Personal data processing notice – Information document pursuant to and for the purposes of Articles 13-14 of the GDPR (General Data Protection Regulation) 2016/679
In compliance with Regulation (EU) 2016/679, we hereby provide the required information concerning the processing of the data you have provided. This information document is not applicable to other websites accessed by following links provided on the internet sites in the domain of the data controller, which shall not be held in any way liable for the internet sites of third parties.
1) Data controller, data processor and place of processing
The data controller is ABC Srl – Registered and Administration Office, Via Luigi Alamanni 16/2
20141 Milan, Italy, VAT no. IT05699480967, in the person of the pro-tempore legal representative.
Phone: +39 02 5253921
PLACE OF DATA PROCESSING
Data processing is carried out at the offices of the Data Controller and at the offices of identified external parties.
2) Types of data processed
Personal and browsing data
‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
The IT systems and software procedures used in the course of the normal operation of this website collect certain personal data whose transmission is implicit in the use of internet communication protocols.
This information is not collected to be associated with identified interested parties, but could by its very nature, through processing and association with data held by third parties, allow users to be identified.
This category of data includes the IP addresses or domain names of the computers used to access the website, the URI (Uniform Resource Identifier) addresses of the resources requested, 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 (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment.
Data provided voluntarily by the user
The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site and/or the completion of data collection forms entails the subsequent acquisition of the sender’s address, which is necessary in order to reply to requests, as well as any other personal data entered.
For contact information, follow the link in the footer (at the bottom of all site pages).
For the cookies policy, follow the link in the footer (at the bottom of all site pages).
3) Purposes of processing for which consent is given, where required (article 6 GDPR)
- A) Voluntarily provided data of a personal nature will be processed for the following purposes:
- browsing this website;
- completion, where applicable, of data collection forms to request quotations and/or contacts and/or to submit applications;
- completion, where applicable, of data collection forms for on-line booking;
- administration and accounting operations in general.
For the purposes of applying the provisions relating to personal data protection, processing operations carried out for administration and accounting reasons are those connected with the performance of organisational, administrative, financial and accounting activities, regardless of the nature of the data processed. Specifically, these purposes are pursued by internal organisation activities, by activities instrumental to the fulfilment of contractual and pre-contractual obligations, and by information activities.
B) The personal data provided when completing data collection forms on the websites or general data collection forms (i.e. name, surname, email address) will be processed, subject to consent, by the Data Controller and Data Processors for use in commercial promotion activities and to send newsletters by email.
4) Method of processing – Retention
Processing will be carried out automatically and manually, using methods and tools that ensure maximum security and confidentiality, by subjects specifically charged with this task in compliance with the provisions of articles 13 and 14 of the GDPR. The data will be retained for no longer than is required for the purposes for which the data were collected and subsequently processed.
5) Scope of communication and distribution
Your data, subject to processing, will not be distributed and may be communicated to companies bound by contract to the data controller in order to fulfil contracts or for connected purposes. The data may be communicated to third parties belonging to the following categories:
- subjects that provide services for the management of the information system used by the data processor and of the telecommunications networks;
- firms or companies in the framework of assistance and consulting relationships;
- competent authorities to comply with legal obligations and/or the provisions of public entities, on request.
The subjects belonging to the aforementioned categories either act as Data Processors or operate completely independently as separate Data Controllers. The list of data processors is constantly updated and available for consultation at the head office of the data controller indicated in point 1.
Any additional communication or distribution will only take place with your explicit consent.
6) Nature of the data transfer and refusal
With the exception of that specified for browsing data, the user is free to provide their personal data. The provision of data for the purposes set out in point A) is necessary. The refusal to provide data for the purposes set out in point A) makes it impossible to obtain that which has been requested or to use the services of the Data Controller. The giving of consent to process data for the purposes set out in point B) is optional. The refusal to give consent for the purposes set out in point B) will not produce any negative effects for the purposes set out in point A).
7) Rights of data subjects
You may exercise your rights as expressed in articles 12 to 23 by contacting the data controller or processor by telephone or email at the number of our head office or the email address indicated in point 1.
As a data subject, you have the rights set out in article 15, GDPR, and specifically the rights to:
- obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet registered, and their communication in intelligible form;
- obtain information on:
a) the source of the personal data;
b) the purposes and methods of processing;
c) the logic applied in the case of processing carried out with the aid of electronic instruments;
d) the identity of the data controller, the data processors and the designated representative pursuant to article 5, sub-section 2, Privacy Code and article 3, sub-section 1, GDPR;
e) the subjects or categories of subjects to which the personal data may be communicated or which may become aware of such data in their capacity of designated representative in the territory of the State, data processors, or persons charged with data processing;
a) the updating, rectification or completion of the data;
b) the erasure, transformation into anonymous form or restriction of the data processed in breach of the law, including those for which retention is not necessary in relation to the purposes for which they were collected or subsequently processed;
c) certification that the operations in letters a) and b) have been notified, also with regard to their content, to the recipients to which the data have been communicated or distributed, unless this requirement proves impossible or involves disproportionate effort with respect to the right protected;
- object, in whole or in part:
a) on legitimate grounds to the processing of personal data concerning you, even if relevant to the purpose of collection;
b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales materials or for market research or commercial communication, by means of the use of automated calling systems without operator intervention, of email and/or of traditional marketing methods involving phone calls and/or paper mail.
Where applicable, you also have the rights set out in articles 16 to 21, GDPR (right of rectification, right to be forgotten, right to restrict processing, right to data portability, right to object), as well as the right to complain to the Data Protection Authority. You may at any time obtain confirmation of the existence or otherwise of personal data concerning you and the communication of such data and the grounds on which processing is based. In addition, you may obtain the erasure, transformation in anonymous form or restriction of data processed in breach of the law, as well as the updating, rectification or, if you have an interest in this, the completion of the data. You may object, on legitimate grounds, to the processing of your personal data.
8) Changes to the privacy information document
The data controller reserves the right to modify, update, add or remove parts of this privacy information document at their own discretion and at any time. The data subject is required to periodically check for any changes. In order to facilitate such checks, the privacy information document will indicate the date of the most recent revision. The use of the website after the date of publication of the modifications will constitute acceptance of same.
9) Social plug-ins