PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA (Web)

The user’s personal data is processed by I TRE FRATI SRL, which acts as the Data Controller, in compliance with the principles governing the protection of personal data established by the GDPR Regulation 2016/679.

METHODS AND PURPOSES OF DATA PROCESSING

1. We hereby inform you that your data will be processed using the following means:


• Computer-based systems


For the following purposes:

• Fulfilment of tax and accounting obligations

• Promotional activities

• Completion of notification forms

• Provision of products and services

• Customer management (contracts, orders, shipments and invoices)

• Marketing (market analysis and surveys)

• Booking of services and issuing of tickets (sports, cultural and recreational activities)


Without prejudice to any express refusal by the data subject, the user’s data will also be processed for the following purposes:


• sending proposals and commercial communications by email, SMS or fax, both by the company and by partner companies:

• market research and statistical analysis, marketing activities and references concerning advertising communications (press, radio, TV, internet, etc.), as well as product preferences:

• profiling activities

• Consent to the processing of special categories of personal data:

Any refusal to consent to the processing of personal data will make it impossible for the user to access the requested service.

LEGAL BASIS

2. The provision of data is mandatory insofar as it is required by legal and contractual obligations. Therefore, any refusal to provide all or part of the requested data may result in the inability to provide the requested services. 

The company processes users’ optional data on the basis of consent, namely through the explicit acceptance of this privacy policy and in accordance with the methods and purposes described below.

CATEGORIES OF RECIPIENTS

3. Without prejudice to disclosures made in fulfilment of legal and contractual obligations, all data collected and processed may be disclosed exclusively for the purposes specified above to the following categories of recipients:

• Employer;

• Internal data processors;

• External data processors;


Furthermore, in managing your data, the following categories of authorised persons and/or internal and external data processors, appointed in writing and provided with specific written instructions regarding the processing of personal data, may have access to such data:

• Internal data processors

• Authorised employees


IT SYSTEMS

DATA RETENTION PERIOD

4. Data required for contractual and accounting purposes is retained for the period necessary to manage the commercial and accounting relationship.

The data of individuals who do not purchase or use products/services, despite having previously been in contact with company representatives, will be immediately deleted or anonymised where there is no other legitimate reason for retaining it, unless valid informed consent has been obtained from the data subjects for subsequent commercial promotional or market research activities.
The data retention period is: 2 years

DATA SUBJECT RIGHTS

5. Pursuant to European Regulation 679/2016 (GDPR) and applicable national legislation, the data subject may, in accordance with the procedures and within the limits established by applicable law, exercise the following rights: 


• request confirmation as to whether or not personal data concerning them exists (right of access);

• know the source of such data;

• receive the data in an intelligible form;

• obtain information concerning the logic, methods and purposes of the processing;

• request the updating, rectification, integration, deletion, anonymisation or blocking of data processed in breach of the law, including data that is no longer necessary for the purposes for which it was collected;

• right to restriction of and/or objection to the processing of data concerning them;

• right to withdraw consent;

• right to data portability;

• where processing is based on consent, receive the personal data provided to the Data Controller in a structured, commonly used and machine-readable format;

• right to lodge a complaint with the competent supervisory authority.


6. The Data Controller of your personal data is I TRE FRATI SRL.

7. The Data Processor responsible for processing your data is appointed internally within the company.


COOKIE INFORMATION

What are cookies?

A “cookie” is a text file saved on the user’s computer when they access a website, with the purpose of providing information each time the user returns to the same website. It is a sort of reminder of the web page visited. Through cookies, the web server sends information to the user’s browser (Internet Explorer, Mozilla Firefox, Google Chrome, etc.), which is stored on the user’s computer and read and updated each time the user returns to the website. In this way, the website can automatically adapt to the user. During browsing, the user may also receive cookies from websites other than the one being visited (“third-party cookies”), which are set directly by the operators of those websites and used for the purposes and according to the methods defined by them.
Depending on their duration, cookies are divided into session cookies (temporary cookies that are automatically deleted from the device at the end of the browsing session, when the browser is closed) and persistent cookies (cookies that remain stored on the device until they expire or are deleted by the user).
Based on their function and purpose, cookies may be divided into technical cookies and profiling cookies.

Technical cookies

Some cookies are used for computer authentication, session monitoring and the storage of specific information about users accessing a web page. These cookies, known as technical cookies, are often useful for allowing users to browse a website and use all of its functionalities. The use of technical cookies does not require the user’s consent.
Analytics cookies also fall into this category. These cookies collect information about how users use a website and help improve its functionality. For example, analytics cookies show which pages are visited most frequently, make it possible to identify recurring browsing patterns and help understand any difficulties users may encounter when using the website.

Profiling cookies

Other cookies may instead be used to monitor and profile users while they browse, study their movements and browsing or consumption habits (what they purchase, what they read, etc.), including for the purpose of sending targeted and personalised advertising. These are referred to as profiling cookies. The use of such cookies requires the user’s prior, freely given and informed consent pursuant to Article 7 of EU Regulation 2016/679.

Third-party cookies

A web page may also contain cookies originating from other websites and included in various elements hosted on the page itself, such as advertising banners, images, videos, maps or specific links to web pages belonging to other domains and hosted on servers other than the one hosting the requested page. In other words, these cookies are set directly by operators of websites or servers other than this website. These are known as third-party cookies and are generally used for profiling purposes. The use of these cookies requires the user’s prior, freely given and informed consent.

Types of cookies used by our website

The main functions of the cookies installed are technical. They are used to continuously improve the Service, for authentication purposes and for statistical purposes, such as counting visits to the website. The use of cookies is therefore strictly aimed at facilitating the functions of the server while browsing the Service.
The website also allows the use of the following third-party cookies. These cookies are not owned or controlled by us. For further information, users may therefore consult the privacy notices and consent forms provided by the relevant third parties by clicking on the links provided.
To improve the website and understand which sections or elements are most appreciated by users, third-party Google Analytics cookies are used as a tool for anonymous and aggregated analysis. These cookies are not owned or controlled by us. For further information, users may consult the privacy information provided by Google.
The website pages incorporate certain Facebook and Google Plus widgets and sharing buttons, allowing users to share website content on their social media channels and interact with our channels. These cookies are not owned or controlled by us, but are created respectively by Facebook and Google when the relevant widget or sharing button is used. For further information, please visit the relevant information pages provided by Facebook and Google.
Some web pages incorporate YouTube video content. When visiting a page containing a video, or clicking to view the video, cookies from YouTube may be activated. These cookies are not owned or controlled by us. For further information, please consult Google’s information page.
The website may use Facebook ADS programs operated by Facebook Inc., Google AdWords and Google Remarketing technology operated by Google Inc. Facebook ADS and AdWords conversion tracking functions also use cookies to help us track sales and other conversions.

Cookie management

Users can manage their cookie preferences through the functions available in common browsers, which allow them to delete/remove cookies (all or some of them) or change browser settings to block the transmission of cookies or limit it to specific websites.
Users may therefore refuse the use of cookies by following the disabling procedure provided by their browser. Below are the procedures provided by the main browsers: Microsoft Windows Explorer, Mozilla Firefox, Google Chrome, Apple Safari, as well as Google Analytics by downloading a specific browser plugin.
For information about cookies stored on your device and how to disable them individually, please refer to the following link: http://www.youronlinechoices.com/it/le-tue-scelte

Social Network Plugins

The website also incorporates plugins and/or commands for social networks, in order to facilitate the sharing of content on users’ preferred social networks. These plugins are designed not to set any cookies when the page is accessed, in order to protect users’ privacy. Cookies may be set, where provided for by the relevant social network, only when the user actually and voluntarily interacts with the plugin. Please note that if a user browses while logged in to a social network, they have already consented to the use of cookies transmitted through this website at the time of registering with the social network.
The collection and use of information obtained through the plugin are governed by the respective privacy policies of the social networks, which users are invited to consult.
– Facebook – (cookie policy link)
– Twitter – (cookie policy link)
– LinkedIn – (cookie policy link)
– Google+ – (cookie policy link).
This privacy policy may be amended from time to time, including as a result of the introduction of new sector-specific legislation, updates to or the provision of new services, or technological developments. Users/visitors are therefore invited to consult this page periodically.

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The undersigned, identified below, declares that they have received complete information pursuant to Article 13 of EU Regulation 2016/679 and expressly consents to the processing and communication of their personal data, with particular regard to so-called special categories of personal data, within the limits, for the purposes and for the duration specified in this privacy notice.