PRIVACY & COOKIE LAW

INFORMATION ON THE PROCESSING OF PERSONAL DATA AND EXTENDED COOKIE INFORMATION
INFORMATION PURSUANT TO ART. 13 OF REGULATION (EU) N. 679/2016 (“GDPR”)
Last updated 06/09/2020

(A) – PREFACE AND ABBREVIATION IDENTIFICATION

The COMPANY protects the confidentiality of personal data and guarantees them the necessary protection from any event that could put them at risk of violation. As required by the European Union Regulation no. 679/2016 (“GDPR”), and in particular to art. 13, below we provide the user (“Interested”) with the information required by law relating to the processing of their personal data.

(B) – INFORMATION RELATING TO THE PRIVACY POLICY OF THE SITE

1. This section contains information on how to manage the WEBSITE with reference to the processing of website users’ data indicated in Section “A”.
2. This information is also valid for the purposes of art. 13 of Legislative Decree no. 196/2003, Code regarding the protection of personal data, and for the purposes of Article 13 of EU Regulation no. 2016/679, relating to the protection of individuals with regard to the processing of personal data as well as the free circulation of such data, for those who interact with the WEBSITE and can be reached at the address corresponding to the initial page indicated in Section A under the entry WEBSITE
3. The information is provided only for the indicated WEBSITE and not for other websites that may be consulted by the user through links contained therein.
4. The purpose of this document is to provide information on the methods, timing and nature of the information that the data controllers must provide to users when connecting to the web pages of the SIT WEB, regardless of the purpose of the connection itself, according to Italian legislation and European.
5. The information may be subject to changes due to the introduction of new regulations in this regard, therefore the user is invited to periodically check this page.
6. If the user is under the age of 16, pursuant to article 8, c.1 EU regulation 2016/679, he must legitimize his consent through the authorization of his parents or guardian.

(C) – DATA CONTROLLER

The owner of the data processing relating to this website is:

Lo Scrigno Sas di Zerbinato Bruno & C
Registered office: Via Stradone Sabbion 32 – 37044 Cologna Veneta (VR)
Phone: 0442 411740
Email address: web@lo-scrigno.eu.

For any further clarification and information, the user can write by post to the address of the registered office or by email to the addresses indicated above.

The COMPANY has signed service contracts with the following companies, which operate as data processors of which the COMPANY is the owner. Below is the list of companies and indication of the type of service subscribed: ARUBA: service provider where the WEBSITE and its database are hosted and that the DATA CONTROLLER uses to provide the pages of its sites and store the associated data. ARUBA SPA Via San Clemente 53 24026 Ponte S. Pietro (BG) Italy www.aruba.it

(D) – WHICH DATA ARE PROCESSED

THE COMPANY does not require the DATA SUBJECT to provide so-called data “Particular”, or according to the provisions of the GDPR (Article 9), personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or sexual life or sexual orientation of the person. In the event that the service requested from the COMPANY requires the processing of such data, the interested party will receive specific information in advance and will be required to give appropriate consent. Now follows a list of the types of ways in which data can be collected on this WEBSITE

(E) – PURPOSE OF THE TREATMENT With reference to Section “C” we indicate by type the purposes of the processing:

• Contact form, information request, quote request, request for registration to services: The personal data provided by users are used for the sole purpose of processing and following up on their requests.
• Newsletter subscription form: The personal data provided by users are used for the sole purpose of sending the newsletter via e-mail.

The acquisition of the data that is required to follow up on the request made by the USER and to subscribe to one of the newsletters is the prerequisite for accessing the services offered. Personal data provided by USERS will in no way be disclosed to third parties. They may be communicated to collaborators of the HOLDER who will treat them in compliance with the instructions given by the HOLDER himself and in the cases provided for by the information and / or by the Law and, in any case, in the manner permitted by this. The data entered may also be used by the COMPANY in order to periodically send e-mail messages containing advertising, promotional material, promotional initiatives, commercial communications to those users who have subscribed to one of its newsletter services.

(F) – STORAGE OF DATA

Unless they explicitly express their will to remove them, the personal data of the interested party will be kept as long as they are necessary with respect to the legitimate purposes for which they were collected.

It should also be added that, in the event that a user forwards unsolicited or unnecessary personal data to the COMPANY in order to perform the requested service or to provide a service strictly connected to it, the COMPANY cannot be considered the owner. of these data, and will delete them as soon as possible. Regardless of the determination of the INTERESTED PARTY to remove them, personal data will in any case be stored according to the terms provided for by current legislation and / or national regulations, for the sole purpose of ensuring specific obligations.

(G) – RIGHTS OF THE INTERESTED PARTY

Pursuant to articles 13, paragraph 2, and from 15 to 21 of the Regulation, we inform you that with regard to the processing of your personal data, you can exercise the following rights:

1. Right to obtain access to personal data and the following information:
   • confirmation that the processing of personal data is in progress or not;
   • the purposes of the processing;
   • the categories of personal data;
   • the recipients or categories of recipients to whom the personal data have been or will be disclosed;
   • if the data are not collected from the data subject, all available information on their origin;
   • the existence of an automated decision-making process, including profiling;
   • a copy of the personal data being processed.
2. Right of rectification and integration of personal data;
3. Right to delete data (“right to be forgotten”) if one of the following reasons exists:
4. the personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;
5. the interested party withdraws consent to the processing of data and there is no other legal basis for the processing;
6. the interested party opposes the processing and there is no legitimate overriding reason to proceed with the processing;
7. the personal data have been unlawfully processed;
8. personal data must be deleted to fulfill a legal obligation under the law of the Union or of the Member State to which the data controller is subject. The data controller, if he has made personal data public and is obliged to delete them, must inform the other owners who process the personal data of the request to delete any link, copy or reproduction of his data.
9. Right to limitation of processing in the event that: the data subject disputes the accuracy of personal data, for the period necessary for the data controller to verify the accuracy of such personal data;
10. the processing is unlawful and the interested party opposes the cancellation of personal data and instead requests that its use be limited;
11. although the data controller no longer needs it for the purposes of processing, personal data are necessary for the data subject to ascertain, exercise or defend a right in court;
12. the interested party opposed the processing, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party.
13. Right to lodge a complaint with the Guarantor for the protection of personal data, following the procedures and indications published on the official website of the Authority garanteprivacy.it.
14. Right to data portability of the interested party or the right to receive in a structured format, commonly used and readable by an automatic device, the personal data concerning him provided to a data controller and possibly transmit them to another data controller, if the processing is based on consent or on a contract and is carried out by automated means. Where technically possible, the interested party has the right to obtain the direct transmission of data from one data controller to another.
15. Right to object at any time to the processing of personal data, including profiling, in particular in the event that: the processing takes place on the basis of the legitimate interest of the owner, after explaining the reasons for the opposition;
16. personal data are processed for direct marketing purposes.
17. Right not to be subjected to a decision based solely on automated processing, including profiling, except in cases where the decision: is necessary for the conclusion or execution of a contract between the data subject and a data controller, is authorized by Union or Member State law to which the data controller is subject or is based on the explicit consent of the data subject.
18. Right to withdraw consent at any time; the data, if not based on another legal basis (including, fulfillment of a legal obligation or execution of a contract) must be deleted by the owner.

The exercise of rights is not subject to any formal constraints and is free.

(H) – REQUEST FOR CANCELLATION OF DATA AND EXERCISE OF RIGHTS

The interested party may at any time exercise their rights by sending a registered letter with return receipt to the registered office indicated in Section “B”, or an email / PEC to the addresses indicated in the same section.

The request for deletion of the data provided by a user can be made:

• automatically, for services that provide for it: for example, the cancellation from one of the newsletters, using the special function inserted in the terminal part of each newsletter message is sent to users;
• by email request, by sending an email to the email address and / or certified email address indicated in Section “B”, requesting the cancellation of the personal data provided. You are requested to send this communication via email using the email address that is present in your profile and / or the one to which you receive the newsletter messages and / or have been contacted.
• In the event of an automatic cancellation procedure, the user will be notified of the cancellation directly to the terminal; with a request via email, confirmation of the cancellation will be provided with an email message sent from the COMPANY’S WEBSITE.

(I) – EXTENDED INFORMATION ON COOKIES: TECHNICAL COOKIES AND AGGREGATE STATISTICS

Cookies consist of portions of code installed in the browser that assist the Owner in providing the service according to the purposes described. Some of the purposes for installing cookies may also require the consent of the user, it being understood that this WEBSITE does not perform user profiling.

Technical cookies have the function of allowing the carrying out of activities strictly related to the operation of this online space. The technical cookies used by the owner can be divided into the following sub-categories:

• Navigation cookies, by means of which browsing preferences can be saved and the User’s browsing experience can be optimized;
• Analytics cookies, by means of which statistical information is acquired regarding the browsing methods of the Users. This information is treated in an aggregate and anonymous form;
• Functionality cookies, also from third parties, used to activate specific functions of this online space and necessary to provide the service or improve it.

These cookies do not require the prior consent of the user to be installed and used.

The settings to manage or disable cookies may vary depending on the internet browser used. In any case, the user can manage or request the general deactivation or cancellation of cookies by changing the settings of their internet browser. This deactivation can slow down or prevent access to some parts of the site.

The use of technical cookies allows the safe and efficient use of the site

SUPPORT IN THE CONFIGURATION OF YOUR BROWSER

The user can also manage cookies through the settings of his browser. However, deleting the cookies from the browser could remove the preferences set for the site.

For further information and support, you can also visit the specific help page of the web browser you are using:

– Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

– Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences

– Safari: http://www.apple.com/legal/privacy/it/

– Chrome: https://support.google.com/accounts/answer/61416?hl=it

– Opera: http://www.opera.com/help/tutorials/security/cookies/

(L) – EXTENDED INFORMATION ON COOKIES: OTHER TYPES OF COOKIES OR THIRD PARTY TOOLS THAT COULD USE THEM

Some of the services listed below may not require the consent of the User or may be managed directly by the owner – depending on what is described – without the help of third parties.

If among the tools indicated below there are services managed by third parties, these could – in addition to what is specified and even without the knowledge of the Owner – perform User tracking activities. For detailed information on this, it is advisable to consult the privacy policies of the services listed.

Interaction with social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.

The interactions and information acquired by this Application are in any case subject to the User’s privacy settings relating to each social network.

This WEBSITE does not use this type of application as there are only links to the COMPANY’s social channels.

Statistics

The services contained in this section allow the DATA CONTROLLER to monitor and analyze traffic data in an anonymous and aggregate manner.

The Google Analytics service is used with anonymized IP (Google Inc.) whose information and information can be found at the links:

• https://policies.google.com/privacy?hl=it
• https://www.google.com/intl/it_it/analytics/learn/privacy.html

(M) – DATA TRANSFER TO EXTRA EU COUNTRIES

This site may share some of the data collected with services located outside the European Union area. In particular with the Google Analytics service. The transfer is authorized and strictly regulated by Article 45, paragraph 1 of EU Regulation 2016/679, for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.

Data will never be transferred to third countries that do not comply with the conditions set out in Article 45 et seq, of the EU Regulation.

(N) – CHANGES TO THIS DOCUMENT

This document is published on this WEBSITE at the link “Privacy & Cookie Law” at the bottom of the home page of the site and constitutes the privacy policy of this site. It may be subject to changes or updates. Users are invited to periodically consult this page to be always updated on the latest legislative news. Previous versions of the document will still be available on this page.

The document was updated on 06/09/2020 to comply with the relevant regulatory provisions, and in particular in compliance with EU Regulation 2016/679.