Privacy Policy

PRIVACY POLICY

INFORMATION FOR THE PROCESSING OF PERSONAL DATA PURSUANT TO ARTICLE 13 OF EU REGULATION 2016/679

In compliance with the provisions of EU Regulation 2016/679 (European Data Protection Regulation), we provide you with the necessary information regarding the processing of your personal data. The information does not apply to other websites that may be reached through links (links) on the domain websites of the owner, who is therefore not responsible in any way for the data collected and processed.

This information is provided pursuant to Art. 13 of EU Reg. 2016/679 (European Regulation for the protection of personal data) and is also based on the provisions of Directive 2002/58/EC, as updated by Directive 2009/136/EC, on Cookies as well as on the provisions of the Order of the Italian Data Protection Authority of 08.05.2014 on cookies. Personal data which may be processed: 'personal data' shall mean any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, by reference in particular to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity; (Recitals 26, 27 and 30).

Specific disclosures: specific disclosures may be presented on the pages of the Site in relation to particular services or processing of the Data provided. Cookies: for more information on the cookies used by this website, see the cookies policy at the following link: https://www.spreafico.net/it/cookie-policy/


1. DATA CONTROLLER and DATA PROTECTION RESPONSIBLE
Pursuant to art. 4 EU Reg. 2016/679, the Data Controller is SPREAFICO FRANCESCO & F.LLI S.P.A., with registered office in VIA C. LOMBROSO 54 - 20137 MILANO, P.IVA:00348240136. The updated list of data processors is kept at the registered office of the Data Controller and is available to those who request it.


2. PURPOSE AND LEGAL BASIS OF THE PROCESSING

Data of a personal nature provided will be processed, in compliance with the conditions of lawfulness pursuant to Art. 6 of EU Reg. 2016/679, for the following purposes

  1. browsing this website: legitimate interest (art. 6 paragraph 1 letter f)) as the legal basis for processing;
  2. possible contact request with sending of information you requested: legitimate interest (art. 6 paragraph 1 lett. f)) as the legal basis of the processing;
  3. subject to your consent and until revoked: for the Controller's direct marketing activities, newsletters, market research or other sample research and direct sales to receive - by automated means e-mail, fax, MMS (Multimedia Messaging Service) or SMS (Short Message Service) messages or other types of messages, as well as by telephone calls through an operator and by paper mail - informative material, for satisfaction surveys, promotional, commercial and advertising material or material relating to events and initiatives, from the Controller - explicit consent (art. 6 paragraph 1 lett. a)) as the legal basis of the processing;

3. RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE DATA

Data of a personal nature provided may be communicated to recipients, who will process the data in their capacity as data processors (art. 28 of EU Reg. 2016/679) and/or as natural persons acting under the authority of the Data Controller and the Data Processor (art. 29 of EU Reg. 2016/679), for the purposes listed in point 2 above. Precisely, the data may be communicated to:

  • entities that provide services for the management of the information system and telecommunications networks including e-mail, newsletters and website management;
  • professionals, studies or companies in the context of assistance and consultancy relationships
  • parties that collaborate with the Data Controller for direct marketing activities;
  • parties responsible for fulfilling legal obligations and/or provisions of public bodies, upon request;

Subjects belonging to the above-mentioned categories perform the function of Data Processor, or operate completely independently as separate Data Controllers. The list of Data Processors is constantly updated and available to those who request it by writing to privacy@spreafico.net


4. DATA TRANSFER TO A THIRD COUNTRY AND/OR INTERNATIONAL ORGANISATION AND GUARANTEES

Data of a personal nature provided may be transferred to countries within the European Union and to countries outside the EU, in order to fulfil related purposes indicated above. Should the data be transferred, it will be on the basis of Article 44 - General principle for transfer; Article 45 - Transfer on the basis of an adequacy decision; Article 46 - Transfer subject to adequate safeguards, specifically data transferred to international organisations for which the Commission has intervened with an adequacy assessment (Art. 45 EU Reg. 2016/679). The data subject may obtain information about the data transfer guarantees by writing an email to privacy@spreafico.net

5. DATA RETENTION PERIOD OR CRITERIA FOR DETERMINING THE PERIOD
The processing will be carried out in automated and manual form, with methods and instruments designed to guarantee maximum security and confidentiality, by persons specifically appointed for this purpose. In compliance with the provisions of Article 5 paragraph 1 letter e) of EU Reg. 2016/679, the personal data collected will be stored in a form that allows the identification of the data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The storage of data of a personal nature provided depends on the purpose of the processing:

on this website (purposes referred to in point 2.a): see the cookies policy at the following link: https://www.spreafico.net/it/cookie-policy/

  • for contact requests, availability or online order processes (purposes under point 2.b): 1 year, unless otherwise required by specific laws, such as accounting and administration;
  • ricezione newsletter o comunicazioni promozionali in genere via e-mail (finalit√† di cui al punto 2.c): fino a Sua revoca;

The timing is determined on the basis of criteria about which the data subject can obtain information by writing to privacy@spreafico.net


6. NATURE OF CONFERMENT AND REFUSAL

Apart from what is specified for navigation data, the user is free to provide personal data. The provision of data is optional or necessary depending on the specific purpose for which the data is processed. Failure to provide the data marked as compulsory in the respective collection forms will make it impossible to obtain what has been requested or to use the services of the data controller.


7. RIGHTS OF THE INTERESTED PARTIES

You may assert your rights as expressed in Articles 15, 16, 17, 18, 19, 20, 21, 22 of EU Regulation 2016/679, by contacting the Data Controller at privacy@spreafico.net You have the right, at any time, to ask the Data Controller for access to your personal data, rectification, cancellation of the same, and restriction of processing. In addition, you have the right to object, at any time, to the processing of your data (including automated processing), as well as to the portability of your data. Without prejudice to any other administrative and jurisdictional recourse, if you consider that the processing of your data violates the provisions of EU Reg. 2016/679, pursuant to Art. 15 letter f) of the aforementioned EU Reg. 2016/679, you have the right to lodge a complaint with the Garante per la protezione dei dati personali and, with reference to Art. 6 paragraph 1(a) and Art. 9 paragraph 2(a), you have the right to withdraw your consent at any time. In the event of a request for data portability, the Data Controller shall provide you with the personal data concerning you in a structured, commonly used and machine-readable format, subject to paragraphs 3 and 4 of Article 20 of EU Reg. 2016/679.


8. MODALITIES FOR EXERCISING RIGHTS

The procedures for exercising rights are as follows:

  • A registered letter to the Data Controller SPREAFICO FRANCESCO & F.LLI SPA via C. Lombroso 54, 20137 Milan
  • An email to privacy@spreafico.net
  • An email to the Data Protection Officer (DPO) Giorgio Marinoni: dpo@privacynet.it it or a PEC to dpo@autpec.it
  • Accessing the website of the Garante Privacy http://www.garanteprivacy.it

Date of update: 04.02.2020