Pursuant to the new GDPR - EU Privacy Regulation 679/2016, we provide below some information on how CONVERTINO MARTINO processes the personal data of:
a) users of web services accessible from the website and / or any other subdomain owned by CONVERTINO MARTINO
b) customers, suppliers, journalists and representatives of communication bodies, third party partners
c) other general users of the website (who are the interested party and / or another person who is presumed to have authorized the same)
The rules provided here apply when you access our sites by browsing the web pages even without registering and without filling in or entering data in web forms. These rules do not apply to any websites operated by third parties that may be accessible by the user through links contained on our sites.
Types of data
Through the web forms available on the sites we never ask you for "particular" personal data (personal data suitable for revealing racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions , associations or organizations of a religious, philosophical, political or trade union nature, as well as personal data suitable for revealing the state of health and sexual orientation) or "judicial" (data relating to criminal records, or relating to the status of defendant or of suspect, etc.). The data we process can be of two general categories: navigation data and data actively provided by the interested party.
When you access the site (also via mobile) or use our. services through this site or via mobile (your smartphone, tablet), the computer systems and software procedures used to operate this website acquire, during their normal operation, some information about you, which can be qualified as "personal data" whose transmission is implicit in the use of Internet communication protocols.
This category of data includes the hardware model, the operating system and version, information on the mobile network and the country from which access is made, the time of the request, the method used to submit the request to the server, the time access, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), the details of the itinerary followed within the web pages with particular reference to the pages visited and other parameters relating to the operating system and the user's IT environment (browser used, version, geographical position, last page visited before accessing the services of the CONVERTINO MARTINO site) and the unique device identifiers (eg. IP address or domain names of the computers used by users, the address in URI notation - Uniform Resource Identifier, MAC address - Media Access Control).
It is also information collected through cookies and / or other tracking technologies, on which see below.
This is information that is not collected to be associated with identified interested parties, but which by their very nature could, in theory, allow users to be identified through processing and association with data held by third parties. However, these data are used only to obtain statistical information in aggregate and anonymous form on the use of the site, to better understand the user's browsing behavior in order to offer the user a better browsing experience, to make technical functionalities possible. of the site, to check and optimize its functioning, to improve the quality of the services offered by the site as well as to guarantee the maintenance of the relative database and of the supporting IT infrastructure. In such cases, the navigation data do not allow the identification of the users concerned and are deleted within 12 months of collection after processing anonymously.
The navigation data can also be used to ascertain responsibility in the event of crimes against the Site or carried out through the Site (attempts at malware, spamming, unauthorized access to computer systems, etc.).
Data provided by the user in active form
By such are meant:
- the information sent by users on an optional and voluntary basis to the email addresses indicated on the Site or by filling in web forms (e.g. name and surname, date of birth, name or company name, physical address of residence, domicile or workplace, nationality , company organization or trade association to which it belongs, email, certified email account, mobile number, fax, product sector, VAT number or tax code, shipping or billing address, credit or debit card number, data on payment methods used) to access or register for, or use, services or content or to purchase services and products accessible on the Site or to participate in initiatives promoted through the Site, through the features made available through the Site and / or third-party sites;
- personal data provided by users who submit requests for news and / or information material ("newsletter");
- personal data provided by users who submit online proposals for job applications ("curriculum vitae", etc.).
When you spontaneously send an email to one of the email addresses listed on our sites, we acquire the sender address and any other personal data you have entered in the message and attachments. The e-mail boxes corresponding to the addresses indicated on our sites and any other CONVERTINO MARTINO e-mail boxes are not personal in nature even when they contain the name and / or surname of a natural person. They belong to the company organization and have the primary purpose of allowing the effective performance of work activities within the CONVERTINO MARTINO companies. This means that the messages forwarded to the email accounts of CONVERTINO MARTINO can be known further that by the recipient, also by other people belonging to the organization. By forwarding e-mails to the other e-mail addresses indicated on our sites, you declare that you have read and accepted the processing conditions contained in this policy.
The provision of data for some specific purposes (eg newsletter subscription, registration to restricted areas, product purchase, customer care, direct marketing, profiling) will involve the insertion of the data in the CONVERTINO MARTINO IT management system dedicated to management of customers, suppliers and other contacts, accessed only by authorized personnel.
Logics and forms of treatment. Security measures.
The logics and forms of processing organization will be strictly related to the purposes indicated above respectively. The treatments will take place electronically, electronically and / or on paper. The processing will take place in compliance with the principles of correctness, lawfulness, transparency and proportionality and all relevant legislation.
Appropriate security measures are applied to the processing of personal data and information of the interested party to ensure their integrity, security and availability. We store all personal information we receive in databases protected by an encrypted password that resides within our secure network, located behind the advanced active firewall software. The data managed at a computerized level can only be consulted by having access to the various data processing or entry programs, by typing in mandatory personal passwords by only personnel authorized by CONVERTINO MARTINO who need to have knowledge of them in the performance of their usual duties. (e.g. legal, commercial and marketing, administrative, logistics, IT, management control, etc.). The staff must in any case comply with predetermined written limitations of use imposed by CONVERTINO MARTINO (eg confidentiality obligations). The data is subject to a daily back-up procedure and a secure custody method, with off-site replication.
Our Web Services support secure HTTP protocol (HTTPS) connections with 2048-bit encryption and TLS v1.x (PCI DSS Compliance) protocol.
In the case of manual processing, the data are processed at the operational headquarters of CONVERTINO MARTINO and in any other place where the offices of any co-owners or external managers authorized by the Data Controller are located.
We reserve the right to conduct security checks (e.g. log analysis) at any time to validate your identity, age, registration data provided by you and to verify your use of the services and your financial operations as well as to verify the possible violation of the Conditions of Use of the CONVERTINO MARTINO website and about law in force. Security checks may include, by way of example, ordering a credit report and / or verifying the information provided to third party databases. Additionally, to facilitate these security checks, you agree to provide such information or documentation upon our request.
Our staff, agents and suppliers may use your personal information and communicate personal data to third parties for the purpose of validating the information provided to us in the course of using the services.
Purpose of the processing
The navigation data relating to users are processed by CONVERTINO MARTINO to manage access to the portal and the services that can be reached, manage technical practices, carry out all the activities necessary or useful for the constant improvement of the service provided, and for the ascertainment of responsibility in the event of crimes against the Site and / or offenses committed through the Site. Specific additional purposes relating to the individual treatments can be identified in detail, through supplementary information, within the various services included on the Site.
Data other than navigation data are processed by CONVERTINO MARTINO for primary and secondary purposes.
The primary purposes are:
1) satisfy pre-contractual needs (e.g. checks of solvency and customer risk control e.g. fraud also through data from public registers, lists, deeds or documents, instructing and fulfilling the specific requests received by the interested party for sending informative material such as bulletins, newsletters, answers to questions, notices, sending offers, specifications or price lists, etc.), and allow users to register on the site and access services and / or purchase products / services;
2) manage contracts with the interested party (supply or purchase of products and / or services such as website development, consultancy, activation of Google AdWords campaigns,monitoring of campaigns and sale of additional optional services, sale of advertising spaces not linked to campaigns, post-sale management of warranty claims, protection of CONVERTINO MARTINO in the litigation phase and to assert or defend a right in court) and / or obligations established by law, by a regulation or by community legislation (eg bookkeeping; formalities tax, administrative and accounting management; fulfillment of obligations regarding electronic communication services provided for by Legislative Decree no. 70 of 9 April 2003;);
3) carry out activities concerning the management of customers and suppliers, for a legitimate interest of CONVERTINO MARTINO or third party recipients of the data, such as: management of credit lines and risk control (prevention of unlawfulness, insolvency, etc.); litigation management and credit assignment or insurance; financial and insurance services instrumental to the management of customers / suppliers; management of electronic payment services; warehouse management, logistics and transport; management of after-sales assistance outside the warranty (via telephone, email and / or contact form on the Site); activation by registering, and subsequent management and technical and security maintenance, of the online account of the interested party connected to the CONVERTINO MARTINO website for access to the same and / or to the services made available therein (eg e- commerce ) and the password or similar authentication credentials; management and use of customer lists and personal data; sales management; relationship management with customers, buyers, other subjects.
4) carry out other organizational and production activities of CONVERTINO MARTINO based on a legitimate interest of CONVERTINO MARTINO such as quality system management, management control, general planning of strategic and operational marketing activities, customer database management, the production, printing and dissemination of promotional editorial materials on paper or via the web, the management of accreditation and involvement of communication bodies, media and referents of services connected to the performance of journalistic and promotional activities; the management of websites and marketing campaigns associated with customer accounts. In some cases, moreover, we ask you for your personal data (eg photographic images and video- audio) to allow you to participate in events, competitions and thematic initiatives of an extraordinary and temporary nature, which by their nature provide for the communication and dissemination of such data. In these cases we will notify you by asking you to give express and specific consent.
5) The following are secondary or direct marketing purposes:
ii) sending commercial and promotional communications and offers for the sale of goods and services of CONVERTINO MARTINO (eg invitations to events) and / or third party suppliers or other partners affiliated with it, through any means of electronic communication (eg email , phone calls with or without operator, text messages, social networks, etc.) and through traditional methods (eg ordinary mail);
iii) studies and market research.
CONVERTINO MARTINO will process the data for these purposes only with the necessary prior specific consent of the interested party (see below).
Legal basis of the processing
CONVERTINO MARTINO can lawfully process the data for the following reasons:
- In the case of the primary purposes, the processing is necessary, depending on the case, for the execution of pre-contractual measures adopted at the request of the interested party (e.g. requests for clarifications, sending information or commercial offers), for the execution of a contract of which the interested party is a party, or to fulfill a legal obligation to which CONVERTINO MARTINO is subject (e.g. to allow the verification of the correct fulfillment of legal and contractual obligations towards the interested party or towards third parties by the administrative authorities and tax, of the board of statutory auditors or auditors, etc.) and / or to pursue the legitimate interest of CONVERTINO MARTINO (prevailing over the interests or fundamental rights and freedoms of the interested party) to process the data in order to manage in effectively and efficiently the relationship with customers and / or suppliers and to organize the related production, organizational and management processes (including relations with its sub-f suppliers and / or with parent companies, subsidiaries or associates pursuant to art. 2359 of the Italian Civil Code or with companies under common control).
- In the case of secondary purposes (profiling, direct marketing), the processing is based on the prior specific free and informed consent of the interested party (subsequently not revoked), and, with regard to profiling, also on the legitimate interest of CONVERTINO MARTINO to promote its products and / or services to target customers based on more personal criteria such as tastes and preferences, belonging to certain geographical areas or gender, etc., so as to increase customer satisfaction and improve the personalization of offer, limiting commercial communication to issues of greatest individual interest.
Mandatory or optional consent
For the sole primary purposes of processing (provided above from 1 to 4) CONVERTINO MARTINO has its own legitimate interest in the processing. Therefore, the processing will be possible even without the consent of the interested party. In case of opposition to the processing CONVERTINO MARTINO will not be able to proceed with pre-contractual relationships, with the online registration of the interested party to the Website and with the provision of services or with the sale of products for which CONVERTINO MARTINO requests registration and / o the provision of data.
The unregistered user will be able to browse the Site and view only the content and materials available without registration. In relation to the secondary purposes of processing (profiling and direct marketing, referred to above in point 5) as well as for the communication of data from CONVERTINO MARTINO to third parties for the same secondary purposes, the consent of the interested party is always optional (free and deniable).
For the aforementioned purpose, consent must be given or denied by the interested party, separately for i) the processing carried out by CONVERTINO MARTINO alone and for ii) the communication of data by CONVERTINO MARTINO to third parties for the same purposes.
Failure to consent will prevent CONVERTINO MARTINO from processing and / or communicating the data to third parties for such secondary purposes, while it will not interfere with the pre-contractual or contractual relationships between CONVERTINO MARTINO and the interested party or the organization to which it belongs.
As permitted by current legislation and for the purpose of fulfilling privacy obligations by CONVERTINO MARTINO in compliance with the principles of simplification (referred to in the General Provision of the Privacy Guarantor of 05.15.2013 - "Consent to the processing of personal data for the purposes of" direct marketing "through traditional and automated contact tools"), the consent required by CONVERTINO MARTINO regarding the secondary purposes of profiling and direct marketing is unitary and comprehensive for all possible means used for processing for marketing purposes (electronic / telematic, paper), as well as for all possible direct marketing purposes (i.e. without multiplying the consent formulas for each distinct marketing purpose pursued).
NB: CONVERTINO MARTINO may process personal data, through the use of telephone calls with an operator and the use of ordinary mail, for the aforementioned secondary purposes, without the prior specific consent of the interested party (in this case the right of the 'interested in opposing the treatment with simplified methods and also electronically by registering the telephone number of which the interested party is the owner and other personal data relating to subscribers in the paper and electronic directories available to the public, in the Public Register of Oppositions (http://www.registrodelleopposizioni.it/) provided for by the Decree of the President of the Republic n. 178/2010).
In the event that CONVERTINO MARTINO requests - for direct marketing purposes - the telephone number and you have given the optional and specific consent to its use, CONVERTINO MARTINO can process it even if the user is registered by you in the Public Register of Opposition : as the number in this case is communicated by you and not taken from public telephone directories.
Legal waivers of the need for your consent for marketing purposes
We point out that the Privacy Code allows the so-called "soft spam". This means that without having to acquire your express consent, we can use the e-mail address you provided in the context of a previous purchase, in order to proceed, by sending via e-mail, to commercial communications and sales offers, provided they relate to products and services similar to those you have already purchased.
Upon receipt of any communication and / or promotional email sent by CONVERTINO MARTINO for the purposes already envisaged, you are informed of the possibility of opposing the processing at any time, in an easy and freeway.
Withdrawal of consent
Even after having given your consent to the processing of data for profiling and direct marketing purposes, as an interested party you can at any time notify CONVERTINO MARTINO of a different will, through one of the following alternative methods:
- by clicking on the "unsubscribe" button, made available to the user at the bottom of the promotional emails sent to the interested party by sending CONVERTINO MARTINO by ordinary mail or email his declaration of revocation of consent. This method of communication is always necessary in the event that the interested party wishes to express a more analytical selective will, either with regard to the use of certain individual means and not others (eg only paper, only electronic, only email, etc.) for the receipt, subject to consent, of marketing communications from CONVERTINO MARTINO, either with regard to individual marketing purposes among those concretely possible (for example by choosing to receive only advertising by paper mail and reject the one sent via automated systems);
- sending without formalities a clear telephone communication of revocation of consent to CONVERTINO MARTINO. Upon receipt of this opt-out request, CONVERTINO MARTINO will proceed to the removal and deletion of data from the databases used for processing for direct marketing purposes and, where possible , will inform any third parties to whom the data have been communicated for the same purposes of this cancellation. The simple receipt of the cancellation request will automatically be valid as confirmation of cancellation. The aforementioned opposition will not produce any consequences on the provision of any ongoing contract activities.
In the event that the interested party wants to revoke his consent to any advertising communications that come from social channels (eg Facebook), he must communicate the revocation directly to the individual social platform, according to the methods made available from time to time by the itself and / or by the browser in use (since CONVERTINO MARTINO is not technically able to influence third party social platforms for this purpose).
Communication of data to third parties
CONVERTINO MARTINO communicates your personal data to third party recipients only when this is necessary and functional to the achievement of the data processing purpose pursued according to the service or product requested by you, and in any case proceeds with the communication only after having informed you, and where necessary, having collected your consent to do so. Communication to third parties will always be limited to the data strictly necessary for the respective purposes. The third parts recipients of the data will process the data as independent owners (in this case CONVERTINO MARTINO does not assume responsibility for the processing of the data in question).
Dissemination of data
The data will not be disseminated, except in the event that - contractually and by law - publication on the CONVERTINO MARTINO website is envisaged (eg publication of photographs of events following a signed release).
Mergers and other events involving automatic transfer
In the event that CONVERTINO MARTINO accesses an insolvency procedure (bankruptcy, arrangement, etc.) or transfers its company or business unit to which the personal data belongs, or its shareholdings, in whole or in part to third parties, o there is a merger with third parties or the substantial transfer of all our assets or part of them to third parties, the third party assignees will be able to automatically acquire the availability of personal data and all other information provided by the interested party to CONVERTINO MARTINO. By using this website, the interested party allows this transfer of information, in the event that it is required as necessary by the applicable legislation.
Transfer of data abroad
The data is stored on the Owner's servers located at the latter's headquarters and / or on servers in EU countries of companies that provide the Owner with outsourced IT services (eg. Disaster recovery). The data may be transferred to countries of the European Union and to countries outside the EU in the event that CONVERTINO MARTINO makes use of website management services, e-mail and / of email direct marketing services provided by third party suppliers based or servers in those countries. In such cases, the transfer to third countries will take place in compliance with the GDPR (EU Privacy Regulation 679/2016) and therefore on the basis of a decision of the European Commission declaring the adequacy of the level of protection of personal data guaranteed by the third country, of a interstate convention eg. USA-Privacy Shield agreement) or, in the absence of such a decision, on the basis of adequate guarantees constituted by ad hoc written agreements between CONVERTINO MARTINO and the third supplier, or failing that, on the basis of your consent, if any.
Data retention period
The owner will process the data for the time necessary respectively to pursue the related purposes as stated above.
In the case of personal data for the processing of which the specific consent of the interested party is required, and this consent is optional and revocable, the processing of the data after the aforementioned term may continue after collection of a new consent from the interested party by the Data Controller and for a new period of time equal to that above.
In the event that personal data are processed for IT security purposes (eg recordings of logs), the data will be stored for the time sufficient to complete the related security checks and evaluate the results; normally these checks are completed within a maximum of 1 year (12 months) from the time of collection.
Holder of the treatment
The owner of the processing of personal data is:
V.le Chiatona, 105 – 74019 Palagiano (TA)
The internal authorized persons belong to the company functional areas that need to process the data for the purposes indicated in this information. In the case of external managers, the processing will take place on the basis of ours. directives and under our general periodic supervision of the security measures adopted by the third part.
Rights of the interested part
We inform you that the interested party will have the right to:
- ask the Data Controller to confirm whether or not personal data concerning him is being processed and, in this case, to obtain access to personal data and the following information: a) the purposes of the processing; b) the categories of personal data in question; c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if they are recipients of third countries or international organizations; d) when possible, the retention period of the personal data envisaged or, if not possible, the criteria used to determine this period; e) the existence of the right of the interested party to ask the data controller to rectify or delete personal data or limit the processing of personal data concerning him or to oppose their treatment; f) the right to lodge a complaint with a supervisory authority; g) if the data are not collected from the data subject, all available information on their origin; h) the existence of an automated decision-making process, including profiling and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the data subject.
– qualora i dati personali siano trasferiti a un paese terzo o a un’organizzazione internazionale, l’interessato ha il diritto di essere informato dell’esistenza di garanzie adeguate relative al trasferimento;
– richiedere, ed ottenere senza ingiustificato ritardo, la rettifica dei dati inesatti; tenuto conto delle finalità del trattamento, l’integrazione dei dati personali incompleti, anche fornendo una dichiarazione integrativa;
– richiedere la cancellazione dei dati se a) i dati personali non sono più necessari rispetto alle finalità per le quali sono stati raccolti o altrimenti trattati; b) l’interessato revoca il consenso su cui si basa il trattamento e non sussiste altro fondamento giuridico per il trattamento; c) l’interessato si oppone al trattamento, e non sussiste alcun motivo legittimo
prevalente per procedere al trattamento, oppure si oppone al trattamento operato per finalità di marketing diretto (compresa la profilazione funzionale a tale marketing diretto); d) i dati personali sono stati trattati illecitamente; e) i dati personali devono essere cancellati per adempiere un obbligo legale previsto dal diritto dell’Unione o dello Stato membro cui è soggetto il titolare del trattamento; f) i dati personali sono stati raccolti relativamente all’offerta di servizi della società dell’informazione.
– richiedere la limitazione del trattamento che riguarda l’interessato, quando ricorre una delle seguenti ipotesi: a) l’interessato contesta l’esattezza dei dati personali, per il periodo necessario al titolare del trattamento per verificare l’esattezza di tali dati personali; b) il trattamento è illecito e l’interessato si oppone alla cancellazione dei dati personali e chiede invece che ne sia limitato l’utilizzo; c) benché il titolare del trattamento non ne abbia più bisogno ai fini del trattamento, i dati personali sono necessari all’interessato per l’accertamento, l’esercizio o la difesa di un diritto in sede giudiziaria; d) l’interessato si è opposto al trattamento svolto per finalità di marketing diretto, in attesa della verifica in merito all’eventuale prevalenza dei motivi legittimi del titolare del trattamento rispetto a quelli dell’interessato.;
– ottenere dal titolare del trattamento, su richiesta, la comunicazione dei terzi destinatari cui sono stati trasmessi i dati personali;
- withdraw at any time the consent to the processing where previously communicated for one or more specific purposes of their personal data, it being understood that this will not affect the lawfulness of the processing based on the consent given before the revocation.
- receive in a structured format, commonly used and readable by an automatic device, the personal data concerning the interested party provided by them to the Data Controller and, if technically feasible, to have such data transmitted directly to another data controller without impediments by the Data Controller to whom he provided them, if the following (cumulative) condition occurs: a) the processing is based on the consent of the interested party for one or more specific purposes, or on a contract of which the interested party is a party and to which execution of the treatment is necessary; and b) the processing is carried out by automated means (software) (overall right to the so-called "portability"). The exercise of the so-called right portability is without prejudice to the right to cancellation provided above; - the interested party has the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or which significantly affects his person in a similar way. - the interested party can at any time also lodge a complaint with the competent supervisory authority under the GDPR (that of his place of residence or domicile).
In case of violation of his rights, the interested party can lodge a complaint with the European Data Protection Committee. For a complete examination of the rights of the interested party under the new GDPR, consult the text of articles 15, 16, 17, 18 , 19, 20, 21, 22 of the same.
The interested party can exercise his rights by writing to the Data Controller.
V.le Chiatona, 105 – 74019 Palagiano (TA)
It is possible to request a list of Autonomous Data Controllers, co-Controllers and external Data Processors.