Notice on the processing of personal data (Italian Legislative Decree 196/2003)
This page describes the methods of handling the personal data of users who browse the site www.pro-activa.it and fill out registration forms there, in compliance with the provisions of Article 13 of Italian Legislative Decree No. 196/2003 – Code on the protection of personal data.
The ‘DATA CONTROLLER’
The ‘data controller’ is Proactiva, in the person of the pro tempore legal representative.
DATA PROCESSING LOCATION
The personal data acquired through the site in question are processed at Proactiva’s registered office and handled exclusively by the company’s technical personnel in charge of processing.
PURPOSE OF THE PROCESSING
The personal data acquired through the site are processed in order to respond to requests for information, to acquire contacts with potential clients and to send informative newsletters. No personal data acquired through the site are communicated or disclosed to third parties.
TYPES OF DATA PROCESSED
Browsing data
The computer systems underlying the website’s functioning acquire, during normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected for the purpose of being associated with identified persons, but by its very nature could allow users to be identified through processing and matching with information held by third parties.
This category of data includes the IP addresses or domain names of the computers users use to connect to the site, the addresses of the requested resources in URI (Uniform Resource Identifier) notation, 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 from the server (successful, error, etc.), and other parameters related to the user’s operating system and computer environment.
This data is solely used to keep track of the traffic experienced by the site, to obtain anonymous statistical information on the use of the site and to check its correct functioning. This data could also be used to ascertain responsibility in the case of any computer crimes committed against the site.
Data provided voluntarily by the user
The voluntary sending of email messages to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, which is needed to respond to requests, and any other personal data included in the message.
The voluntary completion of web forms (field forms) with certain minimum personal data entails the collection of such user-entered data in the form of a database and their retention until the data subject requests their erasure (pursuant to Article 7 of the Privacy Code).
Cookies
This website does not use profiling cookies, as defined by the Provision of the Italian Data Protection Authority of 8 May 2014 ‘Identification of simplified methods for the notice and acquisition of consent for the use of cookies’, for transmitting personal information, nor does it use persistent cookies of any kind or systems for tracking users.
The use of technical cookies (session, analytics or functionality, again pursuant to the above Provision) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe and efficient browsing of the site (e.g. allowing a purchase to be made or authentication to access reserved areas); collecting information in aggregate form on the number of users and how they visit the site; to allow users to browse according to a series of selected criteria (e.g. language, products selected for purchase) in order to improve the service provided to them.
The use of these cookies on this site avoids the use of other IT techniques that could be detrimental to the confidentiality of users’ browsing, and does not allow the user’s personal identification data to be acquired.
OPTIONAL NATURE OF PROVIDING DATA
Apart from what is specified for browsing data, the user can freely choose whether or not to provide personal data. However, failure to provide data may make it impossible to obtain what is requested.
PROCESSING METHODS
Personal data is processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorised access.
RIGHTS OF DATA SUBJECTS
Those to whom the personal data refer have the right at any time to obtain confirmation of whether or not such data exist and to know their content and origin, verify their accuracy or ask for them to be supplemented, updated or rectified (see, for complete details, Article 7 of Italian Legislative Decree No. 196/2003).
Pursuant to the same article, which is reproduced in full below, the data subject has the right to request erasure, transformation into anonymous form or blocking of data processed in violation of the law, and in any case to object for legitimate reasons to their processing. Requests should be addressed to the Data Controller.
This text constitutes this site’s ‘Privacy Policy’, which will be subject to updates.
Article 7 of Italian Legislative Decree 196/2003 (Right to Access Personal Data and Other Rights)
1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
2. A data subject shall have the right to be informed:
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
3. A data subject shall have the right to obtain:
a) updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
4. A data subject shall have the right to object, in whole or in part:
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
Privacy Notice
Notice to the visitor issued by Proactiva pursuant to Article 13 of Italian Legislative Decree 196/2003
Whereas
as a result of you completing the forms on this site, our company will collect and process some of your personal data;
the Privacy Code (Italian Legislative Decree 196/2003) defines the following concepts in this regard:
- Processing: any operation, or set of operations, carried out with or without the help of electronic or automated means, concerning the collection, recording, organisation, keeping, interrogation, elaboration, modification, selection, retrieval, comparison, utilisation, interconnection, blocking, communication, dissemination, erasure and destruction of data;
- Personal data: any information relating to natural or legal persons, bodies or associations that are or can be identified, even indirectly, by reference to any other information including a personal identification number;
given the above, pursuant to Article 13 of Italian Legislative Decree 196/2003 (Privacy Code),
we inform you that the undersigned company will collect and process your personal data in accordance with the following:
a) general purposes: the data will be processed to satisfy your requests, to correctly perform bureaucratic, accounting, tax, commercial and business activities required by law and in any case strictly inherent to the relationships in place;
b) ‘direct marketing’ purposes: your data (not sensitive) may also be used, exclusively subject to your optional, specific and explicit consent which is revocable at any time, to send advertising communications by post, email, fax, SMS, MMS and the like; after expressing consent, it is in any case your right to object, at any time and without charge, to the processing of your data for this purpose (pursuant to Article 7 of Italian Legislative Decree 196/2003);
c) optional provision: the provision of your data is optional and not mandatory; refusal to provide the data or complete objection to their processing for the purposes referred to in point a) may in any case make it impossible to satisfy some of your requests; refusal of the data being used for the purposes referred to in point b) will not have any consequence on existing relationships;
d) data retention periods: your data will be stored by our company in compliance with the maximum periods provided for by current legislation.
e) methods: the data will be processed with both paper and electronic/computer/telematic tools/media, in full compliance with the law, according to the principles of lawfulness and correctness and such as to protect its confidentiality;
f) dissemination: your data will not be disclosed to third parties under any circumstances.
g) rights of the data subject: you have all the rights enshrined in Article 7, which is referred to for complete details;
h) company data processors and persons in charge of processing: the data will be processed exclusively by a limited number of specifically authorised company persons in charge of processing (administration, technical support, sales office, etc.);
i) data controller and data processor: the data controller is the undersigned company Proactiva, based in Milan, Via Olmetto 17, in the person of the pro tempore legal representative; any request for clarifications or information can be addressed to info@pro-activa.it.
This notice may be supplemented, orally or in writing, with additional elements and indications to better respond to any of your “Privacy” information requirements and to satisfy evolving legislation.
