Privacy Policy – The Spiritual Machine

Website information

Data processing methods


1 – Reference law (new EU Regulation 2016/679)

THE SPIRITUAL MACHINE SRL, in line with Legislative Decree no. 196/2003 (hereinafter the “Privacy Code”) and the Regulation (EU) 2016/679 (hereafter “GDPR”), intends to guarantee the privacy and security of the personal data of each visitor in line with the provisions of this Information pursuant to art. 13 of the Privacy Code and articles 13 of the GDPR and updates the previous versions released before now.

This privacy policy applies exclusively to the online activities of the site is valid for visitors / users of the site and does not apply to information collected through different channels. In compliance with the obligations deriving from national and EU legislation on the protection of personal data, this site respects and protects the privacy of visitors and users.

The holder of the processing of personal data is:


Via Cigna 96/17 D

10155 Turin

VAT: 11820170014

2 – Sources and categories of data processed

Browsing data:

With each access of a user to the site and with every call of a file, the access data of this action is stored in a statistics file on the server of our provider.

For example, date, time, website URL, type of browser, language and version of the browser, operating system used, Internet Service Provider, IP address are detected.

We use the technologies indicated below on our website and we detect, process and eventually use additional data.

3 – Purpose of the treatment

Data provided by the user:

We use a limited amount of information that you have provided on a voluntary basis by filling out the contact form on the site (your name, your e-mail address and your areas of interest in the areas of neurology, psychiatry, neruhabilitation or others) for inform you via e-mail, for example, on The Spiritual Machine training courses. Or on other events, technological innovations, new products, congresses and information related to the neuroscience sector. Your data is treated confidentially and is not passed on to third parties.

Apart from that specified for navigation data, the user is free to provide personal data in order to access the services offered by this site. Failure to provide the data necessary for completing the application forms will make it impossible to access the requested services, including the sending of informative material.


As for the cookies processed by, please refer to the cookie policy

4 – IT assets

The navigation data are acquired by the computer systems and by the software procedures of this website for its normal operation. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning. Furthermore, they could be used to ascertain responsibility in case of hypothetical computer crimes against the site.

These data are collected on the basis of the explicit consent of the interested party, which consists of completing the specific request form. The data provided by the user will be used for the following purposes:

registration for access to services and / or content offered by this site;

sending newsletters related to the medical, training, technical comments or dissemination initiatives of THE SPIRITUAL MACHINE SRL;

carrying out market surveys and sending information material on the activities of our company by e-mail.

5 – Applications related to the use of the site.

For statistical site management

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses Personal Information collected for the purpose of evaluating the use of this site, compiling reports and sharing them with other services developed by Google.

Google may use the Personal Data to contextualise and personalize the advertisements of its advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out

Google Tag Manager (Google Inc.)

Google Tag Manager is a statistical service provided by Google Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy


6 – Right to non-profiling and deletion from the database.

With reference to the articles from 15 to 22 of EU Regulation 2016/679 the user has the right at any time it deems appropriate, through the address: to unsubscribe from the website web (right to be forgotten) in this meaning, the user is guaranteed that his data are no longer present in any company database.

7 – Processing methods

The processing will be done by manual, computerized and telematic tools with logic strictly related to the purposes for which they were collected in compliance with the purpose limitation principle as well as with all the other principles contained in Article 5 of Regulation 679/2016. In particular, in compliance with the principles of integrity and confidentiality, pursuant to which specific security measures are adopted to prevent the loss of data, illicit or incorrect use and unauthorized access. The data may also be disclosed to all parties to whom the communication is due on the basis of legal obligations. The list of subjects processing personal data is available by making a request to the e-mail address:


8 – Security measures.

Our computer system is equipped with a firewall through internet connection with Tiscali manager but if you consult other pages and data on our site and you are invited to enter personal data, we point out that this transmission of data through the Internet takes place in unsafe way and unauthorized parties can therefore become aware of the data or even falsify it.


9 – Countries and destination of data.

The data are managed by the Italian provider Host SPA and by Google Analytics (Google Inc.) located in the United States.


10 – Conservation period.

User data is retained by the owners for the period strictly necessary in compliance with applicable regulations.

In any case, the user will have the possibility to revoke, as described above, at any time his consent to the processing of data.

The data transmitted to any service providers will be processed by them for the time strictly necessary for the execution of the tasks entrusted to them.


11 – Categories concerned.

Indicate clearly which are the other structures / people that have the possibility to access the data acquired through the website (reference to the GDPR and to a list of the interested parties specified within the same).

They can access our site:

our employees;

the Libre S.C. with VAT number 09733080015 and registered office in via Beaumont 19, which deals with the technical management of the website;

Mailchimp for sending newsletters.

11 – Rights of the interested parties

Users (interested in processing) have a series of rights in accordance with Regulation (EU) 2016/679. These are:

right to access your personal data (once you have confirmed that your data are subjected to treatment by the owner);

right to obtain rectification and integration of their data;

right to obtain the cancellation of their data;

right to obtain the limitation of the processing of personal data under certain conditions;

the right to receive the personal data provided to the holder in a structured and commonly used format, and to transmit them to another holder;

right to object to the processing of personal data if there are reasons related to his personal situation;

right not to be subjected to an automated decision-making process;

right to obtain communication in the event that your data are subject to a serious violation;

right to withdraw consent to processing at any time;

right to lodge a complaint with a supervisory authority


Requests should be addressed to the Data Controller, who undertakes to make the exercise of rights by the interested parties as easy as possible, at the email address: