Privacy Policy
INFORMATION PROVIDED PURSUANT TO ARTICLES 13-14 OF THE GDPR (GENERAL DATA PROTECTION REGULATION) 2016/679
In accordance with the aforementioned legislation, such processing will be based on principles of fairness, lawfulness, transparency and protection of your privacy and your rights.
Pursuant to Article 13 of GDPR 2016/679, we therefore provide you with the following information:
A – Personal data (first name, surname, identification document details and copy thereof, telephone number, email address, etc.) will be provided at the time of registration depending on the type of membership requested.
TAURO ESSICCATORI SRL, as the data controller of your personal data, informs you about their use and your rights, so that you can consciously give your consent, where required, and exercise your rights under the General Data Protection Regulation (European Regulation 679/2016, hereinafter: the Regulation). Your personal data (provided by you, by third parties or, within the limits of the law, from public lists) may be processed for the following expressly stated purposes: 1) To fulfil a contractual obligation (sale of goods and services); 2) To fulfil legal and regulatory obligations, including those of a fiscal nature (invoices, tax returns, tax payments), social security (employee health protection, insurance and tax obligations); 3) To offer services or goods to the data subject (i.e. activities prior to the conclusion of a contract with third parties); 4) To carry out profiling for the purpose of offering direct or indirect marketing; 5) To send periodic commercial, informational, educational communications and newsletters.
The legal basis for processing is represented by: A Legal or regulatory obligation, B Contract with data subject or contract execution, C Legitimate interest of data controller or third parties, E Explicit consent of data subject
Below, we specify the meaning of the types of purposes:
- by law: that is, to fulfil obligations under the law, regulations, European Union legislation, and provisions issued by authorities legitimised by law or by competent supervisory or control bodies (in this case, your consent is not necessary as the processing of data is related to compliance with these obligations/provisions). The data processed by law includes data relating to tax regulations or anti-money laundering registers.
- contractual and, more generally, administrative-accounting purposes, i.e. to fulfil obligations arising from contracts to which you are a party or to comply with your specific requests prior to the conclusion of the contract, including through remote communication techniques, such as a dedicated call centre (in this case, your consent is not required, as the processing of data is functional to the management of the relationship or the execution of requests); such processing also includes the purpose of protecting mutual interests in court and for tax purposes or for other legal obligations such as, for example, keeping anti-money laundering records, if applicable.
- Direct marketing: data processing activities aimed at providing you with information and sending you informative, commercial and advertising material (including through remote communication techniques such as, by way of example, postal correspondence, telephone calls, including through automated calling systems, fax, e-mail, SMS or MMS messages or other types) on the company's products, services or initiatives, to promote them, to carry out direct sales activities, to conduct market research or to send you promotional offers. telephone calls, including automated calling systems, faxes, emails, SMS or MMS messages or other types of messages) about the company's products, services or initiatives, to promote them, to carry out direct sales activities, to conduct market research, to verify the quality of the products or services offered to you (including through telephone calls or the sending of questionnaires). The processing of such data may take place with your optional consent or on the basis of the company's legitimate interest, where this is deemed and assessed not to conflict with your rights.
- Profiling: data processing activities aimed at optimising the commercial offer (including through focused and selected analyses), to carry out targeted commercial communications, to perform statistical research, to apply one or more profiles to you (for the purpose of making appropriate commercial decisions or analysing or predicting, again for commercial purposes, your personal preferences, behaviours and attitudes). (In this case, your consent is optional and does not affect the maintenance of relations with the company).
- indirect commercial purposes: that is, by communicating your data to third parties so that they may carry out their own independent commercial activities as indicated in point 3 above. (In this case, your consent is optional and does not affect the maintenance of relations with the company)
- commercial posts: that is, in order to investigate, following the termination or revocation of relations with the Company, the reasons for the interruption of relations. (In this case, your consent is optional and does not affect the maintenance of relations with the company)
Special cases of data:
- ‘Special’ data, also known as ‘sensitive’ data, i.e. personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data concerning a person's health or sex life or sexual orientation (Article 9 of the Regulation) or relating to criminal convictions and offences or related security measures (Article 10 of the Regulation). Such data may only be processed with your explicit written consent if one of the reasons indicated in Article 9(2) and Article 10 of the Regulation applies. Consent is free and optional, but refusal to give consent could prejudice the performance of one or more activities requested by you from the company that specifically concern matters for which it is essential to process this type of data.
- Consent to the processing of your data may be binding for the purpose of concluding contracts with the Data Controller or with third parties. Only data whose processing is essential for the purpose of concluding the contract may be binding for the purpose of concluding the contract, while you are free to give or withhold your consent for non-essential data, in particular for profiling, commercial communications and marketing purposes.
- Your data may be transferred to third parties for the purposes stated by the Data Controller. In particular, it may be transferred to third countries subject to an adequacy assessment or, failing that, subject to your explicit consent.
B – DATA PROCESSING METHODS. Your data is processed using manual tools and manual/paper-based archiving, as well as electronic and automated tools, in ways that are strictly related to the purposes indicated above. Where you have given your consent, processing may also take place through profiling or data comparison. The Company has adopted technical and organisational measures to prevent and limit the risk of loss, deterioration or theft of your data, and to ensure its restoration within a reasonable time in the event of a data breach. Processing is carried out in such a way as to guarantee the security, protection and confidentiality of your data. Within the company, your personal data may be disclosed to the following persons, as data processors or persons in charge of processing:
- employees, managers and directors or partners of the company who hold administrative, collaborative or commercial roles subject to self-employment contracts operating within the company structure, either by law or by company statute. These personnel have been provided with adequate training and instructions by the Company to protect the storage, maintenance, updating, security and confidentiality of your data. Consent to processing by such personnel is not required as it is inherent in the necessary procedures provided for by law.
- Outside the company, your data may be processed by:
- collaborators subject to non-employee contracts operating outside the company's premises
- commercial agents subject to a non-employee contract operating outside the company's premises
- consultants of any kind (lawyers, doctors or accountants, engineers, architects, employment consultants or other professionals registered or not registered in professional registers), who perform technical, support (in particular: legal services, IT services, shipping) and business control tasks on behalf of the company.
- In order to pursue the aforementioned purposes, the company may communicate or otherwise transmit
- Your data to certain parties, including foreign parties, who will use the data received as independent joint controllers, unless they have been designated by the company as “processors” for the processing operations under their specific responsibility. You have the right to request and obtain a list of the third parties to whom such data is transmitted.
- Public bodies or public administrations for the fulfilment of legal obligations
The data controller may delegate the processing of your data to other sub-processors, who will in turn be instructed on how to process the data correctly.
Since the data you provide us with may consist of so-called ‘special’ data, already referred to as ‘sensitive’ pursuant to Article 9 of the European Regulation, i.e. data relating to racial origin, health, sexual orientation or habits, political, trade union, religious or philosophical beliefs, or criminal convictions (Article 10 of the Regulation), processing may take place with your prior written consent and for the purposes indicated in this processing form, except in cases of processing defined as lawful by the Regulation.
Your data may be subject to profiling, i.e. the collection and aggregation of data concerning you for the purpose of making appropriate commercial decisions or analysing or predicting, again for commercial purposes, your personal preferences, behaviour and attitudes. Profiling may take place a) with your consent b) based on the legitimate interest of our company. Failure to give consent for profiling purposes does not normally compromise the regular development of the relationship on the basis of which your data is processed. The performance of profiling activities could compromise your rights and opportunities with regard to our company's offers.
Your data may be transferred to a foreign country. In this case, if this occurs within the European Union, your data will be processed in the same way as it is processed in Italy. In the event of transfer to countries outside the European Union, they will be processed in accordance with your rights under the European Regulation. If your data is transferred to a country outside the EU, it may be processed by entities that guarantee compliance with the rights provided for by the European Regulation through voluntary adherence to general measures.
The transfer of data will in any case be carried out using tools that guarantee the protection of the data from intrusion by third parties.
Your data has been collected directly from you and therefore we provide you with the following information in this form, where applicable:
- details of the owner and representative
- data protection officer details
- purpose and legal basis of processing
- recipients of the data
- intention to transfer data abroad
- duration of the retention period or criteria for determining the duration
- right of access, rectification, erasure, objection to processing, portability
- right to withdraw consent to processing, where possible, subject to legal obligations
- possibility of lodging complaints with the authority (Data Protection Authority)
- whether the data is mandatory for the performance of a contract or by law, and the consequences if consent is not given
- whether the data are or will be subject to profiling and, if so, the logic behind the profiling
- the existence of automated decision-making processes and the right of the data subject to have decisions made after human intervention.
Our company has obtained data concerning you from third parties. Therefore, in this form, we provide you with the following information, where applicable to you:
- Data controller and representative details
- Data Protection Officer (DPO) details, if applicable
- purpose and legal basis of processing
- categories of data collected
- recipients of the data
- intention to transfer data abroad
- retention period or criteria for determining the period
- rights of access, withdrawal, rectification, erasure, portability, withdrawal of consent to processing, restriction
- possibility of lodging a complaint with the supervisory authority
- the source from which your data originates, which is as follows:
- _________________________________________________________
- _________________________________________________________
- the existence of automated decision-making processes and the right of the data subject to have decisions made after human intervention
Your data will be stored by the Data Controller, in accordance with the intended purposes, for the time necessary to carry out the relationship with you and to ensure mutual protection of rights in court, as well as to comply with legal obligations, including those of a tax nature. Data not necessary for these purposes will be removed within the maximum period provided for by the right to be forgotten, as indicated further on in this policy, or, at your request, even sooner if this does not conflict with the rights of the Data Controller.
Data relating to the data subject that does not need to be retained for specific legal reasons will be deleted within 10 years.
With regard to profiling logic, the company declares the following: profiling is carried out to improve the browsing experience, for anonymised statistical analysis purposes, for commercial purposes, or to personalise any advertising content offered online or sent.
C – RIGHTS OF THE DATA SUBJECT You may, at any time, exercise the following rights expressly recognised by the Regulation:
- You have the right to lodge a complaint with the national authority (Data Protection Authority) at any time if you believe that your rights have been violated.
- You have the right to ensure that your data is always accurate and up to date and therefore you may report or request updates to your data at any time.
- You have the right to withdraw your consent to the processing of your data where this is not prevented by legal provisions or the need to protect the rights of the data controller, including in court proceedings. In any case, the request for withdrawal gives rise to the right to restrict processing.
- You have the right to access your data processed by the Data Controller by means of a written request, including by electronic means. It is essential that you provide us with proof of your identity, possibly also by accessing our databases using credentials that are uniquely attributable to you. You have the right to free access once, while you may be asked to contribute to the costs for subsequent requests. You have the right to receive a response within thirty days of your request. You have the right to receive your data in printable formats.
- You have the right to correct and update your data and may request that it be updated and corrected at any time if you find that the data in our possession is out of date or incorrect. In order to ensure that your data is kept up to date, we invite you to notify us of any relevant changes.
- You have the right to request the deletion of data concerning you, provided that it does not involve data that the Data Controller is required to retain for specific legal obligations, such as obligations arising from tax regulations, anti-money laundering regulations or for the protection of the Data Controller's rights in litigation.
- If you dispute the accuracy of your data, or the lawfulness of the processing, or the right of the Data Controller to delete your data, or if you object to the processing of your data and the Data Controller disputes your objection, you have the right to have your data stored but not processed, except to the extent necessary to resolve the dispute over the data itself.
- If the Data Controller modifies or deletes all or part of your data, you have the right to be informed and to object to the modification or deletion.
- You have the right to transfer your data – stored and processed electronically – to another operator, within the limits indicated by the Regulation, and provided that it is technically feasible, in a manner that allows it to be easily read and acquired by third parties. The data that you have the right to transfer (portability) also includes data derived from the automatic observation of your activity carried out through the Data Controller's IT services, such as searches and history of activities performed.
- You have the right to object to the processing of your data, profiling, the use of data for direct marketing, profiling for public interest or for scientific, historical or statistical research purposes.
- Under certain circumstances, the company may adopt automated procedures in order to make decisions that affect you and, in particular, to decide whether and under what conditions to enter into contracts with you directly or through third parties. In this case, you have the right to request that, before a binding decision is made, your position be reviewed by a human operator who will carry out a merit assessment. The use of automated decision-making procedures may result in your exclusion from certain proposals, offers or the right to enter into contracts or benefit from particular promotions.
- Since your data may be processed for the purpose of conducting e-commerce activities, you have the right to have your data processed according to the best state-of-the-art IT procedures. To this end, your data may be transferred to third parties for the purpose of carrying out, in whole or in part, the technical and IT procedures relating to the conclusion and execution of the contract, such as, for example, third-party servers, logistics and transport service providers. Your consent to this is always necessary and, in the event of failure to consent to the processing of data necessary for the conclusion of transactions, the Company may not be able to provide you with the requested services. Consent to the processing of essential data must be separate from consent to the acquisition of non-essential data or for purposes other than those relating to the conclusion of e-commerce contracts.
- Under certain circumstances, the company may process your data in order to communicate with you regarding commercial, informational or educational initiatives (e.g. newsletters). In this case, your consent, if necessary, must be explicit and separate from other forms of consent, and you may revoke your consent for this purpose at any time.
- You have the right to be consulted when security procedures for the processing and protection of your data are being evaluated.
D – INDICATION OF THE SUBJECTS INVOLVED IN THE PROCESSING Your data may be processed by the following subjects:
- [owner] Tauro Essiccatori srl – Via del Lavoro, 6 36043 – Camisano Vicentino (VI) – Tax code and VAT number 03977800246
- [joint controllers] None
- [representative] Not applicable
- ActiveCampaign, LLC - 1 North Dearborn Street, 5th Floor - Chicago, IL 60602 - USA; Google Ireland Limited - Gordon House, Barrow Street - Dublin - Ireland; Facebook Ireland - 4 Grand Canal Square, Dublin; Trustpilot A/S, Pilestraede 58, 5th floor, 1112 Copenhagen, Denmark; Graziella Moro, accountant, C.F. MROGZL66S46G224E P.I. 02063800284; Sara De Paoli, communication and marketing consultancy, C.F. DPLSRA82C54G224K P.IVA 05044780285; Italix Sas di Andrea Sivieri e soci, web design and IT development, P.IVA e C.F. 04311980280; MOCA Interactive S.r.l., web marketing, P.IVA IT02852430244, C.F. TV02852430244; Sonar Srl, management software, P. IVA 04752190282; Gianesin, Canepari and Partners S.r.l., Temporary Export Manager, P.I. and C.F. 03506800246; Tommaso Pittarello, marketing consultancy.
- [RDP/DPO] No appointment is required.
E – HOW TO EXERCISE YOUR RIGHTS Your requests can be exercised by writing to the Company at VIA DEL LAVORO 6, CAMISANO VICENTINO (VI) or to the email address info@tauroessiccatori.com, or, if applicable, independently within the personal area made available to you electronically by means of a unique identifier.