Privacy Advisory Note Fluorital S.r.l.

Introduction

On the basis of that established by the Personal Data Protection Code, this privacy advisory note deals with the management methods used for the site with reference to processing the personal data of users who interact with the web services which are available remotely from: www.fluorital.com which corresponds to the home page of the website of Fluorital s.r.l.

For the purposes of art. 13 and 14 of the EU GDPR 2016/679 the following terms are thus defined:

• “processing”, any operation or series of operations, including those done without electronic instruments, concerning the collection, recording, organisation, storage, consulting, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, disclosure, erasure and destruction of data, even if not stored in a database;
• “user”, any natural person who uses an electronic communication service, accessible to the public, for private or commercial reasons, without having necessarily subscribed to it.

By browsing this site, data regarding identified or identifiable persons may be processed.

Controller

The Controller (in terms of processing personal data), to whom you may refer to assert your rights in accordance with this advisory note (see the section “How to exercise your rights”, below), is FLUORITAL S.r.l. with offices at Via Roma, 54, 31050 Villorba (TV), Italy. You may exercise any of the aforementioned rights in accordance with that provided for in the section regarding how to exercise your rights.

The place where processing is carried out

Data is currently processed and stored at the company’s registered offices at Via Roma, 54, 31050 Villorba (TV), Italy.

The mandatory or optional nature of providing data

Some data is essential in order to establish a contractual relationship or to execute one, whilst other data can be defined as accessory to such ends. Providing data to the company is mandatory only with regard to that data for which there is a legal or a contractual obligation.

The consequences of not providing data

In those cases in which providing data is necessary due to a legal or a contractual obligation, any refusal to provide such data would place the Supplier in a situation in which the Contract cannot be implemented or continued since to do so would constitute unlawful processing. In those cases in which there is no legal obligation to provide data, any refusal to provide such data would not have the aforementioned consequences but it could, in any case, prevent any accessory operations from being carried out.

The purposes for which personal data is processed

Data collected via contact forms will be used by Fluorital S.r.l.:

• for marketing purposes;
• to keep users updated about news, promotions, competitions and other aspects of Fluorital S.r.l.
• to fulfil, in general, legal obligations;
• to carry out analysis and statistical research and market surveys aimed at improving the company’s services;
• to send advertising and/or informational materials regarding new product offers and services from Fluorital S.r.l. and/or from third parties with whom the company has established commercial and/or marketing agreements;
• to check the level of user satisfaction and every client loyalty activity;
• to finalise product sales activities;
• to send communications and/or commercial information.

Material which has a formative and/or informational nature (newsletters) will be sent, free of charge, to the indicated email address.

Types of data processed

Browsing data

The information systems and software procedures used to operate this website acquire, as part of their normal operation, certain personal data the transmission of which is implicit in the use of internet communication protocols.

This involves information that is not collected in order for it to be associated to an identified data subject but, by its very nature, could, through processing and associating it with data held by third parties, allow a user to be identified.

This category of data includes: the IP addresses or computer domain names used by users who access the site, addresses of the resources requested in URI (Uniform Resource Identifier) form, 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 (OK, error, etc.) and other parameters relative to the user’s operating system and computing environment.

This data is used for the sole purpose of obtaining anonymous statistical information on how the site is used and to check that the site is operating normally. This data is deleted immediately after being processed. The data could be used to ascertain responsibility in the hypothetical case of a computer crime against the site www.fluorital.com or any other site connected to it: notwithstanding this eventuality, data on web contacts does nor persist for more than a few days.

Data voluntarily provided by the user

Entering personal data into the site and sending an email address to one of the addresses listed on the site leads to the subsequent acquisition of the personal data entered, the sender’s address and any other personal data included in the written communication.

Cookie

To access information on the Cookie Policy in effect on this site, see: http://www.fluorital.com/cookie/

The means of processing personal data and the data requirements

Processing personal data for the purposes given above is done using both automated means, on electronic or magnetic devices, and non-automated means, on paper, in compliance with the regulations on confidentiality and security as established by Law, by relevant regulations and internal provisions.

Communicating data

Without prejudice to the communications and disclosures done in order to comply with legal obligations, the data regarding your legal person may be communicated within Italy and outside of Italy to:

• Professionals and consultants, consulting companies, credit institutes, debt recovery firms, credit insurance companies, commercial information companies, companies operating in the transportation sector;
• Public and private entities, including following inspections or checks such as, for example: the Financial Administration, Tax Authorities, Judicial Authorities, the Italian Exchange Office, Labour Inspectors, ASL (the Italian Local Health Service), Social Security Bodies, the Chamber of Commerce, etc.;
• Parties who can access your data pursuant to the Law.

Data storage times

Data provided will be stored in our archives in accordance with the following parameters: for administrative and accounting activities, orders, budget management, and overall production flow management, assistance, shipping, invoicing, managing disputes: 10 years, as established by Law by art. 2220 of the Italian Civil Code, without prejudice to any delays in the payment of amounts that might justify an extension;

The data subject’s rights

We advise you that, as a data subject, you have the right:

• to obtain confirmation, or otherwise, of the existence of your personal data, even if not yet recorded, and to have this data made available to you in an intelligible form;
• to obtain an indication and, if necessary, a copy: a) of the origin and the category of the personal data held; b) of the logic applied in the event of processing carried out with the aid of electronic instruments; c) of the purposes for which and the means by which personal data is processed; d) of the Controller’s contact details as well as those of any Processors (in terms of processing personal data; e) of the subjects and categories of subjects to whom personal data may be communicated or who might become aware of such personal data, in particular if they are in a third country or are an international organisation; f) when possible, of the data storage period or the criteria used to determine this period; g) of the existence of suitable guarantees in the case that data is transferred to a country outside of the EU or to an international organisation;
• to have, without unjustified delay, inaccurate data updated and rectified or, when there is a request, to have incomplete data supplemented;
• if expressed, to exercise your right to revoke, at any time, any consent previously given, easily, without impediment, using, if possible, the same channels used to grant such consent;
• to have your personal data erased, transformed into an anonymous form or blocked from further processing if: a) processed unlawfully; b) no longer needed with regard to the reasons for which the data was collected or subsequently processed; c) in the case of consent being revoked, and on which processing is based, and in the event that there is no legal basis for processing to be done, d) you object to the processing of your personal data and there is no legitimate prevailing reason to continue processing it; e) in the case of fulfilling a legal obligation; f) in the case of data which refers to a minor. The controller may refuse to erase data only in the case of: a) exercising a right to freedom of expression and freedom of information; b) fulfilling a legal obligation, performing a task in the public interest or exercising an official duty; c) reasons of public health; d) storage in the public interest, scientific or historical research or for statistical purposes; e) exercising a right in a court of law;
• to have processing restricted in the case of: a) a dispute on the accuracy of the personal data; b) the Controller’s unlawful processing of personal data in order to prevent its erasure; c) exercising your rights in a court of law; d) checking any prevalence of the Controller’s legitimate reasons with respect to those of the data subject;
• to receive, if processing is carried out with automated means, without hindrance and in a structured, commonly-used and legible format, the personal data that concerns you and to have this data sent – if technically feasible – to another controller, directly from the Controller to this other controller;
• to object, in whole or in part: a) for legitimate reasons, to the processing of the personal data that concerns you, even if relevant to the reason for which the data was collected; b) to the processing of the personal data that concerns you for the purposes of sending advertising materials or for direct selling or to carry out market research or for commercial communications, using automated calling systems without the intervention of an operator via email and/or via traditional marketing means using the telephone and/or the postal service;
• to lodge a complaint with the Italian Data Protection Authority.

In the cases outlined above, where necessary, the Controller will advise those third parties to whom your personal data has been communicated, of the rights you have exercised, except in specific cases (for example, when doing this should prove to be impossible or involve a use of resources manifestly disproportionate to the protected right).

How to exercise your rights

You may exercise your rights at any time by:

• sending a registered letter with return receipt to the company’s address or by sending a certified email to info@fluorital.commarking it for the attention of the marketing office.

For more information and updates on privacy, refer to the Italian Data Protection Authority’s website www.garanteprivacy.it