The purpose of this Policy is to inform the user about the methods of personal data processing concerning him.
Acotel Group S.p.A. in line with the Regulation (UE) 2016/679 (hereinafter “GDPR”), intends to guarantee the privacy and security of personal data of each visitor in accordance with the provisions of this Policy.
This policy is intended as information pursuant Articles 13 and 14 of the GDPR.
The data controller of the processing is Acotel Group S.p.A., P.le Konrad Adenauer, 3, 00144 ROMA, C.F./P.IVA 06075181005.
Within the Company, the data concerning the visitors to the site will be processed by employees who act as appointees who operate as Processing Authorizers under the direct authority of the Data Controller and duly instructed by the Data controller.
In addition to the employees of the data controller, the processing of personal data may also be carried out by third parties, to whom the company entrusts certain activities (or part of them) related to or instrumental to the performance of the processing or the provision of services offered (e.g maintenance of Web Site). In this case, the same subjects will operate as independent Data Controllers, Co-Data Controller, or will be appointed as Data Processors.
TYPOLOGY OF DATA PROCESSED
The website offers informative and sometimes interactive content. During the navigation of the website, the data controller may acquire information about the visitor, in the following ways:
- Navigation Data
Information systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose 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 the addresses of the websites from which the access was made, information on the pages visited by users within the site, the time of access, the stay on individual page, the analysis of internal path and other parameters to the operating and computer environment of the user.
- Additional data categories
Personal data expressly provided by users, will be communicated to third parties only if the communication is necessary to accomplish the user’s requests, without prejudice to what is provided in the specific policies of individual services.
LEGAL BASIS AND PURPOSE OF PROCESSING
The data controller shall process the personal data deriving from the navigation of the Web site and those that the user has voluntarily provided in connection with the use of the Website itself. In particular, personal data may be used for the following purposes and in accordance with the following legal basis:
- • Providing the services and functions of the website, as well as verification of the correct functioning and improvement of the browsing experience. For this purposes, Acotel Group S.p.A uses a third-party tool (i.e. Google Analytics) for statistical and marketing purposes only. However, the data is managed in a completely anonymous form. These data are used only to obtain statistical information not associated with any user identification data on the use of the Site to check its proper functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site.
Legal basis for the processing of the so-called navigation data is the legitimate interest of the owner to allow a correct use of the contents of the website
- • Receiving of requests made by the user when filling the contact form (personal data acquired are: name, telephone number, e-mail address, as well as any specific content included in the body of the message). The legal basis for the processing of data voluntarily provided by the user is the consent freely give by the user in the margin of the possible filling of the contact form. With reference to such data, it should be noted that the same are used for the sole purpose of responding to requests received and are not communicated to third parties. The use is, in fact, the sole owner of his data and can request its modification or cancellation at any time: see below the section “rights of the data subject”.
Furthermore, the Data controller will not use the data provided for purposes other that those listed above, to which the user concerned has adhered, and only within the limits indicated from time to time in any further information accompanying the different, specific service requested by the user
METHOD OF PROCESSING
The data are processed by the Data Controller and by persons authorized to process them under the authority of the same mainly using electronic and manual systems, according to the principles of correctness, loyalty and transparency provided for by the applicable regulations and protecting the confidentiality of the data through technical and organizational security measures, to ensure an adequate level of security.
We inform you that the data relating to the navigation logs, if recorded, will be kept by the data controller for a period of 20 days.
The data voluntarily provided by the data subject are kept for the time strictly necessary to process the requests made by the latter to data controller, provided that it is not necessary to keep them further to defend or enforce a right or to fulfil any further legal obligations or orders from the authorities.
EXTRA-UE DATA TRANSER
Pursuant to art. 44 of the GDPR, the owner may transfer his/her personal data to Third Parties located in countries outside the European Union or the European Economic Area.
In such case, the Data Controller shall ensure the adoption of adequate safeguards (such as the signing of standard contractual clauses approved by the EU commission) with the foreign company receiving the data; such clauses shall ensure a level of data protection corresponding to that provided for by European legislation.
RIGHTS OF DATA SUBJECTS
By means of a communication to be sent to Acotel Group S.p.A, P.le Konrad Adenauer, 3, 00144 ROMA), or alternatively to the address firstname.lastname@example.org may at any time exercise, pursuant to articles 15 to 22 of EU Regulation no. 2016/679, the right to:
- Ask for confirmation that your personal data is being processed or not and to obtain access to the same;
- Obtain information about the purposes of processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be communicated and, where possible, the storage period;
- Obtain correction, deletion of data;
- Obtain treatment limitation;
- Obtain the portability of data, i.e. receive them from a data controller, in a structured format, commonly used and readable by automatic device, and transmit them to another Data Controller without hindrance;
- Oppose the processing at any time and even in the case of processing for direct marketing purposes;
- Opposing an automated decision making process concerning individuals, including profiling;
- Revoke consent at any time without prejudice to the lawfulness of processing based on consent given before revocation, whether in the case of processing of personal data or particular categories of personal data;
- File a complaint to a supervisory authority;
In compliance with art.19 of EU Regulation no. 2016/679, the Data Controller shall inform the recipients to whom the personal data have been communicated of any corrections, cancellations or limitations to the processing requested, where this is possible.
User can also contact the Data Protection Officer (DPO) of the Data Controller, whose contact details are: Shibumi Srl in the appointed person of Avv. Lapo Curini Galletti, e-mail: email@example.com .
MilanVia Bisceglie, 76
20152 Milan MI
Tel. +39 02.870.121.01
Fax +39 02.870.121.02
RomeP-le Konrad Adenauer
00144 Rome RM
Tel. +39 06.8366.5111
Fax +39 06.8366.5100
LecceVia Corte dei Mesagnesi, 30
73100 Lecce LE