PRIVACY POLICY
updated as per EU Reg 2016/679
(European regulation on the protection of personal data)
1) INTRODUCTION
Firmiana S.r.l. takes the user's privacy seriously and is committed to respecting it. This privacy policy ("Privacy Policy") describes the processing of personal data carried out by Firmiana S.r.l. through the website www.firmiana.it (Website) and the related commitments undertaken along the same line by the Company. Firmiana S.r.l. may process your personal data when you visit the Website and use the services and features on the Website. In the sections of the Website where the personal data of the user is collected, a specific information is normally published as per art. 13/15 of the EU Reg. 2016/679. If required by the EU Reg. 2016/679 the user's consent will be asked before proceeding to the processing of his / her personal data. If the user provides personal data of third parties, he must ensure that the communication of the data to Firmiana S.r.l. and the subsequent processing for the purposes specified in the applicable privacy policy complies with the EU Reg. 2016/679 and with the applicable law.
2) TYPES OF DATA PROCESSED
The visit and consultation of the Website do not generally involve the collection and processing of personal data of the user except for navigation data and cookies as specified below. In addition to the so-called "navigation data" (see below), personal data voluntarily provided by the user may be processed when the latter interacts with the functionality of the Website or requests to use the services offered on the Website. In compliance with the Privacy Code, Firmiana S.r.l. could also collect the personal data of the user from third parties in the performance of its activity.
3) COOKIES AND NAGIVATION DATA
In accordance with the provision of the Guarantor for the protection of personal data of May 8th 2014, on "Identifying the simplified procedures for the disclosure and the acquisition of consent for the use of cookies", Firmiana S.r.l. intends to inform the user of the following.
GENERAL INFORMATION ON COOKIES
When you log in to Firmiana S.r.l. or use one of our services, our system may set or read cookies and/or other types of identifiers for the browser and/or device you are using.
A cookie is a small text file that is stored on the computer of someone who views a website in order to record some information about the visit and to create a system to recognize the user even later on. The identifiers of the devices, however, are generated by collecting and processing some information such as the IP address and / or the user agent (browser version, type and version of the operating system) or other characteristics of the device, again in order to reconnect certain information to a specific user.
A website can set a cookie on the browser only if the preferences configured for the latter allow it. It is important to know that a browser can allow a specific website to access only the cookies set by it and not those set by other websites: there is no risk for your privacy in this regard.
ACTIVITIES RELATED TO COOKIES AND OTHER SIMILAR TECHNOLOGIES
Firmiana S.r.l. uses cookies or other type of identifiers for a variety of reasons, including:
Firmiana S.r.l. DOES NOT use any profiling cookies directly: the only cookies generated and managed directly by Firmiana S.r.l. are the so-called technical cookies (which are used exclusively to provide the services offered to the public correctly) and, in an extremely limited way, analytics cookies (which are used to count the number of readings on the various pages of the website and/or for other statistical purposes). However, we inform users that profiling cookies could be generated through our pages by third parties (Ref. "Cookies of other companies").
COOKIES OF OTHER COMPANIES
Firmiana S.r.l. integrates, within its pages, third-party services that may set and use their own cookies and/or similar technologies. The use of such cookies and similar technologies by these firms is governed by the privacy policies of those companies and not by this policy since Firmiana S.r.l. is totally unrelated to the management of these tools and to the processing of data deriving from them.
We provide below a list (not exhaustive) of some of the partner companies that may use cookies while browsing the site of Firmiana S.r.l .:
Google Analytics (policy)
Google+ (policy)
Facebook (policy)
YouTube (policy)
GOOGLE ANALYTICS COOKIES
This website uses the services offered by Google Analytics in order to have complete and reliable statistics about the use of the website itself. In order to ensure the privacy of users as strictly as possible, we communicate that we have carried out anonymization of the IP (therefore Google Analytics will make anonymous the IP address of the user/visitor as soon as this will be technically possible in the most upstream step of the network where data is collected).
The Data Controller also informs that it has accepted the Amendment on data processing (Google Analytics Data Processing Amendment) made available by Google Analytics in compliance with the Directive 95/46/EC. In particular, by virtue of this amendment, Google guarantees that it will process personal data recorded through the service only within the limits of instructions given by the website operator and not to share them with other Google services unless this has been explicitly requested and authorized by the owner of the website himself.
In view of the above, we inform the user that the advertising and data sharing options with Google have not been activated and that Google Analytics has not been connected to any additional services: therefore, the processing is carried out merely for the sake of statistical purposes and therefore, on the basis of what is explicitly dictated by the Privacy Guarantor, Analytics cookies have been treated as technical cookies and as such, have been installed without the prior consent of the user.
DEACTIVATE COOKIES
You can configure your browser to accept or reject all cookies or particular types of cookies (for example, third-party cookies) or you can choose to be notified whenever a cookie is set inside your computer.
It is important to know that the refusal of all cookies could prevent you from using the products and services of Firmiana S.r.l. that require your access, through username and password, to areas reserved for registered users. In fact, all these services require cookies in order to function correctly and, consequently, the eventual blocking of cookies would make it impossible to use them.
Below are the instructions for the most popular browsers in order to make a custom configuration about cookies:
Microsoft Internet Explorer
click on "Tools" at the top of the browser window;
select "Internet Options";
click on the "Privacy" tab;
to activate cookies, the privacy level must be set to "Medium" or below; by setting the Privacy level above "Medium" the use of cookies will be disabled.
Mozilla Firefox
click on "Tools" at the top of the browser window;
select "Options";
select the "Privacy" icon;
click on "Cookies";
select or not the entry "Accept cookies from websites" and "Accept third-party cookies";
Google Chrome
click the menu icon;
select "Settings";
at the bottom of the page, select "Show advanced settings";
in the "Privacy" section, select "Content settings";
select or not the entry "Prevent sites to set data".
Apple Safari
click on the "Safari" tab at the top of the browser window;
select the "Preferences" option;
click on "Privacy";
set your choice under "Cookies and website data".
CANCELLATION OF COOKIES OF FIRMIANA S.R.L.
Firmiana S.r.l. uses third-party cookies. We cannot provide you with a fast way for deleting these cookies because, technically, this is only possible using the appropriate browser cleaning features.
4) STORAGE OF PERSONAL DATA
Personal data are stored and processed through computer systems owned by Firmiana S.r.l. and managed by Firmiana S.r.l. or by third-party technical service providers; for more details, please refer to the "Policy of accessibility of personal data" section below. The data is processed exclusively by specifically authorized personnel, including personnel assigned to carry out extraordinary maintenance operations.
5) PURPOSES AND METHODS OF DATA PROCESSING
Firmiana S.r.l. may process the user's common and sensitive personal data for the following purposes: use by users of services and features on the Website, management of requests and reports from the members, sending newsletters, management of applications received through the Website, etc. Moreover, with the further and specific optional consent of the user, Firmiana S.r.l. may process personal data for marketing purposes, that is, to send to the user promotional material and / or commercial communications relating to the Company's services, at the addresses indicated, either through traditional methods and/or contact means (such as paper mail, telephone calls with operator, etc.) either through automated methods (such as communications via Internet, fax, e-mail, text messages, applications for mobile devices such as smartphones and tablets -cd. APPS-, social network accounts - eg. via Facebook or Twitter-, phone calls with automated attendant, etc.).
Personal data are processed both in paper and electronic form and entered into the company information system in full compliance with EU Reg. 2016/679, including security and confidentiality profiles and based on principles of correctness and lawfulness of processing. In compliance with EU Reg. 2016/679, the data are kept and stored until 25 May 2118.
6) SAFETY AND QUALITY OF PERSONAL DATA
Firmiana S.r.l. commits to protect the security of the user's personal data and complies with the security provisions of the applicable law in order to avoid data loss, illegitimate or illegal use of data and unauthorized access to them, with particular reference to the Disciplinary Technician in the field of minimum security measures. Furthermore, the information systems and computer programs used by Firmiana S.r.l. are configured in such a way as to minimize the use of personal and identifying data; these data are processed only for the achievement of the specific purposes pursued from time to time. Firmiana S.r.l. uses multiple advanced security technologies and procedures to promote the protection of users' personal data; for example, personal data is stored on secure servers located in places with secure and controlled access. The user can help Firmiana S.r.l. to update and keep correct their personal data communicating any changes related to their address, their qualification, contact information, etc.
7) DATA COMMUNICATION AND ACCESS
The users’ personal data may be communicated to:
all subjects to whom access to such data is recognized by virtue of regulatory provisions;
to our collaborators, employees, as part of their duties;
to all those natural and/or legal persons, public and/or private when the communication is necessary or functional to the performance of our activity and in the manner and for the purposes described above;
8) NATURE OF PERSONAL DATA CONFERMENT
The conferment of some personal data by the user is mandatory to allow the Company to manage communications, requests received by the user or to contact the user himself to respond to his request. This type of data is marked with an asterisk symbol [*] and in this case, the conferment is mandatory to allow the Company to process the request which, in default, cannot be processed. On the contrary, the collection of other data not marked with an asterisk is optional: failure to provide data will not entail any consequences for the user.
The conferment of personal data by the user for marketing purposes, as specified in the section "Purposes and methods of data processing" is optional and the refusal to provide them will have no consequence. The consent granted for marketing purposes is intended to be extended to the sending of communications carried out through automated and traditional methods and / or contact means, as above exemplified.
9) RIGHTS OF THE INTERESTED PARTY
9.1 Article 15 (right of access), 16 (right of rectification) of EU Reg. 2016/679
The interested party has the right to obtain from the data controller confirmation that it is or is not undergoing the processing of personal data concerning him and in this case, to obtain access to personal data and to the following information:
a) the purposes of the processing;
b) the categories of personal data in question;
c) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if recipients are of third countries or international organizations;
d) the foreseen storage period of the personal data provided or, if not possible, the criteria used to determine this period;
e) the existence of the right of the interested party to request the data controller to rectify or delete personal data or limit the processing of personal data concerning him or to oppose their treatment;
f) the right to lodge a complaint with a supervisory authority;
g) the existence of an automated decision-making process, including profiling and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the interested party.
9.2 Right pursuant to art. 17 of EU Reg. 2016/679 - right to cancellation ("right to oblivion")
The interested party has the right to obtain from the data controller the deletion of personal data concerning him without undue delay and the data controller is obliged to cancel the personal data without undue delay if one of the following reasons exists:
a) personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;
b) the interested party revokes the consent on which the processing is based in accordance with Article 6 (1) (a) or Article 9 (2) (a) and whether there is no other legal basis for the processing;
c) the interested party opposes the processing pursuant to Article 21 (1) and there is no legitimate overriding reason to proceed with the processing or opposes the processing pursuant to Article 21 (2);
d) personal data have been unlawfully processed;
e) personal data must be deleted to fulfill a legal obligation foreseen by the Union or the Member State law that applies to the data controller;
f) personal data have been collected in relation to the offer of information society services referred to in Article 8, paragraph 1 of EU Reg. 2016/679
9.3 Right referred to in art. 18 Right of limitation of processing
The interested party has the right to obtain from the data controller the limitation of processing when one of the following hypotheses occurs:
a) the interested party disputes the accuracy of personal data, for the period necessary for the data controller to verify the accuracy of such personal data;
b) the processing is illegal and the interested party opposes the cancellation of personal data and asks instead that its use is limited;
c) although the data controller no longer needs it for processing purposes, personal data are necessary for the interested party to ascertain, exercise or defend a right in court;
d) the interested party opposed the treatment pursuant to article 21, paragraph 1, EU Reg. 2016/679 waiting the verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party.
9.4 Right referred to in Article 20 Right to data portability
The interested party has the right to receive, in a structured format, commonly used and readable by automatic device, the personal data concerning him / her provided to a data controller and has the right to transmit such data to another data controller without hindrance by the data controller
10) REVOCATION OF CONSENT TO PROCESSING
The interested party has the right to withdraw consent to the processing of his personal data by sending a registered letter with return receipt to the following address: Firmiana S.r.l. - Via Flaminia 29 - 01033 Civita Castellana (VT) Italy, accompanied by a photocopy of his identity document, with the following text: << revocation of consent to the processing of all my personal data >>. At the end of this operation the personal data will be removed from the records as soon as possible.
If you would like more information on the processing of your personal data, or exercise the rights referred to in paragraph 7 above, you can send a registered letter with return receipt to the following address: Firmiana S.r.l. - Via Flaminia 29 - 01033 Civita Castellana (VT) Italy. Before we can provide you or modify any information, we may need to verify your identity and you may need to answer some questions. An answer will be provided as soon as possible.
11) HOLDER AND RESPONSIBLE OF TREATMENT
The data controller is Firmiana Srl, a company incorporated under Italian law with registered office in Italy Via Flaminia, 29 - 01033 Civita Castellana (VT). Currently, some supervisors charged with processing your data are as follows:
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