Mod.: IS – Updated 04/2022
Information notice on personal data processing.
Articles 13 and 14 EU REGULATION No. 679/2016
Legislative Decree 196/2003 as amended by Legislative Decree 101/2018
Dear Data Subject,
This information notice describes how the website is managed with regard to the processing of personal data of users visiting it, as well as the data processing practices through this site. In compliance with Article 13 (for data collected from the data subject) and Article 14 (for data not collected from the data subject) of Regulation (EU) 2016/679 (henceforth GDPR), the following information is rendered to the Users of this Website, which refers exclusively to the processing carried out through said Website and not through other websites that may be visited through links from this one, in which case we suggest viewing the respective information notices rendered by the respective Data Controllers. This Website and any services offered through the Website are restricted to individuals who are eighteen years of age or older. Therefore, the Controller does not process personal data relating to individuals under the age of 18. Upon the request of such Users, the Controller will promptly delete all personal data involuntarily collected from them.
1. Data Controller
Data controller FOR ALL srl, based in Via 8 Marzo, 10/12 – 37012 Bussolengo (VR), Tax Code and VAT number 04297880231, (hereinafter “Data Controller”). The Data Controller reserves the right to appoint a web agency or consultant as Data Processor for the purposes of technical assistance, maintenance, technical management and similar of this Site, whose details may be communicated upon request to the addresses indicated above. The Data Controller and the Data Processor also process Users’ data through their own in-house Appointees, specially designated with instructions to authorized processors.
The Data Controller has appointed Mr. Nicola Ghinello as Data Protection Officer who can be contacted at the following: phone +39 348 3165267, e-mail: nicola.ghinello@dpo-rpd.com.
2. Category of data processed and sources of origin
- Navigation data (the computer systems and software procedures used to operate this site acquire, during their normal functioning, some personal data for which transmission is implicit in the use of Internet communication protocols. This category of data includes: IP addresses, the type of browser used, the operating system, the domain name and addresses of websites that were accessed or left from, information on pages visited by users within the site, time of access, time spent on the individual page, internal path analysis and other parameters related to the user’s operating system and computer environment. Such technical/IT data are collected and used only in an aggregate and anonymous manner. This data is processed for the purpose of enabling and monitoring proper use of this site as well as to obtain anonymous statistical information on its use, and is deleted immediately after processing)
- Cookies, on which we invite you to read our Cookie Policy
- Data voluntarily provided by the user, including:
- Common data (identification, personal, billing, and similar data)
- Only exceptionally special data (art. 9 GDPR)
- Only exceptionally criminal data (art. 10 GDPR)
Sources: browsing, other sites, cookies and similar; user; public sources.
We may primarily process browsing data as well as cookies.
We may also process data provided voluntarily by the user, e.g. through the contact form or by sending an e-mail communication, including common data (identification, personal, billing, and similar data) and exceptionally special data pursuant to Art. 9 GDPR or criminal data pursuant to Art. 10 GDPR in the narrow limits where this is made necessary by the request for information received and subject to the consent of the data subject.
Data could come from automated or voluntary sources, as well as from public sources. For example, it could come from the user’s browsing, which could bring with it information about previous consultations of other sites, including in particular cookies and other similar technologies. Data could also be voluntarily contributed by the user or related parties. Other data could come from public sources, such as data processed as part of research and from records, public databases, and similar.
3. Purpose of processing
Personal data of Users of the Website, as described above, will be processed in the manner and in the forms prescribed by the GDPR, for the pursuit of the Website’s own functionalities, with particular, but not exclusive, reference to page navigation and the procedures described therein for data collection, contact form, potential registration/private area access, newsletter subscription and similar. In particular, personal data provided to the Data Controller will be processed for the pursuit of the following purposes:
- to follow up on specific requests made to the Controller by the User through the Website and its communication tools (contact forms, information request forms and similar);
- for communications of informative nature related to the services of the Controller, following the request for information through e-mail messages or filling out the contact form and other communication tools;
- for possible entry to events organized by the Controller and other related activities (e.g., verification of participation, notices regarding event updates or changes, etc.);
- for other purposes in addition or related to those stated above and in any case within the scope of the Website’s activities;
The processing of data conferred generically will be carried out, also as a result of automatic collection during navigation, for the sole purpose of verifying and controlling access to the Website. This also applies to technical cookies, intended as session, functionality or analytics cookies that meet the requirements specified by the Guarantor. In particular, with regard to the latter, it is clarified that they can be assimilated to technical cookies where these are made and used directly by the Website. In any case, for said analytics cookies, the Website, also in accordance with the clarifications of the Guarantor, has provided for the anonymization of IP addresses and the amendment to the processing of data; the collection and use of the aforementioned navigation data (granted the anonymization of IP addresses) allow the monitoring of the Website’s performance and allow to improve the service offered, proposing to the User a better browsing experience. Please refer to the appropriate Cookie Policy for further information.
4. Legal basis for processing
The processing of personal data is based on the fulfillment of contractual or pre-contractual obligations inherent to the request made by the User (e.g. requests for information about the services offered by the Controller, requests for estimates, etc.), as well as, where necessary, on consent through the free and conscious filling in of the appropriate information fields in the form dedicated to the collection and submission of data and the ticking of the appropriate checkbox where required.
It should be noted that filling in the appropriate fields provided in forms for the request for information is inherent to the request itself and therefore this implies the fulfillment of a pre-contractual or contractual obligation, depending on the context. Consent may be required later for the processing of further data.
A specific privacy notice will be present wherever it is needed ( a different notice from this one).
In any case, processing is also based on legitimate interest, including the right to information, for which please refer to the next paragraph.
5. Legitimate interest of the Controller
The processing of personal data is also based on the legitimate interest of the Data Controller, such as the exercise of its rights in the context of the information society, the execution of contractual service and the implementation of direct marketing operations (in the manner, by the means and within the timeframe provided by law).
6. Compulsoriness of data provision
The provision of browsing-related data by Users, for the above purposes, depends on the degree of privacy you have enabled or disabled via your browser. In some cases, disabling it may affect navigation on this Website. For certain modules of this Website, the provision of navigation data and/or the use of technical cookies is mandatory for the proper functioning of the Website itself.
The provision of some of your own data is in any case necessary for the very structure of the Website and its procedures. The possible request of other optional data, will instead be preceded by an appropriate approval tick. The provision of all other data is optional, in accordance with the type of information the User wishes to provide to the Website.
Notwithstanding the above, the provision of the e-mail account, for example, is necessary to be able to respond to the request made via contact form, as well as the other mandatory data indicated therein with an asterisk. The other data are optional.
Failure to provide the data necessary for the requested action (e.g., of the e-mail account via form for requesting information by this mean) makes it impossible for the Controller to process the request.
REGULATIONS APPLICABLE TO ALL PROCESSING
In any case, even where the data subject has given consent to authorize the Controller to pursue all the purposes mentioned in the points above, they will still remain free at any time to revoke it.
It is specifically and separately informed, as required by Art. 21 of the Regulation, that the data subject has the right to object at any time to the processing of personal data concerning them carried out for the above purposes, and that if the data subject objects to the processing, the personal data may no longer be processed for these purposes.
7. Possible recipients of personal data
Data may be disclosed to companies related to, connected with or controlled by the Data Controller, as well as to consultants, or even third parties operating, also on behalf of the Data Controller, for the fulfillment of the services related to the purposes indicated in this information notice, both EU and non-EU (in the latter case, it will be exclusively subjects adhering to the regulations in force).
Browsing data and similar (for which please refer to the above), as well as profiling cookies also from third parties (for which please refer to the Cookie Policy of this Website), will be disclosed to the respective third parties concerned, if they do not handle them directly as Data Controllers.
In any case, the data may be communicated to Data Processors, as well as to persons authorized to the processing and duly instructed, always within the scope of the purposes of the processing.
For brevity, the detailed list of these positions is available at our office.
8. Retention period
Data provided voluntarily by the Data Subject will be kept until expressly revoked by the Data Subject, including by action on their browser, clearing of cookies, express request or otherwise manifested. Browsing data will be kept, in accordance with the principle of proportionality, in a form that allows the identification of the Data Subject for a period of time not exceeding that necessary for the purposes for which it was collected or subsequently processed.
Excluded from the above terms are cases in which it is necessary to retain the data for an additional period of time to defend or enforce a right or to fulfill any legal obligations or orders of the Authorities.
9. Rights of the data subject
Each Data Subject has the right of access, rectification, erasure (be forgotten), restriction, receipt of notification in case of rectification, erasure or restriction, portability, objection, and not to be subject to automated individual decision-making, including profiling, pursuant to Art. 15 to 22 GDPR. These rights may be exercised in the forms and terms set forth in Art. 12 GDPR, by written notice sent to the Data Controller (see point 10).
The Controller will render an appropriate response as soon as possible, and in any case within 1 month of receiving the request.
10. Right to revoke consent (How to exercise rights)
It is possible to revoke consent, where applicable, at any time and/or exercise rights by sending:
– a registered letter with return receipt to the writing company with an express request (see the address given in the letterhead);
– an e-mail to the address info@for-all.it.
11. Complaints
Each Data Subject has the right to file a complaint pursuant to art. 77 et seq. of the GDPR to a supervisory authority, which for the Italian state is identified in the Guarantor for the protection of personal data. The forms, methods and terms of proposing complaint actions are provided for and regulated by current national legislation. The complaint leaves aside administrative and jurisdictional actions, which for the Italian State can be brought alternatively to the same Guarantor or to the competent Court.
12. Profiling
Personal data provided through browsing this website and any completion of forms posted therein may be subject to profiling by third-party providers through third-party cookies.
Profiling allows such third-party providers, autonomous Controllers of their respective processing of personal data for profiling purposes, other than the Controller of this website, to assess certain personal aspects of the Data Subject related in particular to their preferences, interests, and tastes with reference to the pages consulted and the activities carried out, in order to allow such autonomous and different Controllers to offer the Data Subject a more specific service targeted to their needs.
For further information, the User is invited to read the cookie policy.
13. Controller, D.P.O. (R.P.D.), Appointed/Authorized personnel, Data Processors
Below we provide you with some information that it is necessary to bring to your attention, not only in order to comply with the obligations of the Law, but also because transparency and fairness towards the interested parties is a founding part of our activity.
Data Controller. The Data Controller of your personal data is FOR ALL srl, based in Via 8 Marzo, 10/12 – 37012 Bussolengo (VR), Tax Code and VAT No. 04297880231, responsible to you for the legitimate and correct use of your personal data and that you can contact for any information or request at the following: phone +39 045 7150425 e-mail: info@for-all.it
D.P.O. (Data Protection Officer) – R.P.D. (Responsabile delle Protezione dei Dati). You may also contact the Data Protection Officer to obtain information and make requests about your data or to report disruptions or any problems you may encounter.
The Data Controller has appointed Mr. Nicola Ghinello as Data Protection Officer who can be contacted at the following: phone +39 348 3165267, e-mail: nicola.ghinello@dpo-rpd.com.
Appointed/Authorized personnel. The updated list of those appointed/authorized to process the data is kept at the office of the Data Controller.
Data Processors.
For brevity, the detailed list of these positions is available at our office.
14. Social media plug-ins
This site may contain plug-ins from some social media (e.g., Facebook). Social plug-ins are special tools that allow you to embed social media features directly within the site (e.g., Facebook’s “like” feature) and are marked with the logo of the respective social platform. When you visit a page on this site and interact with the plug-in (e.g., by clicking the “like” button) or decide to leave a comment, the corresponding information is transmitted from your browser directly to the social networking platform (in this case Facebook) and stored by it. For information about the purpose, type and manner of collection, processing, use and storage of personal data by the social network platform, as well as how to exercise your rights, please see the social network’s privacy policy.
15. Links to third-party sites
From this site it is possible to connect through dedicated links to other third party websites. The Controller declines any responsibility with regard to the possible management of personal data by third party sites and with regard to the management of authentication credentials provided by third parties.
16. Cookies
Cookies are packets of information sent by a web server (e.g. the site) to the user’s Internet browser, automatically stored by the latter on the computer and automatically sent back to the server each time the site is accessed. For any information on the characteristics, types, methods of use, and options for removing, deleting or disabling cookies on the website, please refer to the specific Cookie Policy.
| The Data Controller FOR ALL srl |
To contact us
FOR ALL srl, based in Via 8 Marzo, 10/12 – 37012 Bussolengo (VR) is pleased to receive comments regarding this privacy policy.
Please contact us at the following address: info@for-all.it