We undertake to safeguard your privacy and protect the personal data you entrust to us, in accordance with the principles of transparency – correctness – fairness.


New Information on Privacy and the Protection of Personal Data

Drafted in compliance with arts. 13 and 14 of EU Regulation 679/2016 (GDPR) and in re-placement of the previous Information provided pursuant to art. 13 of Legislative Decree no. 196/2003, the Italian Data Protection Act

 ,This information is inspired by the principle of transparency , as provided for in art. 12 of the European Regulation on the protection of personal data. It is there-fore designedtobe concise, transparent, intelligible and easily accessible, so that the content is ” comprehensible ” to all the subjects it is aimed at, and with particular attention to cases in which it is aimed at subjects under the age of 18 ”.


Why are you reading this information?

Personal data


are extremely valuable these days, so the new EU Regulation establishes that information not only has a key role to play, but must also be dynamic, subject to change and updated constantly to guarantee data subjects correct, timely information regarding the processing of their personal data.

Maximum attention must be paid, but we should have NO FEAR, because personal data must be able to circulate as widely aspossible,in complete safety and security: this is in EVERYONE’s in-terest!

In order to effectively contextualise this information, it should be noted that the use of any type of communication network,withoutexception – including the cellphone or cable network – is a process that leaves traces that extend far beyond the scope of the data processed by 4life.health Ltd. l., the object of this document. These traces are spread through the device used and throughout the systems of the networks involved, and in certain cases are also simple to intercept on the partofexternal systems. Therefore, connection to a network, such as Internet in particular, must never be considered asa “private”action in any of its aspects, regardless of the activities of Sweet Ice.

4life.health Ltd. collects different data depending on the type of location and client

The analyses performed by 4life.health Ltd.  focus on data stored during registration to the service and location data from the use of the platform from devices, including third party mobile devices


Internet browsing

4life.health Ltd.  services are based on the collection of non-mandatory data. Potentially the data provided when activating the service, or subsequently, may include:


Object of the Information

The information provided here regards your personal data

– both those collected up to now and those that will be acquired in the future in relation to the con-tractual relationshipsenteredinto processed

The Data Controller and Data Protection Officer is:

Dott. Ing. Adamo Musella Via Leonardo Da Vinci, 61 – 20099 Sesto San Giovanni 

mobile: +39.349.29.61.663 

e-mail: musad@inwind.it

pec  adamo.musella@ingpec.eu

C.F: MSLDMA70H04H114R P.IVA: 02410010066

An updated list of Data Processors (if appointed) is available at the address indicated above.


Purposes of the processing of personal data.

Please note that the data you provide, personally or by filling in and electronically sending the forms presented during the provision of our services, will be processed for institutional purposes, purposes connected with or instrumental to our activity and in compliance with legal obligations. Specifically, data are processed for the following purposes:

  1. Provision of services requested by the user and specific to the business activity of 4life.health Ltd.  including non-continuative user location as a consequence of specific events, such as visits to websites linked to the platform.

  2. To exercise the rights of the Data Controller, for example the right to defend their case in court.

  3. Direct and indirect marketing and market research, sending of advertising material; in this case, specific consent will be explicitly requested.

  4. Sending of notifications for specific events, in particular linked to the opening of websites relating to the platform.


Information we collect from third parties

In certain cases, 4life.health Ltd.  platform may interface with external data sources to complete the actions provided for in the services in question, profiling and to apply the appropriate policies to each device. In these cases, data have been collected by other bodies, so you could consult the information they provide.

Methods of processing

The data you provide us with will be processed with the aid of the appropriate electronic tools and by software platforms, equipped to guarantee security and confidentiality, for reasons strictly connected to the purposes of processing; any changes to or destruction of data, and prevention to avoid unauthorized changes or destruction, are managed by the same infrastructure, in ways always strictly connected with the purposes of processing. All location information is provided in real time, in accordance with one of the hallmark features. Data are therefore used instantly

Place of processing

The data collected are processed on the company premises and in a data centre


separate from the company premises, in the cloud managed by a third-party provider and on machines in operation at third-party clients who manage the structure where the service is provided. Operations for the maintenance and development of the Lumen platform are carried out from the operating offices of the company.

Communication and Dissemination

4life.health Ltd.  – the Data Controller undertakes not to divulge personal data to third parties, except, in certain cases, to our client, who manages the structure where our platform is activated, in order to offer the services provided for.

Storage of Data (or Storage Mechanism)

Personal data will be stored


using the methods indicated above, for the minimum period of time provided for by law or by contract. At the end of your contractual relationship with 4life.health Ltd.  your data will be stored for the length of time strictly necessary for and instrumental to their future use if contemplated by law and connected with the specific service requested by the client.

Instead of being erased, data may still be stored, but will be anonymised.

Provision of Personal Data

It is not mandatory to provide your data. However, failure to provide the data requested will make it impossible to establish or continue a relationship and, in certain cases, make it technically impossible to provide the specific service provided by the 4life.health platform.

The processing of data instrumental to complying with these obligations is necessary to properly manage the relationship, and it is mandatory to provide them for the purposes indicated above. The Data Controller wishes to inform you that failure to accurately provide any of the mandatory information may make it impossible for the Data Controller to guarantee the processing is carried out properly.


The aim of the points below is to draw your attention to a series of rights the regulation governing privacy and the protection of personal data has established in order to effectively safeguard your personal data.

Pursuant to article 7 of the Italian Data Protection Act (as far as it remains compatible), and pursuant to articles 13, para. 2, letters (b) and (d), and articles 15- 22 of the Regulation, data subjects are herewith informed that when they entrust their personal data to 4life.health Ltd. they may exercise the following rights, free of charge and without any formal restrictions:

Access to, rectification and/or erasure of personal data (right to be forgotten)

This is the right to request from 4life.health Ltd.   in its capacity as Data Controller, access to



or erasure

of personal data or restrictions on the processing

of personal data regarding the data subject, or to object to the processing

therefore, in the cases contemplated.

Right to data portability (art. 20)

The user has the right to request complete documentation


regarding the processing of his or her personal data provided to 4life.health Ltd. in its capacity as Data Controller. In other words, if the data subject intends to request the services of a “manager” other than Guglielmo S.r.l., he or she has the right to request, and to obtain all the personal data previously provided.

Right to object art. 21

Right to withdraw consent and lodge a complaint

The data subject has the right to withdraw the consent given at any time. This operation must be as easy as giving consent for the processing of data. At the same time, the data subject has the right to lodge an official complaint with the Data Protection Supervisory Authority, following the procedures and indications published on the official website of the Authority: www.garanteprivacy.it

The aforementioned rights may be exercised by sending a request by email to info@4life.health

For further information, consult the indications of the Data Protection Supervisory Authority, available at this link:



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Sweet Ice Co., Ltd.

399 Patak Road. 83130 Phuket – TH


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