COMPLETE PRIVACY NOTICE PURSUANT TO EUROPEAN REGULATION 679/16 (GDPR).
1. Data controller identity and contact details
This notice outlines how personal data is processed by our company on this website, in compliance with data protection regulations in force, including, in particular, EU Regulation 2016/679 (referred to hereinafter as the “GDPR”).
The processing is carried out by:
Idrogru srl, with head office in Via Francesco Vecchione, 110/B – 41126 Modena (MO) VAT 00367070364 ID number, telephone n: 059 923148, email: email@example.com (referred to hereinafter as the “Data Controller” or the “Company”).
2. Processing methods
The website may process your personal data using the tools and in the manner described herein.
2.1 Technical and statistical cookies and environmental variables
- Browsing, functional, and session cookies: these cookies allow the site to operate properly. Session cookies (which are not stored permanently on the data subject’s device and are deleted automatically when the browser is closed) are used solely to send individual session identifiers in order to allow safe and efficient site use. They are mainly cookies set by the “WordPress” platform (wordpress.org), which is used for site creation and maintenance purposes.
- Statistical cookies: this site uses statistical cookies which are either created directly by the Data Controller as a first party or provided by third parties. In the latter case, suitable tools have been adopted to reduce the identification capacity of the cookies, including therein masking significant portions of the IP addresses processed in this way. Furthermore, use of these third-party statistical cookies is governed by contractual undertakings committing the third party to use them solely for the provision of the service, to store them separately, and not to enhance the said data with or cross-reference it against other information available to such parties. As far as Google Analytics cookies are concerned specifically, the information obtained via these cookies will be sent by the data subject’s browser to Google Inc., with head office in 1600 Amphitheater Parkway, Mountain View, CA 94043, United States, and stored on the said company’s servers. Google’s privacy policies, including the policy relating to the Google Analytics service (which we suggest you read), are available at the following address: http://www.google.com/intl/it/privacy/privacy-policy.html
- Browsing data and environmental variables: the IT systems and procedures for proper site operation automatically acquire, during their normal processes, certain items of personal data relating to browsing, including environmental variables. This category of data includes, by way of example:
- the IP addresses of computers used by users accessing the service;
- the access count;
- the pages viewed;
- the access date and time;
- the type of browser used;
- the operating system used.
2.2 Non-technical profiling cookies
• Adwords profiling cookies:
The site also uses profiling cookies provided by Google inc. in relation to Adwords services. Information about the processing is available at https://support.google.com/adwords/answer/2549116?hl=it&ref_topic=3123080
• Facebook profiling cookies:
The site uses profiling cookies provided by Facebook inc. in relation to its services; More specifically, a tool called “Pixel” is used to record the user’s specific preferences and behaviour. Information on data processing and disabling cookies may be found at the following address: https://www.facebook.com/privacy/explanation.
How to delete and disable cookies
You can set your browser so that it does not handle cookies or you can use specific functions to prevent them being set.
How to delete/disable cookies with Firefox: http://support.mozilla.com/it/kb/Eliminare%20i%20cookie
How to delete/disable cookies with Edge: https://support.microsoft.com/it-it/help/4027947/windows-delete-cookies
How to delete/disable cookies with Chrome: http://support.google.com/chrome/bin/answer.py?hl=it&answer=95647
Data provided optionally by the data subject
The data you provide optionally and freely by sending emails to the addresses on the site, or through contact forms, may be acquired for the purposes stated on each occasion. More specifically, in addition to the email address required in order to reply to the sender, any other personal data contained in the email in question will be processed. Data collected in this way will be stored and processed solely for correspondence filing purposes and will not be used for other purposes.
3. Purpose of the processing and legal basis of the processing
As regards technical cookies, as stated in section 2.1, and browsing data, personal data is processed in order to enable proper use of our site; the use thereof is necessary for browsing within our website. In this case, the legal basis for the processing is the data controller’s legitimate interest.
As regards non-technical (profiling) cookies, as stated in section 2.2, personal data is processed in order to offer you customised services through profiling. In this case, the legal basis for the processing is the data subject’s consent.
As regards data provided voluntarily by email, the processing of personal data allows us to respond to requests from data subjects. In this case, the legal basis for the processing is the data controller’s legitimate interest to respond to the data subject’s requests; without this processing, it would not be possible to respond to your requests.
4. Consent provision procedure
For the purposes stated in the previous section, your consent to the processing of your personal data is not required.
5. Source of the personal data
Only data provided in accordance with this notice, or collected through the website or through an email sent by you, the data subject, will be processed. Data taken from sources accessible to the public will not be processed.
6. Recipients and categories of recipients of personal data
The following parties may be sent the data subject’s personal data:
- Communications companies that carry out commercial communication and profiling activities on behalf of the Data Controller, acting in the capacity of data processors;
- Companies providing information society services, including, in particular, those providing email hosting and management services.
- Companies and corporate partners which perform services relating to those requested.
If these parties are established in a third country, personal data may be transferred thereto, or to an international organisation, solely subject to an adequacy decision by the European Commission, following verification that the third country, the territory, or one or more specific sectors within the third country, or the international organisation in question, guarantees a sufficient level of protection for your rights. In the absence of such decisions, the Data Controller – or any party deemed appropriate thereby – reserves the right to enter into separate agreements specifically requiring such parties to take suitable security measures, including organisational measures, aimed at offering appropriate guarantees regarding your rights. Google Inc., in particular, is contractually required to ensure appropriate protection for the data subject’s rights. The data can then be transferred to the United States of America. To obtain a copy of this data and be informed of the place where the data has been transferred, simply email a request therefor to the Data Controller.
7. Personal data retention period
The personal data processed and stored in order to enable proper use of the website and to respond to your requests is processed and retained for a period of no more than 24 months as of the date of each individual collection.
The Data Controller reserves the right, in any case, to request that you, the data subject, renew your consent to the processing and/or the right to verify the consent you have already given.
8. Categories of data processed
The data which will be processed is personal data. In the event that a contact form is completed, the following data will be processed in any case: data subject’s first name and surname, company, address, e-mail and telephone number.
9. Optional consent and consequences of non-provision
As regards personal data processed in order to enable proper use of the website, through technical cookies, as stated in section 2.1, such data is not processed as a result of a contractual obligation but of a legitimate interest of the Data Controller; without this processing, a properly functioning website could not be provided.
As regards personal data processed in order to provide customised use of the website through non-technical cookies, as stated in section 2.2, such data is not processed as a result of a contractual obligation but of consent given by the data subject; without such consent it would not be possible to provide customised tools.
As regards personal data processed in order to respond to specific requests submitted by the data subject either through a contact form or by email, such data is not processed as a result of a contractual obligation but of a legitimate interest of the Data Controller; without this processing, it might not be possible to respond to your requests.
10. Rights of the data subject
10.1 Right to object
Pursuant to Article 6, section 1, subsections e) or f) of the GDPR, you, the data subject, are entitled to object to the processing of personal data concerning you (including profiling based on such legal provisions) at any time, for reasons connected to your own personal situation. The Data Controller refrains from processing personal data any further, except where objective legitimate reasons for processing exist which override the data subject’s interests, rights, and freedoms or in order to ascertain, exercise, or defend a right in court.
10.2 Other rights
The Data Controller also hereby informs you, the data subject, of the following rights:
- Right of access by the data subject: pursuant to Art. 15, you, the data subject, have the right to obtain confirmation, from the Data Controller, of whether personal data concerning you is being processed and, in the event, to obtain access to the said personal data and specific information.
- Right of rectification: you, the data subject, have the right to obtain, from the Data Controller, the rectification of inaccurate personal data concerning you. Pursuant to Article 16 of the GDPR, taking into account the purposes of the processing, you, the data subject, have the right to have incomplete personal data supplemented, including therein through the provision of a supplementary declaration;
- Right to erasure of your data, including the right to revoke consent: you, the data subject, have the right to obtain, from the Data Controller, the erasure – without undue delay – of your personal data, or to revoke your consent if the conditions envisaged in Article 17 of the GDPR exist. As regards the right to revoke consent, you, the data subject, likewise have the right to revoke consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to the revocation;
- Right to restriction of processing: you, the data subject, have the right to ensure the Data Controller restricts the processing in the events set out by Article 18 of the GDPR;
- Right to data portability: you, the data subject, have the right to receive the personal data concerning you provided to the Data Controller in a structured, commonly used, and machine-readable format and you have the right to transmit the data to another Data Controller under the conditions envisaged in Article 20 of the GDPR.
11. Exercise of rights
Notices sent to exercise the rights stated in this notice, including, in particular, the right to erasure and the right to revoke the consent given, must be addressed directly to the Data Controller, and may be sent via the email address stated in section 1. Alternatively, you may exercise your rights by sending the relative notice by recorded delivery mail, with advice of receipt, to the Data Controller’s address.
12. Automated decision making and profiling
If you have consented to the processing of your personal data for profiling purposes via cookies, your data may be submitted to an automated decision-making process, which uses a specific algorithm to establish which communications are most suitable for your profile or which might be most of interest to you .
The consequences of processing carried out in this way include, for example, the receipt of highly profiled commercial communications. In any case, you have the right to disable the profiling cookies used on this site (as explained clearly in section 2) and the right to obtain human intervention by the Data Controller in the decision-making process, as well as the right to express your opinion, to obtain an explanation of the decision made, and to challenge the said decision.
13. Newsletters and the processing of your data
If you have given your consent (by checking boxes) to the receipt of commercial communications, your data may be processed in order to send direct marketing communications, newsletters, and advertising material, or to carry out market research, by means of conventional contact systems or automated information systems, including commercial or promotional communications sent either by email or text; the data subject’s consent, provided as stated in this notice, constitutes the legal basis for the processing. In this event, consent to the processing of your personal data is not a contractual requirement. You, the data subject, may decide whether or not to provide your personal data; in the event of failure to provide such data, however, it will not be possible to carry out any marketing activity. The Data Controller hereby informs you that, as regards the right to object to the processing of personal data for marketing purposes, you may also exercise this right in part, by objecting – for example – solely to the receipt of promotional communications sent using automated and/or digital tools or, alternatively, conventional methods.