1. Data controller
Chinchio Sergio S.r.l. with registered office in Via Leonardo da Vinci 12, 21043 Castiglione Olona (VA) (Italy) (the "Company", "Chinchio" or the "Owner") guarantees compliance with the applicable regulations for the protection of personal data by providing the following information about the processing of data communicated or otherwise collected during navigation on this site.
2. Data processed, purposes and legal bases of processing
Data generated by access to the site
The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
These data (such as domain names, IP addresses, operating system used, type of browser device used for connection) are not accompanied by any additional personal information and are used to: i) obtain anonymous statistical information on the use of the site; ii) manage control requirements about how to use it, iii) ascertain responsibility in case of hypothetical computer crimes.
The legal basis that legitimizes the processing of such data is the necessity to make site functionalities usable as a result of user access.
Data provided voluntarily by the user
The personal data provided by the user through the form are collected and processed for the following purposes:
To interface with the customer on the basis of contractual agreements. For administrative purposes and for the fulfillment of legal obligations such as those of an accounting, tax, or to comply with requests from the judicial authority;
in the presence of specific consent, for the periodic sending, by e-mail, of newsletters and advertising material;
in the presence of specific consent, to receive updates on our activities and reports on the posting of our blog or website;
in the presence of specific consent, to receive promotional communications and invitations to events, training courses, webinars, special promotions or to participate in market analysis and research;
in the case of sending curriculum vitae, exclusively for selection purposes.
The legal basis for processing is the execution of a contract of which the data subject is a party or the execution of pre-contractual measures taken at the request of the latter. In the cases expressly indicated, the legal basis is the consent freely given by the interested party.
Data collected through the Chinchio platform.
For complete information we specify that in sending the communications, Chinchio can use third-party platforms that, through statistical tracking systems (for example web beacons), allow to detect the opening of a message, the clicks made on the hypertext links contained within the email, from which IP address or which type of browser the email is opened with, and other similar details. The collection of such data is functional to the use of the platform and is an integral part of the functionality of the system for sending messages.
The legal basis which legitimizes the processing of such data is the execution of a contract to which the data subject is a party.
3. Nature of the contribution
Apart from that specified for navigation data and for data collected through third-party platforms, the provision of data:
with respect to the purposes set out in letters a), b) and f), it is optional but any refusal will result in the impossibility for Chinchio to implement the contractual commitments undertaken.
with respect to the purposes set out in letter c), d) and e) it is also optional and their use is conditional upon the issue of an explicit consent. Any refusal will result in the impossibility for Chinchio to send newsletters and advertising material or invitations to events and initiatives of Chinchio
4. Processing methods and data retention times
The collected data will be processed using electronic or automated means, computerized and telematic, or by manual processing with logic strictly related to the purposes for which the personal data were collected and, in any case, in such a way as to guarantee the security of the data itself. The data is kept for the time strictly necessary for the management of the purposes for which the data are collected in compliance with current regulations and legal obligations.
In any case Chinchio applies rules that prevent the retention of data indefinitely and therefore limits the storage time in compliance with the principle of minimization of data processing.
5. Subjects authorized to process, responsible and communicate data
The processing of the collected data is carried out by internal personnel of Chinchio identified for the purpose and authorized for the treatment according to specific instructions given in compliance with current legislation.
The data collected, if necessary or instrumental for the execution of the indicated purposes, may be processed by third parties appointed external processors, or, depending on the case, communicated to them as independent owners, namely:
companies belonging to our corporate group for the purposes set out in point 1 lett. a), b) and f);
people, companies, associations or professional offices that provide assistance and advice to our Company, for the purposes set out in point 1 lett. b) and f);
companies, institutions, associations that perform services connected to and instrumental to the execution of the above mentioned objectives (market analysis and research service, credit card payments management, computer systems maintenance).
The collected data may also be transferred abroad, to companies that are not part of our corporate group, even outside the European Union in the forms and methods provided for by current legislation, guaranteeing in any case an adequate level of protection .
In any case, personal data will never be disclosed.
6. Rights of the interested party
At any time you can access the data, oppose the processing or request the cancellation, modification or updating of all personal information collected by Chinchio, exercising the right to limit the processing and the right to the portability of data, by sending an email to firstname.lastname@example.org
7. Responsible for data protection
The owner has appointed the person in charge of data protection who can be contacted at the following e-mail address email@example.com
Last updated: March 29, 2018