Privacy Policy – “SPM Medica” Waiting List (Article 13 GDPR)

Version: 1.0 – October 5, 2025

Data Controller

SPM Sic Parvis Magna Srl
Via La Maddalena, 29 – 00012 Guidonia Montecelio (RM), Italy
Email: info@spmmedica.com

Purpose and Legal Basis

We process the data you enter in the form (name and surname, email, role, interest, and any message) to:

• Manage your subscription to our app’s waiting list and send you communications about the launch, demos/previews, and updates (legal basis: consent, Article 6.1.a GDPR).
• Aggregate statistical analysis of interest in the project, for the sole purpose of MVP validation (legal basis: legitimate interest of the Data Controller, Article 6.1.f GDPR).

Nature of the Provision

Providing the data marked as mandatory is necessary to register you on the waiting list. Failure to provide this data will prevent us from sending you updates or previews.

Processing Methods

The data is processed using IT tools and appropriate security measures. We do not use automated decision-making processes or profiling based solely on the MVP data collected.

Retention

We will retain your data until the end of the app launch phase or until you withdraw your consent (opt-out). Some technical logs may be retained longer due to legal obligations or legal protection.

Recipients and Transfers

We may use service providers (e.g., Google – Google Sheets / Google Apps Script; email) who act as data processors pursuant to Art. 28 of the GDPR. Data may be processed/received on infrastructures located in the EU or, if outside the EU, in countries that guarantee an adequate level of protection or with the EU Commission’s Standard Contractual Clauses. An updated list of providers is available upon request.

Data Subject Rights

You may at any time: access your data, request rectification or erasure, limit its processing, object to processing for legitimate reasons, and obtain data portability (Articles 15–22 GDPR). You also have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

How to Exercise Your Rights

Write to info@spmmedica.com, indicating “Privacy – SPM Medica Waiting List” in the subject line. You have the right to lodge a complaint with the Italian Data Protection Authority.

Data Protection Officer (DPO)

A Data Protection Officer (DPO) has not yet been appointed. If one is appointed, this policy will be updated accordingly.

Updates

We may modify this policy to reflect regulatory changes or service developments.