Our privacy practices comply with applicable laws at the national level (Legislative Decree No. 196 of June 30, 2003) and at the EU level (EU Regulation 2016/679) regarding the protection of personal data.

All further details on the subject of data protection and the data protection notice for users with the status "BASIC" or "PREMIUM" can be viewed here:

SANUSLIFE explains on this page how it processes the data of users who visit its website and how the cookies installed on this website work.

This privacy policy is issued in accordance with Art. 13 GDPR 2016/679 (EU General Data Protection Regulation, Regulation of the European Union, which unifies the rules for the processing of personal data), Recommendation No. 2/2001 of the Working Group pursuant to Art. 29, and the general provision of the Data Protection Authority on cookies No. 229 of May 8, 2014.

The following information applies to this website as well as to all directly connected subdomains. The controller is not responsible for the data and cookies inserted or installed by third-party websites that may be consulted via links.

Information about the Controller

The controller is SANUSLIFE, with its registered office at Lindenstrasse 8, CH-6340 Baar. To exercise the rights provided by law, it is possible to contact the controller at its administrative office, by phone at +41 041 510 93 03, or in writing at [email protected].

Purpose and Legal Basis of Data Processing

SANUSLIFE processes the data that the user enters for the following purposes:

a. Requests for information, responses to contact inquiries, or support requests

The entry of the required data is necessary to process your request. The legal basis for the processing is, in accordance with Art. 6 para. 1 lit. b) GDPR, the fulfillment of a contract to which the data subject is a party, or the implementation of pre-contractual measures at the request of the data subject, as well as, in accordance with Art. 6 para. 1 lit. f), the processing for the purposes of the legitimate interests pursued by the controller or by a third party. The data processed based on your request will be retained for a period of six months.

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

The provision of the requested data is essential to create your account and thereby enable you to access our platform and use our services (these include, for example, access to our online community SANUSWORLD, use of the SANUSAPP services, as well as services related to the SANUSLIFE Marketplace and SANUSLIFE Finance). Furthermore, we need the data for processing related to the services (collecting SANUSCREDITS, using and accepting SANUSCOINS, participating in events organized by SANUSLIFE, attending courses at the SANUSACADEMY, etc.). As a registered user, you are also authorized to invite other people to register on the SANUSLIFE platform and use the services. The legal basis for the processing is, in accordance with Art. 6 para. 1 lit. b) GDPR, the fulfillment of a contract to which the data subject is a party, or the implementation of pre-contractual measures at the request of the data subject. The data processed in connection with the registration will be processed until you submit a request for deletion and deregistration.

c. Entering into a business relationship/partnership (COMPANY Partner)

The provision of the requested data is essential to examine your request regarding entering into a business relationship (partnership) and, if the examination is positive, to subsequently allow you to promote or market your products through the SANUSLIFE platform (e.g., by becoming a COMPANY Partner / NON-PROFIT Partner); entering into such a partnership means that SANUSLIFE processes the data regarding the purchases and sales of the business partner both for the purpose of fulfilling accounting and tax obligations and for all purposes related to the conduct of the business relationship. The legal basis for the processing is, in accordance with Art. 6 para. 1 lit. b) GDPR, the fulfillment of a contract to which the data subject is a party, or the implementation of pre-contractual measures at the request of the data subject. The data processed in connection with the registration will be retained until the termination of the business relationship.

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

The provision of data for this purpose is mandatory and the legal basis is the fulfillment of a legal obligation to which the controller is subject, as provided in Art. 6 para. 1 lit c) GDPR. For processing for this purpose, the user's consent is not necessary. Considering that every user of the SANUSLIFE services can accumulate, use, and accept SANUSCREDIT and SANUSCOIN, data processing also includes those processes triggered by these transactions. The data processed in this way will be retained for the period provided by the relevant provisions.

e. Statistical analyses of aggregated or anonymized data

This type of processing does not allow the identification of the user and is solely for the purpose of verifying the effectiveness of web marketing campaigns or checking the correct functioning of the site by monitoring access frequency. The processing of aggregated or anonymous data that does not allow the identification of users is not covered by data protection law and therefore does not require consent for its processing.

f. Newsletter and business communications (FREE User)

The provision of the required data for subscribing to our newsletter service or for receiving promotional communications or advertising material is voluntary, and the legal basis for the related data processing is the consent of the data subject. The data processed for advertising and marketing purposes will be retained by us until the consent is withdrawn, unless the consent is renewed. Excluded from the requirement to obtain voluntary and specific consent are those operations through which the user is informed about actions and news on the virtual bulletin board accessible through the reserved area.

Processing methods, automated decision-making processes, and data retention periods

Your data is processed electronically, although potential paper-based processing is not excluded. Automated decision-making processes are not used for the processing of your personal data. The data collected through cookies is stored for the periods specified by the individual cookies.

Disclosure of Data (Recipients)

To ensure the functionality of our site and the proper provision of content, we may use the services of third parties. These include, for example, IT service providers, hosting service providers, telecommunications companies, external legal or tax advisors, transport companies, authorities and other public institutions, business partners (COMPANY Partner / NON-PROFIT Partner), service providers in the field of cryptocurrencies, etc. We also inform you that, in addition to the aforementioned persons and institutions, users in your upline (meaning the chain of distributors that enabled your registration and, for example, the partner directly above you) can view the profiles of users directly connected to them. Furthermore, we may use the services of third parties (e.g., carriers) to fulfill the requested services, such as in connection with the purchase of products. The legal basis for the transmission is the fulfillment of legal and contractual obligations as well as the implementation of pre-contractual measures based on your request. In any case, only the data necessary for the fulfillment of the respective service will be disclosed. If the transmission of anonymized data is sufficient, only such data will be transmitted. The dissemination of your personal data will only take place with your express consent. You have the right to contact SANUSLIFE at any time to obtain a list of external persons and institutions that can view and process your data.

Regarding the use of third-party cookies, please refer to the section at the end of this document.

Transfer of Data to Third Countries and International Organizations

The data you provide will not be transferred to third countries or international organizations outside the European Union. Since this is an online platform, the data can be viewed in all countries of the world. The homepage is hosted within the European Union.

Rights of the Data Subject and Complaint to the Data Protection Authority

You have the right to exercise the rights granted to data subjects at any time. Please contact the controller (SANUSLIFE) using the contact details provided above. We will provide you with a written response within 30 days. Additionally, if you believe that your data has been processed unlawfully, you can file a complaint with the competent supervisory authority, the Italian Data Protection Authority (Garante per la Protezione dei dati Personali) based in Rome, Italy.

I. Right of Access by the Data Subject

1. The data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning them is being processed; if this is the case, they have the right to access this personal data and the following information:

a) the purposes of the processing;

b) the categories of personal data being processed;

c) the recipients or categories of recipients to whom the personal data has been or will be disclosed, particularly 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 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 existence of the right to lodge a complaint with a supervisory authority;

g) where the personal data is not collected from the data subject, any available information as to its 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 envisaged consequences of such processing for the data subject.

2. Where personal data is transferred to a third country or to an international organization, the data subject has 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 has the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them.

2. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.

III. Right to Erasure

1. The data subject has the right to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller has the obligation to erase personal data without undue delay where one of the following grounds applies:

a) the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

b) the data subject withdraws consent on which the processing is based according to Article 6(1)(a) or Article 9(2)(a), 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 has been unlawfully processed;

e) the personal data has 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 has 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 who 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, that 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 Article 9(2)(h) and (i) and Article 9(3);

d) or 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 has 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 its use instead;

c) the controller no longer needs the personal data for the purposes of the processing, but the data subject requires it for the establishment, exercise, or defense of legal claims; or

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 is lifted.

V. Right to Data Portability

1. The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format, and they 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 Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b); and

b) the processing is carried out by automated means.

2. In exercising their right to data portability pursuant to paragraph 1, the data subject has 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 has the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on Article 6(1)(e) or (f), 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 is processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing, which includes profiling to the extent that it is related to such direct marketing.

3. If 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 their right to object by automated means using technical specifications.

6. Where personal data is processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to their particular situation, shall have the right to object to processing of personal data concerning them, 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 has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

2. Paragraph 1 shall not apply if the decision:

a) is necessary for entering into, or performance of, a contract between the data subject and a data controller;

b) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or

c) is based on the data subject's explicit consent.

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

VIII. Sharing of Information

You hereby authorize us to share information about you, your account, and your account activities with law enforcement authorities, regulatory bodies, and government agencies. We also authorize you to share information about us and our acceptance services with law enforcement authorities, regulatory bodies, and government agencies.

COOKIES OF OUR WEBSITE

Navigation Data

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

This information is not collected to identify users, although this could be the case through associations and cross-processing with third-party data. From this data, statistical information about the use of the website and its functionality, as well as additional information for determining liabilities in case of computer crimes, is obtained.

What are cookies?

Cookies are small text files that websites visited by the user place on their device. These records are sent back to the website that placed them when the user visits again. If the user also receives cookies from other websites or web servers while navigating the website, these are called third-party cookies.

Cookies are placed for various reasons, including the ability to perform IT authentications, monitor navigation sessions, or select the language.

First- and Third-Party Cookies

The cookies placed directly by SANUSLIFE are "first-party cookies". In contrast, cookies placed and collected by a website other than the one the user is navigating are called "third-party cookies".

Third-party cookies include social buttons (or social plug-ins) that allow the website to interact with popular social media platforms like Facebook, Instagram, LinkedIn, Twitter, etc., or Google Analytics cookies and those necessary to implement YouTube frames, etc. Regarding third-party cookies, the third parties to whom these cookies refer are responsible for providing the privacy notice and information on managing the collected data.

Types of Cookies

Technical Cookies

Technical cookies are usually installed directly by the website operator and enable communication between the website and the user. These can be navigation or session cookies that ensure normal navigation and use of the website. They are typically stored for the duration of the navigation on the website. Additionally, there are functional cookies that allow better use of the website, such as those for selecting the website language, adding selected items to the shopping cart, etc.

Since these cookies are essential for the functioning of the website, no prior consent is required for their placement on the user's device.

Analysis Cookies

These are cookies that can collect information about users in more or less aggregated form, such as the number of users visiting the website or the modalities of website visits. One of the most well-known tools for creating these statistical reports is Google Analytics, a service of Google Inc.

Analysis cookies can be equated with technical cookies if the information is collected in aggregated form and there is no possibility of identifying the habits of individual users. Specifically regarding Google Analytics cookies, it is at least partially necessary to anonymize the IP address of the user visiting the website and eliminate the data sharing by Google. If such anonymization and prevention of data sharing are not possible, these cookies fall under profiling cookies.

Profiling Cookies

These cookies are used to record a user's preferences and present them with advertising messages based on the insights gained. These cookies are particularly invasive, and the user's consent must be obtained before they are placed on the user's device.

Banner on First Access

According to the provision of the Data Protection Authority dated May 8, 2014, when using cookies that are not technical cookies, a banner (so-called short notice) must be set up on the user's first access to the website, briefly summarizing how the website handles cookies and providing a reference to the extended privacy policy.

SANUSLIFE has set up the aforementioned banner. If the user clicks the "Accept" button, they accept the placement of cookies and can continue to use the website. Additionally, a special cookie has been provided to store the user's choice regarding the installation of cookies: This means that the user will only see the cookie once. If they wish to change their choice at a later time, they must follow the instructions under "Instructions for Disabling Cookies".

Overview of the cookies installed by SANUSLIFE:

Name / Designation of Cookie - Path - Duration - Function - Type of Cookie (technical cookie, analytics cookie, profiling cookie)

CAKEPHP     Sanuslife.com     Session     Cookie used for the current session     Technical cookie
REALM     Sanuslife.com     Session     Assignment of the server from which the current data is used.     Technical cookie (performance cookie)
_ga     Sanuslife.com     2 years     This cookie collects information that is used for analytical purposes in connection with the use of the website by users.     Analytics cookie
_gat     Sanuslife.com     1 minute     This cookie limits data collection when there are too many requests to a page. Some requests are blocked, and the results of this process can be extrapolated.     Analysecookie
_gid     Sanuslife.com     1 day     Registers a unique identifier through which statistical data about the use of the site by the user is generated.     Analytics 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

Instructions for disabling 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 policies of third-party providers that set cookies:

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

 

Details of the responsible party:

The responsible party is SANUSLIFE, with its registered office at Lindenstrasse 8, CH-6340 Baar. To exercise the rights provided for by law, it is possible to contact the responsible party at its administrative office, by phone at +41 041 510 93 03, or in writing at [email protected].