • determine if you are logged in or not;
  • remember if you have accepted our terms and conditions.

There is no way to prevent these cookies being set other than to not use our site. Some of these cookies are erased at the closure of the web browser (session cookies), other have a longer duration (as the cookie necessary to provide cookie consent and privacy policy, which lasts 12 months). By clicking OK on the banner shown on the first access or by navigating the website, the user explicitly consents to the use of cookies and similar technologies, in particular on the storing of such cookies on his terminal for the above stated purposes.

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of this website. It may be that you concern around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive. Learn more about managing cookies with antispyware software.


SMARTUP reserves the right to modify, supplement or update this information periodically in accordance with applicable law (GDPR) or the measures adopted by the Italian Garante per la Protezione dei dati personali.

The above modifications or additions will be brought to the attention of the interested parties by means of links to the Privacy Policy page on the website and will be communicated directly to the interested parties by email. We invite users to review the Privacy Policy regularly, to verify the updated information and decide whether to continue to use the offered services.