Privacy Policy

Information on the processing of personal data pursuant to Article 13 of Regulation (EU) 2016/679

This information is provided pursuant to Regulation (EU) 2016/679 (hereinafter "Regulation" or "GDPR") and describes the methods of processing personal data of users who consult and use this website, accessible at www.6enough.eu ("Site"). The Site is dedicated to online auctions owned by 6enough and therefore, does not concern other sites or external online services that may be accessible through links on the Site.


Following consultation of the Site, data relating to the user who accesses the site (defined as "interested" as an identified or identifiable natural person) may be processed. The data controller is Smartlabs Srl, with a registered office in via Monte Nevoso n.30/D, 00141, Rome, VAT number 14176861004, (e-mail: info@smartlabs.eu, PEC: pec@pec.smartlabs.eu) (hereinafter "Data Controller"). The Data Controller has appointed a Data Protection Officer (DPO), to whom you can contact to obtain more information on the processing of data or to exercise your rights, by contacting them, by mail, at the headquarters of the Data Controller, or by email, at the following address: dpo@smartlabs.eu, or by certified e-mail (PEC): pec@pec.smartlabs.eu.


  1. Navigation data

The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the navigation of the websites. This information is not collected to be associated with the identified interested parties; however, by their very nature they could, through processing and association with data held by third parties, allow users to be identified. These include the IP addresses or domain names of the computers used by users who connect to the site, the URL addresses of the requested resources, the time of the request, the method used to submit 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 and other parameters relating to the operating system and the platform used by the user. In this case, the provision of this data is mandatory, and the information is acquired independently in order to guarantee access and navigation on the Site. To ensure transparency for participation and registration in VSA auctions (VIP Solidarity Auctions) cookies are NOT issued and managed by the platform, in any of the types currently used. Therefore there are no further rules on cookies below. The above data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning; they are deleted immediately afterprocessing

  1. Data provided voluntarily by the user (registration, and use of online auction services offered by Smartlabs in collaboration with 6enough.eu – Section "VIP Solidarity Auctions-VSA")

To take advantage of the services offered by SMARTLABS S.r.l., registration on the site is mandatory and involves the acquisition of personal data, necessary to identify you: in particular, your name, surname, your email address will be acquired and secondly, the identification data of your credit card or your current account (but only if you use the online auction service). It should be noted that the provision of the data indicated on the registration page is always optional, however data marked as "mandatory" must be provided to be able to use the services and create your own personal page and, in case of refusal, the account cannot be created. Conversely, failure to provide the data marked as "optional" will not have any consequences for the registration and subsequent management of your requests. The data relating to credit cards are processed exclusively for the verification of the integrity of the data of the registrant and ensure they are of age. NO TRANSACTIONS, not even for payment reservation purposes, is carried out on cards whose data are entered by users. At the end of the immediate verification, the data entered relating to credit cards ARE NOT STORED anywhere on the computer system. The personal identity data thus provided will be used for the sole purpose of allowing your access to the reserved services of the Site, your participation in the online auctions announced by SMARTLABS S.r.l., and the management of any messages regarding the preparation of the online auction or to the technical managers of the platform; these will be communicated to third parties expressly authorized by the Data Controller only if this is necessary in order to respond to your requests or manage the measures.

  1. Data communicated by the user through contact forms on the Site

The optional, explicit and voluntary sending of communications by means of contact forms on the Site or by email to the addresses indicated on this Site, involves the subsequent acquisition of the data communicated by the user, including their email address, and consent to receive any response messages to their requests. In this case, the provision of your e-mail address and any other data indicated is optional, but essential to use the service and receive a response to your request and, in their absence, we will not be able to proceed with the processing. The personal data thus provided are used for the sole purpose of satisfying or responding to the requests transmitted and are communicated to third parties only if this is necessary for this purpose. The data is kept only for the period strictly necessary for the purpose of completing the request and in accordance with current legislation. In any case, at the end of the online auction, and the communication to the organizers of the winning participants of the lots, and the relative quotations, the data will be permanently deleted from the platform.


The legal basis is:

For paragraph B.1, Navigation data, the legitimate interest of the Data Controller to make the Site usable and safe to navigate. The express consent of the interested party is exclusively for the specific profiling activity;

For paragraphs B.2 and B.3, Data communicated by the user, for the provision of services requested by the interested party is therefore in fulfillment to the contractual obligation assumed by the Data Controller with the service (see the conditions and terms of the service, shown in the appropriate document available online).


Smartlabs Srl:

Navigation data is deleted (par.B.1) immediately after processing since such data is used only to obtain anonymous statistical 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: except for this eventuality, the data on web contacts do not persist for more than seven days;

Conserve Data provided voluntarily by the user, the Data communicated by the user through contact forms on the Site (par.B.2 and B.3) for the period necessary for the purpose of completing the request and on the basis of what is permitted by current legislation and any contractual obligations that may have arisen;

Conserve Data relating to the subscription to the Newsletter (par.B.5) by a user for the period in which this service is active (i.e. until the user revokes the consent that he has freely given).

For data relating to cookies, please note that the site does not use them, and does not install any file, either textual or with operating code on the devices of users who interface with the platform.


The personal data collected are processed by the Data Controller's staff, who act upon specific authorization, based on the specific instructions provided regarding the purposes and methods of the processing itself. In addition, the persons designated responsible for the processing pursuant to art. 28 of the GDPR, which the Data Controller uses for the provision of services and for the performance of the activities within its competence, may be recipients of the data collected following consultation of the Site or use of the services within the limits of their respective duties. The related list can be requested from the Data Controller or its DPO using the contact details referred to in section A.

In no case, however, is your data transferred outside the territory of the European Union. In particular, for the specific VSA auctions of present and upcoming organization, no personal data is shared with the software platform for the online auction, nor with the companies that manage it operationally and legally. The Auction on this platform takes place between anonymized users, whose identity is detected by Smartlabs on its systems based on the information already in its possession, and whose conservation is described in the previous par. D.


The interested parties – the identified or identifiable natural persons to whom the data refer – have the right to obtain from the Data Controller, in the presence of the requirements established by law, access to personal data and the correction or cancellation of the products or the limitation of the processing that concerns them, to oppose the processing carried out for marketing purposes and to revoke any consent issued; they also have the right to data portability (articles 15 and ss. of the GDPR). The right can be exercised by contacting the Data Controller or its DPO through the contact details indicated in section A.


Interested parties who believe that the processing of personal data relating to them carried out through this process takes place in violation of the provisions of the Regulation have the right to lodge a complaint with the Guarantor (as provided for in Article 77 of the Regulation), or to appeal to the appropriate judicial offices (as provided for in Article 79 of the Regulation).


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