The website is owned and operated by a company incorporated under Italian law, Zecchino d’Oro srl headquartered in Via Purità, 128, 62015, Monte San Giusto (MC).
1. DATA CONTROLLER
The data controller is Zecchino d’Oro srl, Via Purità, 128, Monte San Giusto (MC) VAT reg. no 01693230433 Phone +39 (0733) 539046 E-mail address: email@example.com
2. PURPOSES AND METHODS OF DATA PROCESSING
Following consultation of this website and use of one or more services, data concerning identified or identifiable natural persons may be processed. Any personal data acquired, always in compliance with the regulations in force, will be processed solely for the following purposes: for purposes strictly connected and instrumental to grant access to and use the website, its functions and the services requested; b to fulfil the obligations envisaged by law and by European regulations; c for internal operational and managerial requirements within Zecchino d’Oro srl and relating to the services and/or products offered; d for the creation of a personal user account; e to provide the newsletter service; In the case of explicit and voluntary manifestation of consent, the data collected for the purposes specified in paragraph 1 herein above will also be processed for the purposes of direct marketing by the Data Controller, in particular to send information, commercial or advertising material relating to the services and/or products offered by Zecchino d’Oro srl, also via e-mail, text message, MMS and fax. The data will be processed in a lawful and correct manner and used only for the purposes specified in the previous paragraphs. The processing will occur using suitable tools to guarantee security and confidentiality of the personal data, and may be carried out with hard-copy instruments and/or with the aid of automated means designed to store, manage and transmit the said data.
3. NATURE OF THE CONFERMENT OF DATA AND CONSEQUENCES OF A POSSIBLE REFUSAL
The conferment of personal data is compulsory only for the purposes specified in Art. 2, paragraph 1, to allow the use of the website and related services requested by the user, possibly after disclosure for every additional service, which will be provided to users in the manner prescribed by law. The website may nevertheless be consulted without providing any personal data, but certain functions will not be available and certain services will not be provided. The conferment of the data and the provision of processing consent for the purposes specified in Art. 2, paragraph 1(d), (e) and (f), and paragraph 2, is optional: in the absence of a request by the user and/or the provision of his/her explicit consent, these services will not be provided, but there are no other consequences. Should you choose not to provide your consent for the purposes specified in Art. 2, paragraph 2, you may nevertheless use the website and services for the purposes specified in Art. 2, paragraph 1. In other words, the consequences of a possible refusal to answer or provide your consent are always made explicit and are connected to each service provided: for example, a refusal to the related processing may prevent the consultation of the website with all its functions (in the case of cookies), the sending of our newsletter (in the case of Art. 2, paragraph 1, letter e) or the receipt of advertising material (in the case of Art. 2, paragraph 2). In any case, the user may consult the website even without providing his/her personal data and refusing to provide his/her consent to data processing, where required; in this case, however, some functions or characteristics of the website may be disabled.
4. LOCATION OF DATA PROCESSING
Data processing connected to the web services specified in this website is carried out on the premises of Zecchino d’Oro srl, barring any explicit exceptions, and is only handled by technical staff appointed specifically for this processing by the Data Controller.
5. TYPES OF DATA PROCESSED/SPECIFIC PROCESSING
Depending on the service provided, different types of personal data may be processed, as specified in this article. Please note that, when the data entered by the user also concern other people, the user himself/herself must ensure the same other people read this privacy disclosure first. The data processing of data subjects below the age of sixteen may only take place with the consent of their parents or legal guardian. In the absence of this consent, in the case of receipt of data from a minor, the Data Controller reserves the right to delete them. Consequently, when using our services, we invite the data subjects not to enter data relating to minors under sixteen; in any case, these data can only be used in limited cases such as, for example, for communications to be made to the public authority.
5.1 Navigation data The information technology systems and the software procedures responsible for the functioning of this website acquire, during their normal use, some personal data, the transmission of which is implicit for website navigation. This information is not collected to be associated with identified data subjects; nevertheless, owing to its very nature, this information could, through processing and associations with details held by others, make it possible to identify the users. This includes IP addresses or domain names of computers used by the users who connect to the website, the URL addresses of the resources requested, the time of the request, the method used to make the request to the server, the size of the file obtained in reply, the numeric code indicating the state of the reply given by the server and other parameters relating to the operating system and to the platform used by the user. The above data are used for the sole purpose of obtaining anonymous statistical information regarding the use of the website and to check that the site is operating correctly, and are cancelled immediately after being processed. The data could be used to establish liability in the event of hypothetical IT crimes that damage the website: except in this case, information on web contacts is currently not held for more than seven days. With respect to cookies, please refer to para.
5.2.1 Data provided voluntarily by the user (communications – website registration) The optional, explicit and voluntary sending of communications by means of contact forms on the site or e-mail to the addresses specified on this site entails the subsequent acquisition of the data communicated by the sender, including his/her e-mail address, and the consent to receive any reply messages to their requests. To this end only the personal data necessary to identify the user and to provide the service requested by the same are collected (in particular, name, surname and e-mail address). The data provided by the user to Zecchino d’Oro srl are only used in order to accommodate or to respond to the requests sent and are disclosed to third parties expressly authorised by the Data Controller only where necessary for this purpose. Information specifications designed specifically for particular services upon request will be provided on the relevant pages of the site.
5.2.2 Data provided voluntarily by the user (to receive communications for marketing and/or commercial promotion purposes) Every data subject may voluntarily provide their personal data to S.r.l./SpA in order to receive commercial or promotional information, whatever their designation, in both digital and hard-copy form. Only in the event that the e-mail coordinates are provided by the data subject as part of the sale of a product or service, the e-mail address thus provided may be used for the direct sale of further similar products or services, pursuant to the provisions of Art. 130, paragraph 4, of Italian Leg. Decree 196/2003, without the need for express and prior consent from the data subject (also known as “soft spam”). In any communication of this type, however, the data subject is reminded that (s)he may revoke consent at any time and without formality. The data processed for marketing purposes are deleted at the request of the data subject, who may at any time revoke consent, as specified in detail in the following Art. 9.
5.3. Newsletter The Zecchino d’Oro srl newsletter is sent via e-mail to those who have explicitly requested, by filling in the dedicated form on this website and thereby authorising Zecchino d’Oro srl to process their personal data for the above mentioned purposes. Consent: The conferment of data required for this purpose (e-mail and, possibly, selection of default categories of areas of interest) is compulsory only in order to receive the newsletter: the refusal to provide these data in fact entails the inability to benefit from the newsletter service, but there are no other consequences. Purposes: The personal data provided by users are only used in order to send the newsletter and will not be disclosed to third parties. Method: The data collected are processed with computerised tools. Suitable security measures are observed to prevent the loss of data, unlawful or incorrect use and access by unauthorised persons. Unsubscribing from the service: to stop receiving the newsletter simply select the unsubscribe link, found at the end of every e-mail received, or send a request to the e-mail address: firstname.lastname@example.org. Unsubscription is managed in an automated manner, which is why, following the request to unsubscribe from the service, you may receive further newsletters as their sending had already been scheduled prior to receipt of your unsubscribe request, but for a maximum period of 72 hours.
5.4.1 Cookies What are they? Cookies are pieces of information stored by your browser when you visit a website with any suitable device (such as a PC, a tablet or a smartphone). Each cookie contains various data (e.g., the name of its server of origin, a numerical identifier, etc.), and it may remain in the system for the duration of a session (until your browser is closed) or for long periods and may contain a unique identification code. What are they for? Cookies are used for various purposes depending on their type: some are strictly necessary for a website to function properly (technical cookies) while others optimise performance to offer an improved user experience or capture statistics on the use of the site, such as analytics cookies, or they allow you to see personalised advertising, such as profiling cookies. Consent: any provision of consent by the user is stored by Zecchino d’Oro srl under its area of responsibility, by means of a technical cookie, with a duration of 12 months. The user is notified by both a short disclosure (banner displayed until consent is provided or denied, as explained in paragraph
5.4.4. ‘How to disable cookies?’) as well as this full disclosure; moreover, paragraph
5.4.3 contains the links to the privacy policies of any third parties, also for the purposes of disabling them (where this is directly available through the same). How do you disable them? You can disable cookies using either your browser settings (para. 5.4.4. ‘How to disable cookies?’) or using the mechanisms available from certain third parties (para. 5.4.3 ‘Cookies used on the site’).
5.4.2 General types of cookies used on the site Technical cookies: they are essential for the site to work properly.
Analytics cookies (third party): these are used for aggregate analysis purposes of site visits, resorting to a third-party service. Profiling Cookies (third party): these are used to create profiles about the user and are used to send advertisements in keeping with the preferences shown by the same during their web browsing, resorting to a third-party service.
5.4.4 How to disable cookies? Control via browser: The most commonly used browsers (e.g., Internet Explorer, Firefox, Chrome, Safari) accept cookies by default, but this setting can be changed by the user at any time. This applies both for PCs as well as mobile devices such as tablets and smartphones: it is a generally and widely supported function. Consequently, cookies can easily be disabled by accessing the options or preferences of the browser being used and generally only third-party cookies can also be blocked; as a general rule, these options will only be effective for that particular browser and on that particular device, unless options to merge and apply these preferences onto multiple devices have been enabled. Specific instructions can be found in the Options or help page of the browser itself. Disabling technical cookies can however affect the full and/or correct operation of several sites, including this website. Normally, the browsers currently used: – offer the ‘Do not track’ option, which is supported by some websites (but not all). This way, some websites may no longer collect certain navigation data; – they offer the option of anonymous or incognito browsing: this way, data will not be collected in the browser and the browsing history will not be saved, but the navigation data will nevertheless be available for acquisition by the operator of the website visited; – they allow you to delete the cookies stored in full or in part, but once the website is visited again, they are normally installed if this possibility has not been blocked. Below are links to the support pages of the most widely used browsers (with instructions on how to disable cookies on these browsers):
– Firefox (https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie)
– Internet Explorer (http://windows.microsoft.com/it-it/internet-explorer/delete-manage-cookies#ie=ie-11)
– Safari (iOS) (https://support.apple.com/it-it/HT201265 )
– Chrome (desktop) (https://support.google.com/chrome/answer/95647?hl=it)
– Chrome (Android e iOS) (https://support.google.com/chrome/answer/2392971?hl=it)
Third-party cookies: third-party cookies can be disabled either using the above method or by contacting each individual third party (following the links provided in the previous paragraph). On-line tools: please note that from the http://www.youronlinechoices.com/it/ website not only provides more information about cookies, but also allows you to verify the installation of multiple cookies on your browser/device and, where supported, disable them too.
6. DATA STORAGE PERIOD
The data conferred will be stored for the time prescribed by law and, in any case, for the time strictly necessary to fulfil the activities for which they were collected (for example, the data provided in the ‘Leave a message’ form will be deleted after the related request has been accommodated) and/or until you revoke the consent provided for the purposes specified in Art. 2, paragraph 2. The personal data collected will however not be stored for more than twenty-four months for the marketing purposes specified in Art. 2, paragraph 2 (barring any amendments and/or addenda to the reference legislation regarding the protection of the personal data which you will be expressly notified of).
7. CATEGORIES OF PERSONAL DATA RECIPIENTS
For the purposes specified in Art. 2, where necessary and only with prior consent, the data may be disclosed to third parties whose collaboration Zecchino d’Oro srl may and/or shall use for the provision of the services offered. The data acquired via the web, or in any way arising from web services, may be disclosed to technological and instrumental partners whom the Data Controller uses for the provision of the services requested by users/visitors, always in compliance with the purposes specified in Art. 2. The data collected for the purposes set out above may also be disclosed to companies related to or belonging to the same corporate group as the Data Controller and to entities authorised for this purpose by legal provisions and European regulations. A list of entities to whom the Data Controller discloses the personal data collected for the above-mentioned purposes is available to data subjects from the Data Controller himself and can be received subject to prior written request sent to the Data Controller.
8. RIGHTS OF DATA SUBJECTS
The data subject is the natural person, identified or identifiable, to whom the personal data subject to processing refer. We hereby inform you that, as the data subject, you have the right to request from the Data Controller at any time which data concerning you are processed, how they were collected, with what methods and for what purposes they are processed (right of access) in order to verify their accuracy and to verify the lawfulness of the processing carried out by the Data Controller. You may also exercise all the rights acknowledged by the regulations currently in force, at both national and European level, on the protection of personal data (Italian Leg. Decree 196/2003 and EU Reg.no. 2016/679 and subsequent amendments and addenda): in particular, you may request at any time the correction and updating of incorrect or inaccurate data, the limitation of the processing performed and the cancellation of the same (right to be forgotten), as well as lodge a complaint with the Supervisory Authority for the protection of personal data. With reference to the personal data processed using automated means, you are also acknowledged the right to receive the data concerning you in a structured and widely used format and possibly to transmit them to another Data Controller (right to data portability). Every request in relation to the processing of personal data and any communication concerning the exercise of your rights can be directed to the Data Controller using the ‘Contact Us’ form on the http://www.zecchinodoro.it/contacts/ website or by sending an e-mail to the address: email@example.com; or, instead, by mail, to Zecchino d’Oro srl, Via Purità, 128, Monte San Giusto (MC)
9. RIGHT TO REVOKE CONSENT AND TO OBJECT
Every data subject is also entitled to revoke at any time the consent provided, without prejudice to the lawfulness of the processing carried out by the Data Controller up until that time. The data subject is also always entitled to object to the processing of data concerning him/her if it is carried out for the purposes of direct marketing as specified in Art. 2, paragraph 2; in this case, once your notice of revocation of consent has been received, your data will no longer be processed for such purposes (right to objection).