1. THE DATA PROCESSING “OWNER”, pursuant to art. 28 of the Code for the protection of personal data, is SOFAR SpA, in the person of its legal representative for the time being.
THE DATA PROCESSING MANAGER, pursuant to art. 29 of the Code for the protection of personal data, is Marco Martena, who is in charge of internal processing.
2. Types of data processed
Personal and identification data
Personal data consists of any kind of information about a natural person, whether identified or identifiable, directly or indirectly, by reference to any other information, including a personal ID number; Identification data consists of personal data that allows direct identification of the interested party (such as name, surname, date of birth, address, e-mail address, telephone number etc.).
The IT systems and software procedures dedicated to the functioning of this site obtain, as part of their normal activities, certain personal data whose transmission is inherent to the use of Internet communication protocols.
This information is not collected for association with identified interested parties but, given its nature, it could allow the identification of users following further processing and association with other data held by third parties.
This category of data includes the IP addresses and the domain names of the computers used by visitors to the site, the URI (Uniform Resource Identifier) 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 response, the numeric code indicating the status of the response given by the server (completed, error etc.) and other parameters relating to the operating system and the user’s IT environment.
This data is used solely to obtain anonymous statistical information about use of the site and ensure that it is functioning properly; it is deleted immediately after processing.
Defence in court
The Personal Data of the User may be used to defend the Owner in court or at the pre-trial stage in relation to the improper use of such data or related services by the User. The data may be used to determine the responsibility for possible IT crimes committed against the site.
The Personal Data of the User may be processed in additional ways and for other reasons for maintenance-related purposes.
Data provided voluntarily by the user
The optional, explicit and voluntary sending of e-mails to the addresses indicated on this site and/or the completion of data collection forms involves the subsequent acquisition of the sender’s e-mail address, needed in order to respond to the requests, as well as any other personal data included in the message.
3. Purposes of processing for which consent is given if requested (art. 23 of Leg. Decree no. 196/03)
The personal and possibly sensitive data supplied on a voluntary basis will be processed for the following purposes, unless objections are received:
– browsing this website;
– any contact requests, with transmission of the information requested by you;
– various administrative-accounting activities. For the purpose of applying the instructions on the protection of personal data,
the processing carried out for administrative-accounting reasons relates to organisational, administrative, financial and accounting activities, regardless of the nature of the data processed. In particular, processing for such purposes includes internal organisational activities, those related to the performance of contractual and pre-contractual obligations, and information-providing activities.
4. Methods of processing – Storage
The processing will be carried out automatically and/or manually, on a basis and using tools that guarantee the maximum security and confidentiality, by parties specifically appointed to perform such work pursuant to arts. 31 et seq. of Leg. Decree no. 196/03. The data will be retained for a period no longer than that required for the purposes for which the data was collected and subsequently processed.
5. Extent of communication
Your data, collected for processing, will only be communicated on the basis stated in the following consent request disclosure and may be communicated to companies that are contractually bound to SOFAR SpA, situated abroad within the European Union, in compliance with and within the limits contained in art. 42 of Leg. Decree no. 196/2003. Personal data may be transferred abroad to non-EU countries in the context of and within the limits contained in arts. 43 and 44 letter b) of Leg. Decree no. 196/2003, in order to comply with contracts or for related purposes. The data may be communicated to third parties belonging to the following categories:
– parties that provide the IT and telecommunications management services used by SOFAR SpA (including the e-mail system);
– offices and companies that formally provide support and advice;
– competent authorities for compliance with legal requirements and/or the instructions of public bodies, upon request.
The parties belonging to the above categories either act as Data Processing Managers or independently, as separate Data Processing Owners. The list of responsible persons is updated constantly and is available at the offices of SOFAR SpA. Any further communications of data will only take place after obtaining your explicit consent.
6. Nature of provision and refusal
Except as stated in relation to navigation data, users are free to supply their personal data or otherwise. The provision of such data is optional but necessary. Failure to provide data may make it impossible to obtain the service requested or to use the services offered by the data processing owner.
7. Rights of interested parties
You may exercise your rights pursuant to arts. 7, 8, 9 and 10 of Leg. Decree no. 196 of 30 June 2003 by contacting the data processing owner or manager at our offices, either by telephoning +39 02 9093621 or by sending an e-mail to firstname.lastname@example.org. You are entitled, at any time, to obtain confirmation of the existence or otherwise of your data, to know its content and origin, to check its accuracy and to request additions, updates or corrections (art. 7 of the Code for the protection of personal data).
The same article grants you the right to request the deletion, transformation into anonymous form or blocking of data processed in violation of the law, as well as to object in all cases, for legitimate reasons, to the processing of the data.
If you contact the data processing owner, please provide your e-mail address, name, address and/or telephone number so that your request can be administered correctly.
8. Changes to the privacy information
The data processing owner reserves the right to amend, update, add or remove parts of the privacy information at any time and at its sole discretion. Interested parties should check periodically to see if changes have been made.
In order to facilitate such checks, the information will contain the date of the latest revision. Use of this site after the publication of changes shall represent acceptance of such changes.
Revision date: 2 September 2014
The data processing owner is: SOFAR SpA, with registered offices at Via Firenze 40 – 20060 Trezzano Rosa (MI), in the person of its legal representative for the time being, Anna Labruzzo.
The webmaster is: Marco Martena, c/o the offices of the data processing owner.