PRIVACY POLICY
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Subject: Information on the processing of personal data
Dear user,
Pursuant to (Italian) Legislative Decree no. 196 of 30 June 2003, ‘Personal Data Protection Code’ (hereinafter, the ‘Privacy Code’) and Article 13 of Regulation (EU) 2016/679 of 27 April 2016 (hereinafter, the ‘Regulation’), in relation to the processing of your personal data, we inform you of the following:
1. Type of data and purpose of processing.
The type of data requested or otherwise acquired includes but is not limited to data identifying email addresses or accounts, data entered by the user and relating to the services requested.
The IT systems and software procedures used to operate the Protos S.p.A. website (hereinafter, also ‘Protos’ or the ‘Company’) acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified interested parties, but by its very nature could, 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 by users who connect to the site, the URI (uniform resource identifier) addresses of the resources requested, the size of the file obtained in response, and other parameters related to the user’s operating system and IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation, and are deleted immediately after processing.
2. Methods of data processing.
Processing is carried out manually, i.e. in paper, computer and electronic format for reasons related to the purposes indicated above, in compliance with the obligations provided for by laws, regulations, EU legislation and, in any case, in such a way as to guarantee the security and confidentiality of the data.
With regard to security, specific measures are put in place to prevent data loss, unlawful or incorrect use, and unauthorised access. In any case, the processing of data is based on the principles of correctness, lawfulness and transparency, guaranteed, in particular, by the Service Provider’s adoption of the minimum security measures set out in Article 32 of the Regulation.
3. Data retention periods and other information.
The personal data subject to processing is stored in accordance with the principle of proportionality and until the purpose of the processing is fulfilled or until the data subject withdraws his/her specific consent, and in any event:
- For the period of time necessary to fulfil legal obligations (e.g. document storage);
- For the time strictly necessary for the provision of any services requested by the user;
- For as long as is strictly necessary to achieve the purposes for which they are processed, as per point 1;
4. The Data Controller is:
Protos S.p.A., with registered office in Via Livenza 3, 00198, Rome, Italy,
which may also use external subjects to perform all or part of the activities relating to, resulting from or in any case connected with the processing of personal data for the purpose of carrying out the activities referred to in point 1, including professionals registered with professional bodies who, in their capacity as data processors, provide for the performance of legal and/or contractual obligations, such as, purely by way of example, accounting, administrative and tax obligations, in accordance with the object and purpose of processing.
5. The Data Processor is:
Pursuant to Article 28 of the Regulation, the Controller may appoint one or more Data Processors. The Data Processor shall be selected from parties who, by virtue of their experience, capacity and reliability, are able to guarantee the proper performance of the task.
The appointed Processor assists the Controller in fulfilling legal obligations, developing strategies related to the purposes and methods of data processing and data security.
Information concerning the Data Processor or the updated list of Data Processors is available at the registered office of the Data Controller.
The email address for the exercise of the rights set out in Article 13, paragraph 2, letters (b) and (d), and Articles 15, 16, 17, 18, 19, 20, 21 and 22 of the Regulation (also with regard to requests addressed to third parties to whom data have been communicated with the specific consent of the data subject) is privacy@protos-spa.it.
5. Place of data processing.
Personal data is processed at the Company’s registered office, or at the places where any appointed Data Processors operate, and are handled only by technical personnel in charge of processing or appointed to carry out specific operations. The personal data provided by users who request information material are used only to perform the service requested.
Further information in relation to the processing of personal data may be requested at any time from the Data Controller using the contact information.
6. Nature of data provision.
The provision of data is optional, unless required by law or contractual provisions. Refusal to provide personal data may make it impossible to perform the services.
In the course of normal operation, the IT systems and software procedures used to operate the site may acquire certain personal data, the transmission of which is implicit in the use of Internet communication protocols (such as Internet domain and IP protocol, type of browser and computer operating system used, date, time and length of stay on the site, pages viewed, and any search engine from which the site is accessed).
This is information that by its very nature may make it possible to identify users, by virtue of processing and association with data held by third parties. This category of data includes the IP addresses or domain names of the computers used by users browsing the site, 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. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its operation, and are deleted immediately after processing.
7. Communication and dissemination of data.
For the purpose of performing the services referred to in point 1, personal data may be disclosed to third parties, such as:
- Public Administrations requesting information from the service provider in accordance with legal obligations;
- Service companies (administrative, accounting, IT or archiving) and insurance companies used by the company;
- Protos collaborators and employees, specifically appointed for this purpose and within the scope of their duties.
Apart from the abovementioned cases, personal data will not be subject to dissemination.
8. Transfer of data abroad.
The data may be transferred, again for the purposes set out in point 1, to countries in the European Union and to non-European Union countries, mainly within the context of relations with the Company’s business partners.
The free circulation of personal data between Member States takes place in accordance with the provisions of the Privacy Code and the Regulation, i.e. in free circulation, without prejudice, however, to the adoption of possible measures in the event of transfers of data aimed at circumventing its provisions.
Any transfer to third countries will be protected subject to obtaining express written consent, or subject to authorisation by the Italian Data Protection Authority on the basis of adequate guarantees for the protection of the data subject’s rights, also provided contractually.
9. Modifications.
The Data Controller reserves the right to make changes to this policy at any time, which shall be automatically effective, unless otherwise specified.
10. Third-party cookie management.
The site uses the following technical cookies:
Analytics: This site uses cookies from the Google Analytics service provided by Google Inc. in order to process statistical analyses of how users browse the site. User IP addresses are anonymised before being saved by the Google Analytics service, a technical cookie required to keep track of the consent given by the user.
11. Cookie policy
11.1 Definitions.
Cookies are small text files that the sites visited by the user send to his/her device (usually to the browser), where they are saved and then sent back to the same sites on the next visit.
Cookies are used for different purposes: performing computer authentication, monitoring sessions and storing information on specific configurations concerning users accessing the server.
Given that there are no technical characteristics that differentiate them from one another, in order to arrive at a proper regulation of these devices, it is necessary to distinguish them on the basis of the purposes pursued by those who use them.
Therefore, in implementing the provisions contained in Directive 2009/136/EC, pursuant to Article 1, paragraph (5), letter (a) of (Italian) Legislative Decree no. 69 of 28 May 2012 amending Article 122 of the Privacy Code, the legislature has established the obligation to obtain the prior and informed consent of users for the installation of cookies used for purposes other than purely technical ones.
11.2 Categories:
(a) Technical cookies
Technical cookies are those used only for browsing and to facilitate user access and use of the site. Technical cookies are essential, for example, to access Google or Facebook without having to log in to all sessions.
They are not used for any other purpose and are normally installed directly by the website owner or operator. They can be subdivided into navigation or session cookies that guarantee normal browsing and use of the website. In turn, they can be subdivided into:
– Navigation or session cookies, which guarantee normal browsing and use of the website (allowing, for example, to make a purchase or perform authentication to access restricted areas);
– Analytics cookies, assimilated to technical cookies where they are used directly by the website operator to collect information, in aggregate form, on the number of users and how they visit the site;
– Functionality cookies that allow the user to browse based on series of selected criteria (e.g. language, products selected for purchase, etc.) in order to improve the service rendered.
(b) Profiling cookies.
Profiling cookies are aimed at creating user profiles and are used to send advertising messages in line with the preferences expressed by the user while browsing the web. Due to the particular invasiveness that such cookies may have in the private sphere of users, European and Italian legislation provides that the user must be adequately informed about the use of such cookies and express his/her valid consent to their use.
11.3 Procedures for approving cookies.
No consent is required for the installation of technical cookies, whereas profiling cookies can only be installed on the user’s device after the user has given consent following simple notification.
When connecting to the website for the first time, the user must immediately see a banner in the foreground containing a short information notice, a request for consent and a link to the more extensive information on what profiling cookies are and how they are used on the site.
In addition, the banner must be of a size that constitutes a perceptible discontinuity in the use of the contents of the web page and must specify that the site uses profiling cookies, including those of third parties (where this is the case), and that in the extended information notice it is possible to refuse consent to any installation of any cookie, with indication that continued browsing by accessing another area of the site or selecting an element of the same involves the provision of consent to use of the cookie. The banner must be able to be deleted only with an active action by the user.
11.4 Cookies used on the site.
For maximum transparency, listed below are a series of technical cookies and cases of specific operation on the site:
- Cookies installed directly on the user/contractor’s device (which will not be used for any further purposes), such as session cookies used for online bookings on the site, authentication cookies, personalisation cookies (e.g. for choosing the browsing language); these cookies remain active only for the duration of the session;
- Cookies used to statistically analyse visits to the site (so-called ‘analytics’ cookies), only if used for statistical purposes (and not for profiling or marketing purposes), and which collect information in aggregate form without the possibility of identifying the individual user. In these cases, the legislation in force requires that for analytics cookies, the data subject must be provided with a clear and adequate indication of the simple ways to object to their installation (including possible mechanisms for displaying the cookies in an anonymous form). The duration of analytics session cookies is * minutes.
11.5 How to disable cookies.
Most browsers allow you to delete cookies from your computer’s hard disk, block acceptance of cookies or receive a warning before a cookie is stored.
Therefore, for the removal of cookies we invite you to follow the instructions on the dedicated pages of the various browsers:
Chrome: https://support.google.com/chrome/answer/95647?hl=il
Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
Internet explores: https://windows.microsoft.com/it-it/windows7how-to-manage-cookies-in-internet-explorer-9
Safari: https://support.apple.com/kb/HT1677?viewlocale=it_IT (verification by site operator)
11.6 Disabling cookies.
If you block or delete a cookie, you may not be able to restore your previously specified preferences or personalised settings, and the site’s ability to personalise your experience will be limited.
11.2 Categories:
(a) Technical cookies
Technical cookies are those used only for browsing and to facilitate user access and use of the site. Technical cookies are essential, for example, to access Google or Facebook without having to log in to all sessions.
They are not used for any other purpose and are normally installed directly by the website owner or operator. They can be subdivided into navigation or session cookies that guarantee normal browsing and use of the website. In turn, they can be subdivided into:
– Navigation or session cookies, which guarantee normal browsing and use of the website (allowing, for example, to make a purchase or perform authentication to access restricted areas);
– Analytics cookies, assimilated to technical cookies where they are used directly by the website operator to collect information, in aggregate form, on the number of users and how they visit the site;
– Functionality cookies that allow the user to browse based on series of selected criteria (e.g. language, products selected for purchase, etc.) in order to improve the service rendered.
(b) Profiling cookies.
Profiling cookies are aimed at creating user profiles and are used to send advertising messages in line with the preferences expressed by the user while browsing the web. Due to the particular invasiveness that such cookies may have in the private sphere of users, European and Italian legislation provides that the user must be adequately informed about the use of such cookies and express his/her valid consent to their use.
11.3 Procedures for approving cookies.
No consent is required for the installation of technical cookies, whereas profiling cookies can only be installed on the user’s device after the user has given consent following simple notification.
When connecting to the website for the first time, the user must immediately see a banner in the foreground containing a short information notice, a request for consent and a link to the more extensive information on what profiling cookies are and how they are used on the site.
In addition, the banner must be of a size that constitutes a perceptible discontinuity in the use of the contents of the web page and must specify that the site uses profiling cookies, including those of third parties (where this is the case), and that in the extended information notice it is possible to refuse consent to any installation of any cookie, with indication that continued browsing by accessing another area of the site or selecting an element of the same involves the provision of consent to use of the cookie. The banner must be able to be deleted only with an active action by the user.
11.4 Cookies used on the site.
For maximum transparency, listed below are a series of technical cookies and cases of specific operation on the site:
- Cookies installed directly on the user/contractor’s device (which will not be used for any further purposes), such as session cookies used for online bookings on the site, authentication cookies, personalisation cookies (e.g. for choosing the browsing language); these cookies remain active only for the duration of the session;
- Cookies used to statistically analyse visits to the site (so-called ‘analytics’ cookies), only if used for statistical purposes (and not for profiling or marketing purposes), and which collect information in aggregate form without the possibility of identifying the individual user. In these cases, the legislation in force requires that for analytics cookies, the data subject must be provided with a clear and adequate indication of the simple ways to object to their installation (including possible mechanisms for displaying the cookies in an anonymous form). The duration of analytics session cookies is * minutes.
11.5 How to disable cookies.
Most browsers allow you to delete cookies from your computer’s hard disk, block acceptance of cookies or receive a warning before a cookie is stored.
Therefore, for the removal of cookies we invite you to follow the instructions on the dedicated pages of the various browsers:
Chrome: https://support.google.com/chrome/answer/95647?hl=il
Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
Internet explores: https://windows.microsoft.com/it-it/windows7how-to-manage-cookies-in-internet-explorer-9
Safari: https://support.apple.com/kb/HT1677?viewlocale=it_IT (verification by site operator)
11.6 Disabling cookies.
If you block or delete a cookie, you may not be able to restore your previously specified preferences or personalised settings, and the site’s ability to personalise your experience will be limited.
12.Rights of the data subject.
We inform you that Article 13, paragraph (2), letters (b) and (d), and Articles 15, 16, 17, 18, 19, 20, 21 and 22 of the Regulation, available at the link https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679, grant the data subject specific rights in relation to the processing of personal data, such as:
- The right to have confirmation of the existence or otherwise of personal data concerning him/her, as well as their communication;
- The right to know the origin of the data, the purposes and methods of processing, the logic applied in the case of processing carried out with the use of electronic instruments, the identification details of the data controller and data processor, as well as those to whom the data may be disclosed;
- The right to obtain the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as the updating, rectification or, where desired, the integration of data;
- The right to object, on legitimate grounds, to processing;
- The right to withdraw consent to the processing of his/her data, at any time, without prejudice to the lawfulness of processing based on the consent given before withdrawal, and to object at any time to processing for marketing and/or marketing-related profiling purposes (right to object under Article 21 of the Regulation)
The exercise of rights is not subject to any restriction.
To exercise your rights, email privacy@protos-spa.it.
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the Italian Data Protection Authority.
Rome, 16 October 2018
Protos S.p.A.