Dear User/Data Subject
The present document is pursuant to article 13 of Legislative Decree of 30 June 2003, n. 196 and successive modifications (known as the Privacy Code) as well as pursuant to article 14 of Regulation EU 2016/679 of the European Parliament and Council of 27 April 2016.
We inform you that the personal data provided by yourself in consulting the website www.zenam.it will be processed by the Administrative Office as Data Controller (hereinafter also Controller) in respect of the principles of protection set out by the Code with regards to personal data and successive modifications, as well as all European and national laws and/or measures applied by Supervisory Authorities.
We inform you that the voluntary sending of email to the addresses indicated on this website, as well as the completion of contact forms requires the acquisition of the sender’s address, which is necessary for responding to requests, as well as any other personal data included in the communication.
We inform you that ZENAM may, in the event that you have provided your address and consent, send you proposals via email for the purchase of products or services similar to those which you have already requested. In this case, we will ensure that you are reminded that you maintain the right to not receive further similar communications and that during navigation on the website of ZENAM technical cookies may be installed on your browser in order to improve your user experience.
You will find further information regarding said cookies and the relative processing in the paragraph “COOKIES”.
A. PURPOSES OF DATA PROCESSING
The processing of data spontaneously provided telematically by the User during navigation via the completion of the forms (contacts, newsletter and checkout) is carried out by ZENAM for the following purposes:
a. to allow us to respond to the requests made by yourself. For this purpose the following information is requested: name, surname, company, email address and telephone number (the latter is optional);
b. with prior consent, for the effective establishing and management of commercial relations, with particular reference to promotional, advertising, marketing purposes regarding products and services supplied by ZENAM;
c. with prior consent, to analyse your habits and choices for the sending of the most appropriate forms of commercial material according to the characteristics of the above.
B. TYPE OF DATA COLLECTED AND PROCESSES
Without prejudice to the personal autonomy of the Data Subject and without prejudice to the provision of navigation data, the provision of the data specified in paragraph A letter a) is obligatory, and the non-provision, even partial, of the data expressly indicated as necessary will result in the impossibility for ZENAM to proceed with the carrying out of the request made. Obligatory data are marked with an asterisk. The provision of data specified in paragraph A letters b) and c) is optional and the non-provision for said purposes will result in the impossibility to keep Users up to date on promotional sales initiatives.
C. CONTROLLER, PROCESSORS AND AGENTS
The data controller is ZENAM, represented by its pro tem legal representative located at Vicolo San Giovanni; email: email@example.com.
We inform you that you may contact the data processor via the company contact information above.
We inform you that the Data provided will be processed by: Administrative Department as data processing agent.
D. PROCESSING METHODS
The Personal data provided will be processed at the offices of ZENAM also via the use of automated procedures in the ways and within the limits necessary for the aforementioned purposes. We also inform you that the Personal data provided will be processed with the use of computerised procedures in the ways and limits necessary for the aforementioned purposes.
The controller makes use of the services provided by Valeo Studio srl, external provider of Housing services, based at Vai Daste e Spalenga 11, Bergamo.
E. PERIOD OF STORAGE
We inform you that the Data provided will be processed and stored by the Controller strictly for the purposes specified in point A and stored by the Controller for the period of time strictly necessary for the carrying out of the requests made by the User. At the end of the period of storage, the data will be cancelled/destroyed.
F. RIGHTS OF THE DATA SUBJECT
As data subject, you may at any time exercise your rights with the Data Controller pursuant to Legislative Decree 193/2006 and to Regulation EU 2016/679 presented below.
G. RIGHT TO ACCESS – article 15 of Regulation EU 2016/679
1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
a) the purposes of processing;
b) the categories of personal data concerned;
c) the recipients or categories of recipients to whom the personal data were or will be communicated, in particular recipients in third countries or international organisations;
d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
f) the right to lodge a complaint with a supervisory authority;
g) where the personal data are not collected from the data subject, any available information as to their source;
h) the existence of automated decision-making, including profiling referred to in Article 22(1) and (4), and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
II. RIGHT TO RECTIFICATION – Article 15 of Regulation EU 2016/679
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
III. RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”) – Article 17 of Regulation EU 2016/679
1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
d) the personal data have been unlawfully processed;
e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
a) for exercising the right of freedom of expression and information
b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
e) for the establishment, exercise or defence of legal claims.
IV. RIGHT TO RESTRICTION OF PROCESSING – Article 18 of Regulation EU 2016/679
1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
V. RIGHT TO DATA PORTABILITY – Article 20 of Regulation EU 2016/679
1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
b) the processing is carried out by automated means.
2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
VI. RIGHT TO OBJECT – Article 21 of Regulation EU 2016/679
1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such purposes, which include profiling to the extent that it is related to such direct marketing.
3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
GENERAL RULES FOR THE EXERCISING OF RIGHTS
We inform you that the rights specified in the paragraphs above can be exercised at any time by sending an email to the following address: firstname.lastname@example.org
together with a digital copy of your valid identification document. We remind you that in the event of a request for interruption of all processing of your personal data, we will not be able to continue to provide you with the services requested. In any case, our company may store certain personal data in the event that this may be necessary in order to defend or exercise our rights.
During standard operation, the computer systems and software procedures used to operate the website www.zenam.it acquire some personal data, the transmission of which is implicit in the use of internet communication protocols. This is information which is not gathered in order to be associated to identified data subjects, but which, for its very nature, could allow the identification of the user through processing of, and association with, data held by third parties. This category of data includes:
– IP addresses or domain names of computers used by the Users connected to the website;
– the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to make the request to the server, the size of the file received in response, the numerical code indicating the status of the response provided by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s computing environment.
These data are used solely to gather anonymous statistical information regarding the use of the website and in order to monitor its correct functioning and are cancelled immediately after being processed.