Privacy eng
INTRODUCTION
Last update: 30/03/2020 – v0.00
The European Data Protection Regulation (GDPR) replaces the European directive 95/46/EC. The Regulation aims to provide a modern, uniform and solid framework for data protection in Europe based on the principle of accountability. The new forecasts have an impact in organizational, operational and technological terms, and at the same time establish a more severe sanctioning system than the previous one.
The biggest change in the data protection regulatory landscape concerns the extensive jurisdiction of the GDPR, as it applies to the processing of personal data carried out within the activities of an establishment by a data controller or a data processor in the European Union, regardless of whether the processing is carried out in the European Union or not. Furthermore, the Regulation applies to the processing of personal data of data subjects who are located in the Union, carried out by a data controller or by a data processor who is not established in the Union, when the processing activities concern: the offer of goods or the provision of services to the aforementioned data subject in the Union, regardless of the obligation of a payment by the data subject; or, monitoring their behavior to the extent that such behavior takes place within the European Union.
The Regulation also applies to the processing of personal data carried out by a data controller who is not established in the Union, but in a place subject to the law of a Member State under public international law.
The GDPR requires companies to implement adequate technical and organizational measures to implement the principles of data protection and safeguard individual rights: this is the so-called “Data Protection by Design and by Default”. The “Data Protection by Design” ensures that the company considers the problems related to privacy and data protection in the design phase of any system, service, product or process and therefore during its cycle of life. The “Data Protection by Default” requires Favini S.r.l. to ensure that the Company processes only the data necessary to achieve a specific purpose and for a period of time no longer than the one that is necessary for the purpose for which the data were collected and subsequently processed. Favini S.r.l. has adopted a Management Model for the Protection of Personal Data pursuant to the GDPR, also taking into account the provisions of Legislative Decree 196/2003, as amended by Legislative Decree 101/2018, defining binding rules and procedures for the Company and for its employees. Favini S.r.l. revises and updates, where necessary, periodically its Policy on Data Protection and Information Security, and defines evolutionary guidelines that it translates into an implementation plan of updates. In the various documents published in the “Privacy” section of its websites, Favini S.r.l. provides, in accordance with art. 13 of the GDPR, all the information required by the legislation, which are different according to the purpose for which the Personal Data of the Data Subjects are processed. For any further clarification regarding the content of Favini’s Privacy notices, the user is invited to contact our contact person on the matter identified, at the email address: [email protected].
GENERAL
Last update: 30/03/2020 – v0.00
INFORMATION ON THE PROCESSING OF PERSONAL DATA PURSUANT TO ART. 13 GDPR (EU Reg. 2016/679)
Favini S.r.l., owner of the site www.favini.com (hereinafter also the “Site”), intends to give information on how the Site is managed in relation to the processing and protection of the personal data of the data subjects who browse the Site.
This document represents an information pursuant to the provisions of art. 13 of the European Regulation of 27 April 2016 n. 679 (hereinafter “GDPR”) and is valid only and exclusively for the Site owned by the Company and not for other sites that can be consulted by the user through links that may be activated through the Site.
This information may undergo changes following the introduction of new rules or revision of the same, or following changes to the Site, so we invite users to periodically visit this section.
1. Data controller
The Data Controller of the personal data provided on the Site is Favini S.r.l. (hereinafter also the “Company” or the “Data Controller”), located in Via Alcide De Gasperi No. 26 – Rossano Veneto (Vicenza), VAT number 03464230246.
For the purpose of exercising the rights provided by the Regulation and for any request relating to your personal data, you can contact the Data Controller, sending a communication to the email address [email protected] or a registered letter with return receipt to Favini Srl, Via Alcide De Gasperi n ° 26 – 36028 Rossano Veneto (VI).
Favini has appointed a data protection officer (DPO), who can be contacted by writing to the following address: [email protected].
2. Purpose and legal basis of the processing
The purposes for which the processings are carried out are the following:
a) Information request – Contact form
Personal data are collected and processed in order to respond to users’ requests for information on Favini’s products. The legal basis is provided by art. 6 par. 1 letter b) or f) of the European Regulation: “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”; “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”.
We inform you that on the website, at https://www.favini.com/products-converting/it/contatti.php, there is a contact form, owned by Cartotecnica Favini S.r.l., a company of the Favini Group. With reference to the data collected and processed through the aforementioned form, Favini S.r.l. acts as Data Processor having been specifically appointed by Cartotecnica Favini S.r.l. for this purpose, pursuant to art. 28 GDPR. For more information on this processing, we invite you to read the information pursuant to art. 13 GDPR made available by Cartotecnica Favini S.r.l at the bottom of this document.
b) Request samples (Casting Release section)
Personal data are collected and processed in order to process the request for samples sent by the user. The legal basis is provided by art. 6 par. 1 letter b) or f) of the European Regulation: “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”; “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”.
c) Working with us
The data you provide will be processed for the specific purpose of finding and selecting personnel, in particular to assess the consistency of your profile with respect to the job positions open at our Company and to make all the appropriate considerations regarding the possibility of establishing with you an employment or collaborative relationship.
For this purpose, we ask you to indicate in your curriculum only the data necessary to evaluate your application and to contact you in order to schedule a possible interview, avoiding from providing information not strictly relevant to the aforementioned purposes.
The legal basis for the processing of your personal data is mainly that provided by art. 6, lett. b) of the Regulation: “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”;
If the Company becomes aware of data concerning health, for the purpose of hiring workers belonging to protected categories, the processing will be based on art. 9 paragraph 2 lett. b) GDPR:
“processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject”.
When the candidate communicates further special categories of data as defined in art. 9 par. 1 of the Regulation (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, biometric data, data concerning a natural person’s sex life or sexual orientation), the legal basis of the processing will be that provided by art. 6, lett. a) of the Regulation:
“the data subject has given consent to the processing of his or her personal data for one or more specific purposes”. It’s clear that if in the curriculum there are special categories of personal data not relevant to the purpose of research and selection of personnel, such information will not be used to evaluate your application.
d) Direct marketing and newsletter
The data collected on the Site may be processed for direct marketing purposes, that is to send commercial communications to the Data Subject by traditional means as paper mail, but also via e-mail, SMS, landline and mobile phone service.
The legal basis for this processing is represented by art. 6, lett. a) of the Regulation: “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”.
We inform you that pursuant to art. 130, paragraph 4, of Legislative Decree 196/2003 and subsequent amendments (relating to the so-called “soft spam”), without having to acquire your express consent, we can use the e-mail address that you provided to us in the context of a previous purchase, for the purpose of direct sale and / or promotion of our products similar to those you have already purchased, provided that you do not object to such use by writing to the data controller or by clicking on the appropriate link to object to the receiving communications considered unwanted, made available within the promotional emails sent by our Company.
Newsletter. The newsletter is a communication with promotional and advertising content sent to all data subjects who request it. Registration for the newsletter implies the sending of generalized and / or even targeted promotional communications based on the data provided by the data subject (e.g. language, country of origin, interest in certain products). This means that we may process your data so that the newsletter sent is as close as possible to what you have requested and which may be of interest to you.
You can withdraw your consent to the processing of your data for marketing purposes and / or to send newsletters at any time, in the manner described in this Policy, or by clicking on the appropriate link to object to receiving communications considered unwanted, made available within the promotional emails sent by our Company. If the processing of your data for direct marketing purposes is based on the legitimate interest of the data controller, you also have the right to object to this processing, pursuant to art. 21 GDPR.
3. Types of personal data processed
Data provided by the user
As part of the various purposes mentioned above, data will be processed as listed below:
a) Information request – Contact form: name, surname, telephone, e-mail address;
b) Sample request: name, surname, e-mail address, address, postcode, city, country, telephone; fax; kind of activity;
c) Working with us: identification data (name, surname, place and date of birth, ); contact details (address, telephone number, e-mail); training, educational qualification, professional experience, technical knowledge. The candidate is invited, unless this is expressly requested by a search announcement addressed to workers belonging to protected categories, not to communicate health-related data, nor data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, biometric data, data concerning a natural person’s sex life or sexual orientation, and any information in any case attributable to the special categories of data referred to in art. 9 paragraph 1 of the Regulation. In the event that the curriculum sent to the Company also contains data falling within these categories, or if such data is provided to the Company on the occasion of any subsequent assessment interviews aimed at verifying the skills and conditions necessary for any recruitment, the Company will proceed with the processing only if the candidate has given his consent to the processing of these types of data. If in the curricula sent by the candidates there is data not relevant to the aim pursued, Favini will refrain from using this information.
d) Direct Marketing and Newsletter: common personal data such as name, surname, e-mail address, address, postcode, city, country, telephone; fax; type of business, etc .;
Contact form of Cartotecnica Favini S.r.l .: since it is a service owned by Cartotecnica Favini S.r.l., for any information regarding the personal data processed through it, we invite you to read the information pursuant to art. 13 GDPR made available by Cartotecnica Favini S.r.l. at the bottom of this document.
Data that we automatically collect
The computer systems and software procedures used to operate the Site acquire, during their normal operation, some data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature it could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers and terminals used by users, the addresses in URI / URL (Uniform Resource Identifier / Locator) notation of the requested resources, the time of the request, the method used in the submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Site or other users, only upon request from the supervisory bodies in charge.
4. Processing methods
The data collected are processed, exclusively by authorized subjects, with automated and non-automated tools, with suitable methods to guarantee the security and confidentiality of the data and for the time necessary to achieve the purposes for which they were collected.
5. Recipients or categories of recipients of personal data
The personal data Favini will come into possession of are not subject to disclosure. The data may be communicated within the Company and to other Favini Group Companies. They may also be communicated to authorized people (e.g. Favini’s employees) and to the data processors appointed by Favini pursuant to art. 28 GDPR.
We inform you that the data, depending on the case, may be communicated to:
a) financial institutions;
b) companies specialized in the detection and prevention of scams;
c) suppliers and collaborators of logistics, transport and delivery services;
d) suppliers of services related to customer support;
e) suppliers and collaborators of marketing and advertising services;
f) suppliers of web services and / or other outsourced services (e.g. sending newsletters etc.).
6. Transfer of personal data to third countries
The Company does not currently intend to transfer your personal data to third countries with respect to the European Union.
In any case, if this happens, Favini S.r.l. guarantees that this transfer will take place:
– towards companies belonging to the Favini Group and which adopt the same procedures regarding the processing of personal data, also through the adoption of binding corporate rules or corporate binding rules approved by the competent supervisory authority;
– to non-EU countries that the European Commission has deemed to guarantee an adequate level of protection (Art. 45 GDPR) or after stipulating standard contractual clauses approved by the European Commission.
Any exceptions to the above will only take place in compliance with art. 49 GDPR.
7. Data retention period
Information request – Contact form: personal data relating to requests for information from users will be kept for the time necessary to provide the answer to the data subject and in any case no later than 24 months from the request.
Sample request (Casting Release section): personal data relating to users’ requests for samples will be kept for the time necessary to process the request and for the following 24 months.
Working with us: the personal data collected through the “send your CV” form on the Favini website will be kept for a period of 12 months from receipt of the CV.
Contact form owned by Cartotecnica Favini S.r.l.: it’s a service owned by Cartotecnica Favini S.r.l., so please for any information regarding the data retention period read the information pursuant to art. 13 GDPR made available by Cartotecnica Favini S.r.l. at the bottom of this document.
Direct Marketing and Newsletter: the data processed for direct marketing purposes will be kept, as appropriate, for a period of 24 months from the release of consent and / or from the purchase made by you.
The data processed for sending newsletters will be kept for a period of 24 months from the registration / release of consent unless, before the expiry of the aforementioned term, we receive a request for unsubscription from you. In this case, we will delete your data from our databases within 72 hours of the unsubscription request.
At the end of the retention periods indicated above, your data will be permanently deleted or permanently anonymized. We inform you, however, that a longer period of retention of personal data may possibly be determined by requests made by the Public Administration or by another judicial, governmental or regulatory body or by the participation of the undersigned Company in judicial procedures involving the processing of personal data provided by you.
8. Mandatory and optional nature of providing data
The provision of your personal data is optional but nevertheless necessary to allow Favini to fulfill the purposes described above. Failure to provide it will in fact make it impossible for Favini to provide each individual service requested by you.
9. Rights recognized to the data subject
The data subject has the right to obtain access to personal data from the Data Controller. In particular, the data subject has the right to obtain: a) an indication of the origin of personal data, of the purposes and methods of processing, of the logic applied in case of processings carried out with the aid of electronic instruments; b) updating or rectification; c) the erasure or restriction of the processing of data concerning the data subject (transformation into anonymous form, blocking of data processed in violation of the law, including those which need not be kept for the purposes for which the data were collected or subsequently processed); d) the portability of the data processed in a structured way.
However, the data subject has the right to withdraw consent to the processing of personal data, for cases where the processing is based on its consent. In any case, the revocation of consent to processing does not affect the lawfulness of the processing based on the consent given before the revocation.
The data subject has the right to object at any time to the processing of its personal data, if the latter is based on the legitimate interest of the data controller and there are the conditions set out in art. 21 GDPR. In particular, the data subject has the right to object at any time to the processing of its data for direct marketing purposes.
To exercise these rights, the data subject can send a request to the Data Controller through:
– E-mail to [email protected];
– Registered letter with return receipt to the following address: Via A. De Gasperi n ° 26 – 36028 Rossano Veneto (VI)
The data subject residing in Italy also has the right to lodge a complaint with the Supervisory Authority, represented in Italy by the Guarantor for the Protection of Personal Data, based in Rome, Piazza Monte Citorio, 121. The data subject residing outside Italy may lodge a complaint before the designated Control Authority in its country of residence.
10. Inexistence of an automated decision-making process
The processings referred to in this Information notice are not subject to automated decision-making processes.
The Data Controller
Favini S.r.l.
CARTOTECNICA FAVINI
Last update: 30/03/2020 – v0.00
Information on the processing of personal data pursuant to ART. 13 EU Reg. 27 April 2016 n. 679
With this document Cartotecnica Favini S.r.l., a company of the Favini Group (hereinafter also “Company”), owner of the contact form referred to at https://www.favini.com/products-converting/it/contatti.php, present on the site www.favini.com (hereinafter the “Site”), owned by Favini S.r.l., intends to inform the data subjects about the processing and protection of the personal data of the data subjects who use the aforementioned contact form, as established by the art. 13 of the European Regulation of 27 April 2016 n. 679/2016 (“GDPR”).
Data Controller
The Data Controller is Cartotecnica Favini S.r.l. located in Rossano Veneto (VI), Via Alcide de Gasperi 26, VAT number: 0346230246.
For the purposes of exercising the rights provided by the Regulation and for any request relating to your personal data, you can contact the Data Controller by sending a communication to the email address: [email protected] or a registered letter with return receipt to Cartotecnica Favini S.r.l., Via Alcide De Gasperi n ° 26 – 36028 Rossano Veneto (Vicenza).
Cartotecnica Favini S.r.l. has appointed a data protection officer (DPO), who can be contacted by writing to the following address: [email protected].
Purposes and legal basis of the processing
Cartotecnica Favini S.r.l. processes the personal data provided by the user for the following purposes:
1) Contact form:
Personal data is collected and processed in order to respond to users’ requests for information on Cartotecnica Favini products. The legal basis is provided by art. 6 par. 1 letter b) or f) of the European Regulation: “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”; “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”.
Types of personal data processed
When the user contacts the Company by filling in the appropriate contact form Cartotecnica Favini S.r.l. processes:
– identification data (name, surname);
– contact details (e-mail, telephone number).
Optional or mandatory nature of the providing of data
The provision of personal data in the contact form is optional but nevertheless necessary to allow the Data Controller to reply to users’ requests. Any refusal to provide us, in whole or in part, with your personal data will therefore make it impossible for Cartotecnica Favini S.r.l. to provide the data subjects with the requested service / check their request for information.
Processing methods
The personal data provided by the user will be processed, exclusively by authorized subjects, with the support of IT or telematic means, however suitable to guarantee the security and confidentiality of the related processing.
The processings covered by this Information notice do not use automated decision-making processes or forms of profiling.
Recipients or possible categories of recipients of personal data
The personal data of which the undersigned Company will come into possession are not subject to disclosure. The data may be communicated within the Company and to other Favini Group Companies. In particular, the data will also be processed by Favini S.r.l., owner of the Site www.favini.com, which has been appointed data processor pursuant to art. 28 GDPR for the processings referred to in this Information notice.
The data may also come to the attention of subjects authorized for processing by Cartotecnica Favini S.r.l., as well as of the data processors appointed by Cartotecnica Favini S.r.l. pursuant to art. 28 GDPR.
We inform you that the data may be communicated to:
– financial institutions;
– companies specializing in the detection and prevention of scams;
– suppliers and collaborators of logistics, transport and delivery services;
– service providers linked to customer support;
– suppliers and collaborators of marketing and advertising services;
– web service providers and / or other outsourced services.
TRANSFER OF PERSONAL DATA
The Company does not currently intend to transfer your personal data to third countries with respect to the European Union.
In any case, if this happens, Cartotecnica Favini S.r.l. guarantees that this transfer will take place:
– towards companies belonging to the Favini Group and which adopt the same procedures regarding the processing of personal data, also through the adoption of binding corporate rules or corporate binding rules approved by the competent supervisory authority;
– to non-EU countries that the European Commission has deemed to guarantee an adequate level of protection (Art. 45 GDPR) or after stipulating standard contractual clauses approved by the European Commission.
Any exceptions to the above will only take place in compliance with art. 49 GDPR.
DATA RETENTION PERIOD
The personal data provided through the contact form will be kept for the time necessary to provide the answer to the data subject and in any case no later than 24 months from the request.
A longer period of data retention may possibly be determined by requests made by the Public Administration or by another judicial, governmental or regulatory body or by the participation of the undersigned company in judicial procedures that involve the processing of the personal data you provide.
RIGHTS OF THE DATA SUBJECT
The data subject has the right to obtain access to personal data from the data controller. In particular, the data subject has the right to obtain the indication: a) of the origin of the personal data; b) the purposes and methods of processings; c) the logic applied in case of processings carried out with the aid of electronic instruments; d) updating or rectification; e) the erasure or restriction of the processing of data concerning the data subject (transformation into anonymous form, blocking of data processed in violation of the law, including those which need not be kept for the purposes for which the data were collected or subsequently processed).
The data subject has the right to object at any time to the processing of its personal data, if the latter is based on the legitimate interest of the data controller and there are the conditions set out in art. 21 GDPR.
The data subject has the right to withdraw consent to the processing of personal data where provided. In any case, the revocation of consent to treatment does not affect the lawfulness of the processing based on the consent given before the revocation.
The data subject also has the right to data portability.
For the purposes of exercising the rights provided by the Regulation, the data subject can send a request to the Data Controller through:
– E-mail to the email address: [email protected];
– registered letter with return receipt to Cartotecnica Favini S.r.l., Via Alcide De Gasperi n ° 26 – 36028 Rossano Veneto (VI).
RIGHT TO LODGE A COMPLAINT
The data subject residing in Italy has also the right to lodge a complaint with the Supervisory Authority, represented in Italy by the Guarantor for the Protection of Personal Data, based in Rome, Piazza Monte Citorio, 121. The data subject residing outside Italy may lodge a complaint before the designated Control Authority in its country of residence.
The Data Controller
Cartotecnica Favini S.r.l.