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STATEMENT ON PERSONAL DATA PROTECTION IN ACCORDANCE WITH THE ARTICLE  13 OF THE EU REGULATIONS 2016/679

CODE ON PERSONAL DATA PROTECTION
 

You will find herewith description of the web site arrangements in relation to processing of personal data of the users who visit this web site.

F.lli Zaffrani srl is conscious of importance of the personal data protection and undertakes to observe the directives and the norms referred to privacy matter that guarantee secure and confidential Internet navigation.

As far as it concerns data processing, the web site www.zaffrani.it (the “site”) user is invited to read with attention the present document, namely the rules that  F.lli Zaffrani srl observes when it comes to personal data collection and processing and, in particular, personal data supplied by the user him/herself  navigating the web site, using contact forms or information requests available on there.

The statement complies with the Article 13 of the EU Regulations 2016/679 regarding personal data protection of the users who interact with the web site F.lli Zaffrani srl, Processing Controller, available in telematic way at the address www.zaffrani.it.

The statement is also  valid for all web sites and services under domain www.zaffrani.it, but not for other web sites that can be eventually visited through the link.

The statement is also compliant with national and European legislation, the  Recommendation  n. 2/2001 of the Working Group, Article  29 referred to minimum requirements for online data collection in the European Union, in order to identify minimum requirements for online personal data collection and, in particular, modes, deadlines and nature of the information that Processing Controller shall supply to the users when the latter connect with the web pages, regardless the purpose of connection.

 

DATA PROCESSING CONTROLLER

Data Processing Controller is  F.lli Zaffrani srl, Via dell’Industria, 159, Corridonia (MC).

 

GENERAL PRINCIPLES OF PERSONAL DATA PROTECTION

Personal data processing is subject to the principles of legality, correctness, transparency, purpose and retention limitations, data minimization, accuracy, integrity and confidentiality. In particular:

  • process data exclusively for the purposes and according to the statement contents;
  • process data for which a prior explicit consent by the concerned user is necessary, only provided the relative consent has been given;
  • respect anonymity, enabling anonymous navigation on the web pages that do not require authentication, excepting automatic acquisition of navigation data;
  • provide third parties with the data, exclusively for accessory purposes related to supply of the required services and in other cases, excepting where it is allowed by the law, only if the concerned user gives his/her consent;
  • observe rights of the concerned users, accepting requests related to cancelation, modification or integration of the supplied data, objection to data processing related to supply of commercial or advertising information;
  • ensure correct and legitimate personal data management, observing privacy right of the concerned user, as well as undertake proper security measures to protect privacy, integrity and availability of the processed data;
  • ensure maximum transparency, supplying relative statements for each data collection.

 

TYPES OF PROCESSED DATA

By “personal datum” it is implied “any information concerning an identified or identifiable  physical person“ namely “concerned person”), with identifiable it is implied a physical person who can be directly or indirectly identified, with a particular reference to the name, ID number, location data, online identification or one or more elements typical for his/her physical, physiologic, economic, cultural or social  identity  (article 4 of the EU Regulations 2016/679).

 

Consequently, personal data are name, contact information and details, as well as any other information on the web site  user  that can be directly or indirectly obtained from them.

 

DATA SUPPLIED WILLINGLY BY THE USERS

Explicit and voluntary e-mailing at the addresses specified for various access channels of the web site www.zaffrani.it and filling in the available forms cause subsequent acquisition of the sender/user’s address and data, necessary to reply to the generated requests and required services.

Supply of such data is optional, explicit and voluntary and entails consequent acquisition of the sender’s address and other eventual personal data, necessary to reply to the requests.

F.lli Zaffrani srl will process such data presuming they are supplied by the user or by the entities who explicitly authorized the user to supply them on the proper legal basis that enables their processing. In  such case the user is an autonomous processing controller and takes the whole legal responsibility and fully indemnifies any claim or damages that third parties, whose personal data have been processed by the web site in breach of the current legislation, may ask to  www.zaffrani.it.

Anyway, F.lli Zaffrani srl invites the user to not supply any personal data which are not strictly necessary: some personal data can be processed only provided that the user gives his/her explicit consent and to the extent stated by the current legislation. Consequently, the Data Processing Controller points out importance to supply an explicit consent to certain types for personal data, whether the user decides to share such information.

Specific brief statements will be available on the site pages dedicated to the services upon request.

 

NAVIGATION DATA

IT systems and software procedures implemented for the web site www.zaffrani.it during its regular running acquire certain personal data, whose transfer is implicit for the use of Internet communication protocols.

It is about information which is not collected to be associated to the concerned identified users, but which for its nature may allow to identify the users through elaboration and associations with the data controlled by the third parties.

IP address or domain name of the users’ personal computers connected to Internet, URI addresses   (Uniform Resource Identifier)  of the requested resources, time of the requests, methods used to submit a request on the server, reply file dimensions, number codes that identify a reply status given by the server ( success, error etc), browser, operation system and other parameters related to operation system and to IT environment of the user take part of such data.

Such data are exclusively used with the purpose to get statistics information unlinked to any user’s ID datum on use of the web site and to control its regular running and are deleted after elaboration or, as maximum, within a week. The data may be used to check responsibility in case of IT offences or damages to the web site.

These data are saved in the systems of the  Data processing  Controller or the web site managers.

 

SYSTEM LOGS

Access to the web site, consulting the relative content and use of the available services allow the web server to register  automatically  so-called  “system LOGs”, namely the information that the user’s browser sends during navigation on the web site. Such information consists of the web pages required by the user, checked, modified or created documents, IP addresses, browser type, browser language, data and time of the  request.

 

STATISTICS DATA

Statistical analysis data allow the Processing Controller to monitor and analyze traffic data, meant to measure the site performance in terms of search, assessment of usability and interest. The data are supplied in aggregated or anonymous form, thus, there is no way to identify the user.

 

Google Analytics is a  navigation statistical analysis tool supplied by Google Inc. (“Google”).  On this web site Google Analytics is set up to reveal data anonymously, by anonymizing IP address of the user. The anonymization is enabled within the confines of the European Union state-members or in other countries which joint the Agreement on the European Economic Area. Only in certain cases  IP addresses will be sent to the servers of Google and shortened in the United States.

Collected data are related to the cookies and to the data on use of the web site: Google Analytics uses the user’s personal data, including data transferred to Google, when subscribing to other services, in order to track and analyze use of the web site, compile statistics reports and share them with other services  developed by Google.

Google may use personal data of the user to customize advertisement of its advertising network.

Data processing is carried out in the United States, based on the adequacy decision of the European Commission  named as “Privacy Shied” (http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/5306161),  which Google joins. Google Privacy policy: https://goo.gl/k4J1Nb.

Google offers an additional tool to disable data collection by Google Analytics (https://goo.gl/BdFny5).

 

COOKIES

This web site uses cookies in order to provide the users with a better navigation experience on the web site, as well as to optimize visits.

Please refer to the relative Statement, compliant  with the Privacy Authority Provision n. 229 of May 8, 2014: http://www.zaffrani.it/it/cookies-policy/

 

PURPOSE OF THE USERS’ DATA PROCESSING

Personal data willingly supplied by the web site users are processed for different purposes for which a consent may be needed:

 

Treatment purpose Legal base and consent to process
1. MANAGEMENT OF REQUESTS AND SUPPLY OF SERVICES
a)    Process eventual requests sent to us, for instance, by means of a message, email or snail mail to the details specified on the web site that entail acquisition of the address, also email one, of the user or the relative phone number necessary to reply to the requests, as well as other eventual personal data present in the relative communications. Processing is carried out to the extent of a Contract fulfillment of which the user is a Party or of precontractual measures adopted upon request by the user  (art. 6, comma 1, lett. B of the Regulations).

Consent s not necessary.

b)    Fulfill obligations required by the law, regulations and EU or National legislation, as well as by provisions coming from the authorities or from control and vigilance entities. Processing is necessary to comply with a legal obligation, to which F.lli Zaffrani srl is subject to (art. 6, comma 1, lett. a) of the Regulations).

Consent s not necessary.

 

c)      Prevent and identify any abuse concerning use of the web site or any fraudulent activity and, thu,s allow F.lli Zaffrani srl to defend themselves in trial.

 

One or more consent can be revoked at any time contacting F.lli Zaffrani srl  at the details for exercise of the rights specified in the end of the present privacy policy

 

PURPOSE OF NAVIGATION AND SYSTEM LOG DATA PROCESSING

Personal data, whose transfer is implicit for use of Internet and use of communication protocols, are processed only to collect anonymous statistical information on use of the web site, to control its correct running and protect IT systems that enable its running.

Data do not allow to identify the concerned users and are not linked to other sources that could allow assimilation to identify the users.

Such data, as the user’s IP address, may be also used to check responsibility in case of eventual IT offences and damages to the web site.

 

OBBLIGATION OR RIGHT TO SUPPLY DATA

Apart from the mentioned above data concerning navigation, the user  is free to supply personal data mentioned in the forms or signup procedures. Lack of supply of the data may cause non-fulfillment of a request or a service, as it is specified below in relation to the mentioned above purposes:

MANAGEMENT OF REQUESTS AND DELIVERY OF SERVICES

Supply of data  (marked as mandatory in the forms) is necessary for the purposes mentioned in the Item 1 and a refusal to supply them will make it impossible for  F.lli Zaffrani srl  to process orders or fulfill requests by the users and cause for them impossibility to use the services through  the web site.

Moreover, data processing for these purposes is necessary to comply with certain law obligations: personal data shall be processed as per the applicable legislation, including thier retention and trasnfer to the Authorities for accounting, fiscal and other reasons.

PROCESSING MODES

Personal data are processed through automatic tools, modes and procedures for the period strictly necessary to achieve the purposes they have been collected for and for the reasons specified in the present Statement.

In particular, processing is carried out by authorized personnel with electronic, IT or, anyway, automatic means, through e-mail and other remote communication techniques.

DATA RETENTION

The data are saved until it is strictly necessary in order to supply required services or for the period stated in the legislation in force.

In general, personal data supplied by the users not necessary anymore for the purposes for which they have been collected are immediately cancelled or made anonymous, excepting retention obligation required by the law or indicated otherwise by the concerned user.

Moreover, in order to protect its own interests, F.lli Zaffrani srl will process personal data for the period specified by the legislation, as per the Article  2947 of the Civil Code,  in particular, as far as it is necessary in order to protect interests of the Controller for eventual claims regarding provided services.

 

DATA SECURITY

Data Controller adopts specific security measures, proper and preventive ones, in order to preserve privacy, integrity, completeness, availability of the concerned user’s data, as well as to prevent from loss of data, from illegal or incorrect use or unauthorized access.

Anyway, the Controller is not responsible for false, incomplete information sent directly by the user ( for instance, correctness of an e-mail  or postal address or credit card details), as well as for information that concerns it and which has been supplied by a third party, even fraudulently.

 

DATA RECIPIENTS

Personal data  may be supplied to the entities which can access the data, in accordance with the law,  EU regulations or legislation, to the extent required by such norms.

To supply and manage services required by the user, the user’s personal data may be supplied to other entities, who are responsible and\or autonomous data controller (for instance, carriers or  Poste Italiane S.p.A., internet and email  providers  or providers of technical services which supply accessory services for the web site, entities that do assistance and consulting  in accounting, administration, legal, tax or debt collection field, as far as it concerns supply of services, to the employees authorized to process data and bound by privacy obligation, to the extent necessary to carry out their tasks for our Company and who act as responsible for processing and who are bound to privacy as well as by legal requirements.

Moreover, the data may be communicated to the entities, bodies or authorities as per law requirements, protection against abuse, frauds or orders issued by the Authorities.

Complete list of the mentioned above entities can be requested directly to F.lli Zaffrani srl. Personal data that have been collected are not widespread.

 

DATA PROCESSING PLACE

Data processing related to this web site is carried out in the mentioned above Controller’s Headquarters who avails of external providers for web site hosting service, or which are run by technical personnel authorized to data processing and, on occasion,  by maintenance personnel.

If necessary, the data may be treated by personnel in the Headquarters of the present Company.

Personal data will be saved on the server / database of the Controller situated in the European Union. Without prejudice to the mentioned above, the data will be not trasnferred outside of the European Union.

 

RIGHTS OF THE CONCERNED USERS

The concerned users whose data are processed as per the legislation in force, as per the Articles 15-22 of the EU Regulations 2016/679, are entitled to ask at any time to F.lli Zaffrani srl:

  • to have access to the personal data and addition information on their processing
  • to modify or to update the data
  • to delete the data

 

Moreover, the user can:

  • oppose processing,
  • ask to limit processing,
  • obtain his/her personal data in a structured, common and readable form for an automatic device,
  • revoke consent to process for the purposes, where it is applicable

 

As per and to the extent of the Legislation in force, the user has the right to submit a claim to the concerned Control Authorities (Personal Data Protection Authorities), whether personal data processing breaches the legislation.

The mentioned above rights can be exercised at any time by the concerned user, contacting F.lli Zaffrani srl, Via dell’Industria, 159, Corridonia (MC),  0733.281385, email info@zaffrani.it.

 

MODIFICATIONS AND UPDATES

The present privacy policy is in force starting with May 24, 2018. F.lli Zaffrani srl reserves the right  to modify or update its contents, as well as in compliance with variations of the applicable legislation. All the modification and updates are mandatory as soon as they have been published on the web site.