PRIVACY & COOKIES

1 PERSONAL DATA PROCESSED and PROCESSING

By “personal data” we mean all information that could either directly or indirectly allow users to be identified.

Such information, for example, can be: name, address, username, e-mail address and telephone number, or even the IP address of the device used, browsing preferences or information relating to your lifestyle or your hobbies and interests as well as your online shopping preferences.

The personal data processed are those provided voluntarily by the user (e.g. common data such as identification data, telephone number or e-mail address) and those collected by tracking technologies (cookies). The Data Controller processes these data in compliance with the applicable legislation, assuming that they refer to you, or to any third parties who have given you their authorization to process them. With respect to the data of third parties entered in the fields to be filled in on the website, you shall consider yourself as an independent data controller, assuming every obligation and related responsibility of the law about such a matter. In this sense, you are granting the Data Controller the widest indemnity on this matter against any disputes that may arise from any third party involved relating to the processing of their data entered on this Website.

By “processing of personal data” we mean any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or a set of personal data, such as the collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction.

2 DATA CONTROLLER

The “data controller” is the natural or legal person, public authority, service or other body which, either individually or together with others, determines the purposes and the means of processing personal data. He/She is also in charge of safety profiles.

With regard to this Website, the Data Controller is the company specified and identified above, and if you need any clarification or exercise of your rights, please contact them to the following email address: simec@simecsrl.it.

3 DATA PROCESSOR

The “data processor” is the natural or legal person, public authority, service or other body that processes personal data on behalf of the Data Controller.

With regard to your personal data provided while browsing this Website, the Data Controller has appointed Google Analytics as the data processor, pursuant to and for the purposes of art. 28 of the EU Reg. 2016/679.

For further information please contact: simec@simecsrl.it.

4 PROCESSING METHOD

On this Website, data are collected electronically and processed through operations carried out mainly with the aid of electronic tools, also making sure that suitable measures for the safety of the data processed are taken and guaranteeing their confidentiality. Specifically, data processing is carried out by minimizing the use of sensitive personal data.

Your personal data shall be processed by collaborators and/or employees of the Data Controller as managers or processors, within the scope of their respective functions and in accordance with the instructions given by the Data Controller.

5 PLACE OF PROCESSING AND SCOPE OF DATA CIRCULATION

The processing of personal data relating to the services of the Website takes place at the Data Controller’s place specified above and shall be handled exclusively by authorized personnel.

Your personal data may be disclosed to Judicial Authorities and Police Forces only in the cases in which this is required by law and used by the Data Controller for the purposes of any defence of their rights in court, where strictly necessary.

The collected data will not be disclosed. However, for the actual execution of the requested service, some data will be shared with external parties, appointed as data processors pursuant to art. 28 of the EU Reg. 2016/679, in charge of carrying out specific tasks on behalf of the company (e.g. web agencies, freelancers, etc.). The Data Controller undertakes to protect the security of personal data by adopting all the IT and physical measures necessary for the protection of the personal data provided. No security system guarantees this protection with absolute certainty, therefore, except in cases of liability due to fault, the Data Controller shall not be deemed to be liable for actions accomplished by third parties who may illegally access the systems without the necessary authorizations.

6 PURPOSE OF PROCESSING and TYPE OF PROCESSED DATA

• providing Services through the Website, allowing you to contact the Data Controller for information related to the Data Controller's activity, to request information regarding the products or services displayed or described online on the Website, and providing you with any other Service or information you may require and available to the Data Controller. Filling out the various enquiry forms shall not be considered for the Data Controller any takeover of legal obligations, nor any formal start of a pre-negotiation. For the processing of common data of third parties given when filling out the form, the Data Controller shall process these data in compliance with the applicable legislation, assuming that they refer to either you or to third parties who have expressly authorized you to provide them on the basis of an appropriate legal basis that legitimizes the processing of the data involved. With respect to these hypotheses, you shall act as an independent data controller, taking over all the obligations and responsibilities set forth by the law. As far as this is concerned, you undertake to give the widest indemnity with respect to any dispute, claim, request for compensation for damage from processing, etc. that should be made towards the Data Controller by any third party whose personal data have been processed by filling out the form (purposes of “Provision of the Service”). The data processed are common data. The Data Controller invites the user not to enter confidential data (concerning for example their health conditions, be it physical or psychological, political or religious orientation, etc.) unless strictly necessary for the purpose of requesting information or purchasing products;
• sending you marketing communications, promotions and advertisements, including through the e-mail address that you entered in the newsletter and / or in the fields filled out (purposes of “Marketing”). The data processed are common data;
• sending you marketing communications via e-mail regarding products and services similar to those you purchased through the Website, or for the management of technical and analytical cookies on the Website (“Soft Spam”). The data processed are common data;
• sending you commercial communications in line with your preferences (“Profiling”)
• statistically monitoring the turnout to the site in aggregate format(“Analysis”);
• fulfilling legal obligations that require the Data Controller to collect and/or further process certain types of personal data (purposes of “Compliance”). The data processed are common personal data;
• preventing or identifying any abuse in the use of this Website, or any fraudulent activity and therefore allowing the Data Controller to defend themselves in court (purposes of “Abuse and Fraud Prevention”). The data processed are common personal data.

7 LEGAL BASIS FOR DATA PROCESSING

The legal basis for the processing of personal data provided by you through navigation is:

• Provision of the Service: the fulfilment of contractual or pre-contractual obligations pursuant to art. 6, paragraph 1, letter b). Processing for this purpose is necessary in order to be able to provide you with the requested service (for example requesting information relating to the products or services of the Data Controller) and to answer to your questions or enquires. It is not mandatory to provide the personal data requested, however failure to indicate them does not allow the requested service to be provided and therefore to fulfil any enquires. As for the e-mail address entered in the contact form, it is not mandatory to provide your data (e-mail address), however failure to provide the e-mail address will not allow to subscribe to our newsletter. You can always - and at any time - revoke your subscription by unsubscribing from the newsletter using the appropriate link at the bottom of the newsletter or by writing to simec@simecsrl.it.
• Marketing: the consent pursuant to art. 6, paragraph 1, letter a). The activity is also carried out through the newsletter (if the service is active) with promotional content. It is not mandatory to give your consent for Marketing purposes, and you can always revoke it at any time without any consequence (other than not receiving any marketing communication any longer) by writing to simec@simecsrl.it.
• Soft Spam: the legitimate interest pursuant to art. 6, paragraph 1, letter f) of the Data Controller in sending you products similar to those already purchased and therefore in line with your interests. You can object to this processing at any time by writing to simec@simecsrl.it without any consequence (other than not receiving any promotional communication any longer);
• Profiling: the consent pursuant to art. 6, paragraph 1, letter a). The activity is carried out by applying profiling cookies. The data processed are common data. You can object to this processing at any time by writing to simec@simecsrl.it without any consequence.
• Analysis: the legitimate interest pursuant to art. 6, paragraph 1, letter f) of the Data Controller;
• Compliance: the fulfilment of a legal obligation pursuant to art. 6, paragraph 1, letter c). The processing for this purpose is necessary for the Data Controller in order to fulfil the legal obligations set forth by the legislation, including those specific for certain sectors, such as fiscal, tax or other obligations.
• Abuse and Fraud Prevention: he legitimate interest pursuant to art. 6, paragraph 1, letter f). Processing for this purpose serves exclusively the purpose to allow the Data Controller to prevent and/or identify any fraudulent activities committed through the Website and therefore defend themselves in court.

8 DATA RETENTION PERIOD

Data processed to fulfil legal obligations shall be kept until such obligations are fulfilled, and in any case for a period of time necessary to demonstrate the fulfilment; the data processed to fulfil contractual purposes shall be kept up to their fulfilment and, if a contract is signed or if there are pre-contractual negotiations, for ten years from the date in which the contract was signed in order to allow any judicial or extrajudicial protection and to demonstrate the correct fulfilment of the obligations taken according to the contract. The data processed for marketing and profiling purposes shall be kept until the consent is revoked by the party involved.

With regard to the activity of commercial communications of soft spam via e-mail and for the management of technical and analytical cookies, data shall be kept until the party involved will oppose it, whose procedure shall be followed in the manner indicated below, or for the processing based on consent, up to when such a consent is revoked. Data processed for Compliance purposes shall be kept for the period of time indicated by the specific legislation.

Data processed for the purposes of Abuse and Fraud Prevention shall be kept for the time strictly necessary to allow the Data Controller to defend themselves in court.

9 RECIPIENTS OF PERSONAL DATA

The personal data you provide may be disclosed to the Data Controller and/or any appointed data processors.

Any additional categories of recipients who may become aware of your personal data during or after the execution of the contract are:

1. entities who process data to fulfil specific legal obligations;
2. consultants and external professionals who provide functional services, deriving from or connected to the aforementioned purposes (e.g. marketing activities), identified in writing and to whom specific written instructions have been given with reference to the processing of personal data;
3. entities with whom it is necessary to interact to provide the requested services (e.g. hosting providers, credit institutions);
4. persons authorized by the Data Controller to process personal data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of the Data Controller);
5. in general, all those public and private entities for which communication is necessary for the correct and complete fulfilment of the indicated purposes;
6. entities or organizations to which it is mandatory to communicate data for the purposes of Compliance, prevention of abuse and fraud, or by order of the authority.

10 DISCLOSURE OF DATA

Without prejudice to your specific written request, or specific order of the Judicial Authority/regulatory obligation, the personal data you provide are not subject to disclosure.

11 TRANSFER OF DATA

To provide certain services, personal data may be transferred to organizations or third countries, where the hosting servers or suppliers are located.

Should this event occur, the Data Controller ensures that the processing of your personal data by these recipients is made in compliance with the applicable legislation on applicable data protection, including the European and Italian legislation to which we are subject. Where required by the European data protection legislation, the transfer of your Data outside the European Union shall be made on the basis of adequate guarantees (such as the standard contractual clauses of the European Union for the transfer of data between EU countries and countries outside the EU) and/or other legal bases under the EU legislation.

For further information please contact simec@simecsrl.it.