PERSONAL DATA PROCESSING POLICY -PURSUANT TO EU REGULATION N. 2016/679 AND TO THE COUCIL HELD ON 27TH APRIL 2016
1. TYPES OF PERSONAL DATA COLLECTED
The personal data PALETTI ANGELO & C. di PALETTI IVANO SNC collects from you directly can include, as an example: your name and surname, date of birth, gender, personal or work email addresses, mobile number or phone number, home address, identification number and other information. If you are using a mobile device online or browsing our website, we may collect your IP address or other device identifier, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other portable device information. If you are sending us an email to the email addresses listed on our website, we will get the sender email address, necessary to send them an answer to their request, as well as potential other personal data belonging to the sender themselves; any other personal data information, sensitive data, to us provided by the individuals.
2. WHY DO WE COLLECT YOUR PERSONAL DATA?
Personal data provided by individuals will be processed to:
a) Perform our contractual obligations to which you are a party, pre-contractual phase included and, more precisely, to compile registries, bookkeeping, invoicing, communicating via hardcopy or any other technologically advanced mean, financial fulfillment, managing, making and compiling contracts, scheduling appointments, forwarding orders, delivering, bureaucratic fulfillments connected to required services.
b) your data could be also used to send, via hardcopy or email, commercial communications and/or sales about services or products similar to the ones you’ve already had, unless specified.
Your data could be used internally to draft statistics.
c) (NB only if a profiling option is active) profiling to evaluate certain personal aspects relating to an individual, in particular to analyze or predict aspects concerning an individual’s tastes, personal preferences, interests, behavior, choices and to make personalized offers according to the information collected by PALETTI ANGELO & C. di PALETTI IVANO SNC, subsidiaries, parent or equal companies, as well as by cooperating companies or juridical person involved in commercial activities and relations;
d) to consent the transfer of your data, after your specific consent, to commercial partner of PALETTI ANGELO & C. di PALETTI IVANO SNC in order to receive their communications, or to adhere to undertaken contractual obligations. We also remind you that, referring to point a), you’re obliged to give in your personal data, if you refuse to do so or if you hand in incomplete or wrong information it’d prevent:
- referring to the purpose shown in point a): PALETTI ANGELO & C. di PALETTI IVANO SNC wouldn’t be able to carry out its administrative-accounting activities and the fulfillment of regulations and of contractual obligations, among which broadcasting your data to third parties to comply to contractual obligations.
As per further goals shown in points b), c), d), providing your personal data and consenting to their processing for said end isn’t compulsory. Anyways, your hypothetical refusal could impede PALETTI ANGELO & C. di PALETTI IVANO SNC:
-as per point b) ends and purposes: sending promotional communications from PALETTI ANGELO & C. di PALETTI IVANO SNC to your attention;
-as per point c) ends and purposes: profiling activities and sending personalized offers based on your preferences from PALETTI ANGELO & C. di PALETTI IVANO SNC
-as per point d) ends and purposes: transferring your personal data to commercial partners of PALETTI ANGELO & C. di PALETTI IVANO SNC in order to allow them to send you communications, if not the complete or partial impossibility to receive third-party services.
3. MEANS AND PURPOSE OF PERSONAL DATA PROCESSING
The Data will be processed both manually and with the help of electronic instruments in a safe way and to guarantee the individuals’ privacy.
PALETTI ANGELO & C. di PALETTI IVANO SNC will be able to add this information to the data already collected through its services. Should the user choose to share info using the aforementioned social networking platforms, PALETTI ANGELO & C. di PALETTI IVANO SNC will receive data from these sites according to the consent options accepted by the user. Any Personal Data received through social networks will be subject to terms and conditions of the Social Network, as well as to the terms established by this communication.
4. RECIPIENTS OR TYPES OF RECIPIENTS OF PERSONAL DATA
Your personal data may be transferred to the Board of Trustees at PALETTI ANGELO & C. di PALETTI IVANO SNC or any other of our administration groups, Data Controller, or people appointed by PALETTI ANGELO & C. di PALETTI IVANO SNC. They’ll have the permission to process and handle your personal data.
Your personal data could be shared with PALETTI ANGELO & C. di PALETTI IVANO SNC’s authorised third-party service providers and partners for the aforementioned purposes like, for example, just to cite a few, parent companies, subsidiaries and/or associates.
We’ve the right to share your data with suppliers, contractors, subcontractors, banks, insurance companies and other subjects providing for PALETTI ANGELO & C. di PALETTI IVANO SNC:
– to handle on our behalf of back office related activities to supply product/services for which you’ve signed a contract with PALETTI ANGELO & C. di PALETTI IVANO SNC;
– to to handle and/or manage internet site and technological instruments or telematic alike used by PALETTI ANGELO & C. di PALETTI IVANO SNC;
– to send informative and promotional communications, even of commercial kind, advertising or offers of products or services;
– to the execution of profiling activities like the identification of habits and behaviors, tastes and preferences, as well as to making marketing studies and research.
Your personal data can be also transferred to foreign countries, according to the existing laws and regulations, even in countries outside the EU where the society has interests. Transferring data to non EU countries. The country to which your data is transferred has been deemed to provide an adequate level of protection for personal data by the European Commission, this means the appropriate guarantees as requested by art. 46 or 47 or 49 of the Regulation are held true.
5. HOW LONG DO WE KEEP YOUR DATA?
5.1 Processing Period.
5.2 Conservation of data
Data will be saved according to these criteria:
-data of point a) of this document, will be saved for as long the user will benefit from at least one or more services/products of PALETTI ANGELO & C. di PALETTI IVANO SNC and for ten years after the interruption of the contract, unless a longer conservation is needed, to consent PALETTI ANGELO & C. di PALETTI IVANO SNC to adhere to the obligations determined by regulations or to defend their rights and to keep said data at your disposal, should you ask explicitly in the future;
-processed data for marketing and profiling purposes of letters b) and c), paragraph 2 (“Why do we collect your personal data?”) of this very same policy will be stored for a maximum of ten years.
6. YOUR RIGHTS
We’re informing you that, any time, you can choose to execute the rights prescribed in articles 7 and 15-22 of the Regulation.
To claim the rights described here, please contact the Data Controller at the email address email@example.com; a kind reply will follow the request pursuant to the period of time indicated by the Italian data protection authority.
You’ll have the right to:
- withdraw or restrict consent or temporarily stop our processing of your personal data in certain circumstances;
- ask the Data Controller to edit (the so-called “right to be forgotten”) or delete personal data concerning you in certain situations where there is no good reason for us to continue to process it;
- obtain data portability;
- have your data processed in a fair, lawful and transparent way;
Particularly, as per articles 13, comma 2 and articles 15 to 21 of the Regulations, we’re informing you that, as far as your personal data is concerned, you’ll have the following rights.
a) the right to gain access to your personal data and to certain information:
- know if your data is being processed;
- why your data is being process;
- the types of personal data;
- the recipients or types of recipients to which your data were sent or will be sent;
- any possibile information about the origin of your data;
- if there is any kind of automated decision making process, profiling included;
- a copy of your personal data, subject of the policy;
b) the right to ask the Data Controller to edit or correct your personal data;
c) the right to ask the Data Controller to cancel your data (the so-called “right to be forgotten”) if any of these situation occurs:
there is no good reason for us to continue to process it;
the individual withdraws consent for the processing of his data and there’s no legal reason to continue to process it;
the individual asks to stop processing his data and there’s no greater purpose to continue to process it;
your personal data were obtained illegally;
your personal data must be deleted to adhere to a legal obligation prescribed by the Union or by a Member State law, to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests
d) The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims;
the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
e) The right to complain to the Italian data protection authority, following procedures and instructions that can be found on the official web site garanteprivacy.it
f) Right to portability, which means that the data subject has the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided;
g) The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her, if:
Data processing is done filling the interests of the person to whom the data belong;
data is being processed for marketing purposes;
h) The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests or unless consent is based on the data subject’s explicit consent.
i) The right to withdraw at any time; if data aren’t based on other juridical basis (this is possible if it doesn’t affect the lawfulness of processing based on consent before its withdrawal) they must be erased by the Data Controller.
The exercise of the preceding rights is not subject to any form constraint and is free.
7. DATA CONTROLLER, DATA SUBJECT AND RESPONSIBLE FOR THE PROTECTION OF PERSONAL DATA
The Data Controller is PALETTI ANGELO & C. di PALETTI IVANO SNC – based in COLLEBEATO (BS), Via A. De Gasperi, 11 and represented by PALETTI IVANO.
The person responsible for data treatment at PALETTI ANGELO & C. di PALETTI IVANO SNC is PALETTI IVANO.
Any request regarding data processed by PALETTI ANGELO & C. di PALETTI IVANO SNC can be sent to the registered office of the firm, or it can be sent as an email to: firstname.lastname@example.org
The updated list of those named “responsible” pursuant to art. 28 of GDPR is available at PALETTI ANGELO & C. di PALETTI IVANO SNC and it can be examined when appropriately asked as above explained.
The phone number of the Data controller of PALETTI ANGELO & C. di PALETTI IVANO SNC is 030 25 11 219.
8. WEB SITE AND COOKIES
PALETTI ANGELO & C. di PALETTI IVANO SNC web site and third-party suppliers, among which stand Google and other suppliers, in this website, use proprietary cookies as well as third party cookies to determine the link between web site visits and impressions of advertising in Google AdWords’s Display, other ends of advertising services and interactions with those impressions and advertising services, and to determine the connection between demographic information and interests on Google Analytics.
9. UPDATES AND CHANGES
1. WHAT ARE COOKIES?
Cookies are little text files which are stored on the browser or hard drive of your computer or mobile device when you visit a webpage or application. Cookies have different ways to save in your devices (computer, laptops. tablet, smartphones) information, they remember your preferences so you don’t have to insert your details over and over again. There are different types of cookies, the most well-known are small text files, saved on the user’s devices, these files can be identified later.
Some of these cookies are necessary to this web site, others are useful for users because they can safely remember, i.e. user names.
2. FOR HOW LONG ARE COOKIES ACTIVE ON PALETTI ANGELO & C. di PALETTI IVANO SNC?
The Cookies we use have different expiration dates. A “cookie Session” ends when we close the browser, while a “persistent cookie” stays on the the user’s device for a period of time. Users can delete all the cookies saved on the browser whenever they want, using the menu in their settings, then it depends on the browser. If you want to know where to find the saved cookies, you can use the Search Option inside your Settings or you can also use the Help section on your browser.
3. WHICH COOKIES DOES PALETTI ANGELO & C. di PALETTI IVANO SNC USE?
We use both third party cookies and first party cookies. First Party Cookies are inserted and read by PALETTI ANGELO & C. di PALETTI IVANO SNC. Third Party Cookies are inserted or read by third parties, this means external services.
Functional Cookies allow us to use the Workplace (Intranet area) or to activate certain functionalities. One of these cookies, i.e., allows us to stay logged in the workplace without having to fill in our information every time we click on a link inside the portal. These Cookies can be placed regardless of users authorization when he enters the portal or when he uses essential functionalities.
Apart from all this, we use functional cookies to:
-Verify the user’s account type
-Verify that the user has logged in
-Save data about the kind of decide used to visit the intranet area
They record the way in which users browse the portal. We can use the data collected by these cookies to analyze how the portal is used and to identify eventual mistakes on the platform online. Some are placed regardless of the user’s consent when visiting PALETTI ANGELO & C. di PALETTI IVANO SNC, i.e. cookies that collect only aggregated data.
Analytics and Search cookies are used to:
-Measure the number of users on the website in a certain amount of time
-Measure how long users stay on the website
-Track the order in which users visit different web pages
-Decide which part of the site need to be improved
-Identify the type of device and browser used to access the website
-In general, to monitor how people use the website, in order to improve their user experience.
Social Networking Cookies
We’d like to give our users the chance to share on Social Media this website’s content. For this reason we’ve added some buttons and options that allow users to share content. Other buttons allow users to access our profiles on some Social Media.
Using these buttons and options, said Social Media can add Cookies that, at a later time, they can read. These Cookies are used to:
-allow users that are logged in to access some social media platforms and and share content on that online platform
-allow users to watch videos on our YouTube official channel using the improved privacy mode on YouTube.
Facebook is a social network
Twitter is a social network
Flickr is a web platform that allows users to share and watch photos online
YouTube is a we platform that allows users to share and see videos online
Google Analytics is a web analysis online service provided by Google Inc.
4. HOW CAN WE CONTROL HOW COOKIES ARE USED?
Microsoft Windows Explorer
To manage third-party cookies you can go on these web pages
These websites allow you to block specific third-party Cookies.
7. THIRD-PARTY COOKIE CHART
Currently our web site doesn’t use third-party Cookies. We only use functional cookies.
Why we need your data
Personal data provided by individuals are used only to manage and execute the contact requests forwarded by individuals.
Personal data provided by individuals are treated in law-abiding ways, to comply to precontractual measures or to contractual duties (art. 6 par. 1 lect. b) of the Regulation 679/2016 asked by individuals themselves (the request is forwarded by sending the form).
Personal data provided by individuals won’t be forwarded to third party realities. The data controller could instead communicate the data to employees or collaborators who will respect the instructions they’ll be given.
Personal data responsibility
If needed, in case of activity connected to the maintenance of the tech aspects of the website, individuals’ personal data will be handled by data controller as per art. 28 of EU Regulation No. 679/20016.
Time limits for storing the data
Users’ personal data will be handled as long as necessary to fulfill certain purposes.
Data Subjects’ rights
Pursuant to Article 13, 2 and 15 to 21 of the Regulation, we’re informing you that as far as your data are concerned you’ll have the following rights:
a) The right to gain access to personal data and to the following information:
- receiving a confirmation or denial that your data is being processed;
- aim of the processing;
- personal data types;
- recipients or types of recipients to whom individuals’ personal data were or will be sent;
- when said data aren’t collected by the person involved, information about their origin;
- if there’s an automated decision-making process, profiling included;
b) Right to rectification and integration of personal data;
c) Right to erasure of data if:
- the personal data is no longer necessary for the purpose which you originally collected or processed it for;
- one is relying on consent as their lawful basis for holding the data, and the individual withdraws their consent;
- you are relying on legitimate interests as your basis for processing, the individual objects to the processing of their data, and there is no overriding legitimate interest to continue this processing;
- you have processed the personal data unlawfully;
- you have to do it to comply with a legal obligation;
Where personal data has been made public in an online environment, reasonable steps should be taken to inform other controllers who are processing the personal data to erase links to, copies or replication of that data.
d) Right to restricting processing if:
- the individual contests the accuracy of their personal data, as long as the controller is verifying their accuracy;
- the data has been unlawfully processed and the individual opposes erasure and requests restriction instead;
- you no longer need the personal data but the individual needs you to keep it in order to establish, exercise or defend a legal claim;
- the individual has objected to you processing their data and you are considering whether your legitimate grounds override those of the individual.
e) Right to complain to the controller for the protection of data, as per procedures and instruction published on the official web page of The Italian Data Protection Authority (Garante per la protezione dei dati personali) www.garanteprivacy.it
f) Right to portability which gives individuals the right to receive personal data they have provided to a controller in a structured, commonly used and device readable format. It also gives them the right to request that a controller transmits this data directly to another controller if the processing is based on consent or on a contract and if it’s made using automated technologies. If technically possible, individuals have the right to request that a controller transmits this data directly to another controller.
g) Right to object at any time, this gives individuals and users the right to ask the controller to stop processing their personal data if:
- the processing follows the interests of the controller, prior explaining the reasons for the objection;
- personal data are processed for direct marketing purposes.
h) Right related to automated decision making including profiling. This shall not apply if the decision is necessary for entering into, or performance of, a contract between the subject/user and the controller; is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests.
i) Right to withdraw at any time; if data aren’t based on other juridical basis (this is possible if it doesn’t affect the lawfulness of processing based on consent before its withdrawal) they must be erased by the Data Controller.
The exercise of the aforementioned rights is not subject to any form of constraint and is free.
To this end, you can contact the Data Controller by sending a registered letter with return receipt to PALETTI ANGELO & C. di PALETTI IVANO SNC based in COLLEBEATO (BS) – Via A. De Gasperi, 11 or an email to email@example.com
The Data Controller is PALETTI IVANO .
Contact information 030 25 11 219
Mail to: firstname.lastname@example.org