Art. 13 Code regarding the protection of personal data
Legislative Decree 30 June 2003 n. 196 (hereinafter, the "Privacy Code")
and art. 13 EU Regulation no. 2016/679 (hereinafter "GDPR")it

1. Data processing carried out through the website
Pursuant to the Code regarding the protection of personal data, Legislative Decree 30 June 2003, n. 196 (so-called "Privacy Code") and art. 13 EU Regulation no. 2016/679 (hereinafter "GDPR"), the data processing is based on the principles of correctness, lawfulness, transparency and protection of confidentiality.
This information, made pursuant to art. 13 "Privacy Code" and "GDPR", concerns the processing of personal data carried out by COMHAS S.r.l. (hereinafter also COMHAS) through the website (hereinafter also the Site).
When accessing the site, the navigator can view the information in the appropriate section, accessible from the home page at the URL: During user registration, the information is also provided before sending personal data, in the appropriate box.

2. Holder of the treatment
The data controller is COMHAS, with registered office in Cinisello Balsamo (Milan), CAP 20092, at Via Matteotti 66 (Telephone 02.61298551, fax 02.66594921).

3. Information collected automatically
COMHAS is committed to protecting the privacy of visitors and users of its Site.
During their normal operation, the IT systems and software procedures used to operate the Site acquire some personal data whose transmission is implicit in the use of Internet communication protocols.
This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the addresses in URI (Uniform Resource Identifier) ​​notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's IT environment.
These data are used for the sole purpose of obtaining anonymous information on the use of the site and to check its correct functioning. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.
During the navigation and use of e-commerce services, no cookies are generated.
For the management of the Site, and in particular of the orders, some information is stored on the server used by the company that manages the administration of the site (Comhas S.r.l.). This information, necessary for the purchase procedures and for the security of transactions, relates to the browsing sessions of users who have accessed their profile.

4. Purpose of the treatment

Your personal data are processed:

A) without your express consent (art.24 letter a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes: - to conclude contracts for the services of the Owner;

- fulfill the pre-contractual, contractual and tax obligations deriving from existing relationships with you;
- fulfill the obligations established by law, by a regulation, by EU legislation or by an order of the Authority (such as for example in the matter of anti-money laundering);
- exercise the rights of the owner, for example the right to defense in court;

B) Only with your specific and distinct consent (Articles 23 and 130 of the Privacy Code and Article 7 of the GDPR), for the following Marketing Purposes:

- send you by e-mail, post and / or sms and / or telephone contacts, newsletters, commercial communications and / or advertising material on products or services offered by the Owner and detection of the degree of satisfaction with the quality of services;
- send you by e-mail, post and / or sms and / or telephone contacts commercial and / or promotional communications of third parties (for example, business partners, insurance companies, other companies of the Card Protection Plan Group).

We would like to point out to you that if you are already our customer, we will be able to send you commercial communications relating to the owner's services and products similar to those you have already used, except for your dissent (Article 130 c. 4 of the Privacy Code).

5. Optional supply of data

The provision of data for the purposes referred to in art. 4.A) is mandatory. In their absence, we cannot guarantee the services of art. 4.A).

The provision of data for the purposes referred to in art. 4.B) is instead optional. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Data Controller. However, you will continue to be entitled to the services referred to in art. 4.A).

In particular, the failure to provide personal data, for the purposes referred to in art. 4.A), indicated as mandatory in the registration form, makes it impossible to activate the user profile and therefore proceed to purchase online.

6. Processing methods

The processing of your personal data is carried out by means of the operations indicated in art. 4 Privacy Code and art. 4 no. 2) GDPR and precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electronic and / or automated processing.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the Service Purpose relationship for Marketing Purposes.

7. Security

Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):

- to employees and collaborators of the Data Controller or of the companies of the Card Protection Plan Group in Italy and abroad, in their capacity as persons in charge and / or internal data processors and / or system administrators;
- to third-party companies or other subjects (as an indication, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) who carry out outsourcing activities on behalf of the Owner, in their capacity as external managers of the treatment.

The online payment procedure is managed by NEXI-XPay through its servers through SSL security protocol, Verified by Visa / MasterCard SecureCode.

8. User rights (art. 7 "Privacy code")

In your capacity as an interested party, you have the rights referred to in art. 7 Privacy Code and art. 15 GDPR and precisely the rights of:

the. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;

ii. obtain the indication: a) of the origin of the personal data; b) the purposes and methods of treatment; c) the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the owner, of the managers and of the representative appointed pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents;

iii. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment occurs proves impossible or involves the use of means manifestly disproportionate to the protected right;

iv. object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail.
Please note that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition also only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication.

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

The interested party can address their requests to the Data Controller, by sending the communication by email to or by ordinary mail to the following address:

Via Matteotti 66
20092 Cinisello Balsamo (MI)

The user subscribed to the newsletter of the Site may at any time request the cancellation of the subscription using the appropriate email address / link present in each issue of the newsletter.


9. Disclosure of data

Without the need for express consent (pursuant to art.24 lett. A), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies, Judicial Authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom communication is mandatory by law for the accomplishment of said purposes. These subjects will process the data in their capacity as independent data controllers.

Your information will not be disseminated.


10. Data transfer

Personal data are stored on servers located in Italy, within the European Union. In any case, it is understood that the Owner, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller ensures as of now that the transfer of non-EU data will take place in accordance with the applicable legal provisions, subject to stipulation of the standard contractual clauses provided by the European Commission.


11. Accuracy of the data collected
COMHAS may, on its own initiative or upon request, integrate, correct or delete any incomplete, inaccurate or obsolete personal data for the functioning of this Site.

12. Change
COMHAS can modify the data treatment criteria and procedures at any time, or change and modify the methods of accessing this Site or its content.
In these cases, COMHAS will promptly update the Privacy Policy, to be understood as known to users at the time of publication on the Site.

13. Link
This Policy refers to and applies to information collected through the Site. COMHAS is not responsible for the privacy policies on websites that may be reached via links from the Site.