Privacy


Information about the processing of personal data

Roces S.r.l. with its registered office in Via G. Ferraris 36 31044 Montebelluna (TV) – VAT NUMBER IT00301810263 (hereinafter, “Data Controller”), as data controller informs you pursuant to art. 13 D.lgs. 30.06.2003 n. 196 (hereinafter, “Privacy Code”) and art. 13 EU Regulation n. 2016/679 (hereinafter, “GDPR”) that your data will be processed for the following purposes:

1. Object of the treatment

The Data Controller processes personal, identifying and non-sensitive data (for example, but not limited to, name, surname, company name, address, telephone number, mobile phone number, email address – hereinafter, “personal data” or even “data”) communicated by you when registering the Data Controller’s website (hereinafter, “website”), filling out the registration form through the website, requesting online clarifications or requests for support and sending newsletters.

2. Purpose of the processing

Your personal data are processed for the following purposes: to manage and maintain the website; allow you to use any of the services requested by you; process a contact request; fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority; prevent or discover fraudulent activities or malicious activities harmful to the website; exercise the rights of the owner, for example the right to exercise a right in court (“Ordinary Purposes”).

3. Methods of processing

The processing of your personal data is carried out by means of the operations indicated in art. 4 of the Privacy Code and art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electronic and / or automated processing. The Data Controller will preserve personal data for the time necessary to fulfill the mentioned purposes and in any case for no more than 10 years from the termination of the relationship for the Ordinary Purposes and no later than 2 years from the termination of the relationship for the Other Purposes.

4. Security

Your data will be processed mainly in automated way, but also in paper, with logic strictly related to the specific purposes, through databases, electronic platforms managed by Roces S.r.l. or third parties appointed for the purpose of external processing and / or integrated computer systems of the aforementioned third parties.

5. Access to data

Your data may be made accessible for the following purposes:
• to the employees and collaborators of the Data Controller, in their capacity as persons in charge and / or internal process managers and / or system administrators;
• to third-party companies or other subjects (as an indication, website provider, cloud provider, e-payment service provider, suppliers, hardware and software service engineers, shippers and carriers, credit institutes, professional offices, etc.) who carry out activities on behalf of the Data Controller, in their capacity as data processor.

6. Data communication

Without your express consent (pursuant to Article 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data to Supervisory entities, Judicial Authorities and to all other subjects to whom the communication is mandatory by law.

7. Data transfer

The management and storage of personal data will take place in Europe, on servers of the Data Controller and / or third-party companies duly appointed as data processor.

8. Nature of the provision of data and consequences of refusal to respond

The provision of data for the Ordinary Purposes is mandatory.
The provision of data for Other Purposes is optional. You can therefore decide not to give any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive the newsletter service, invitations to events and / or to register for events to which is party or organizes the Data Controller. In any case, you will continue to be entitled to the services referred to in the Ordinary Purposes.

9. Rights of the interested party

In your capacity as interested parties, you have the rights set forth in art. 7 of the Privacy Code and art. 15 GDPR and precisely the rights of:

• i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;

• ii. obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the owner, the managers and the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, managers or agents

• iii. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment is proved impossible or involves a use of means manifestly not proportionate to the protected right;

• iv. to object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right to object even only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.

Where applicable, you also have the rights referred to in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

10. How to exercise rights

You can exercise your rights at any time by sending:
• a registered letter a.r. addressed to Roces S.r.l. Via G. Ferraris 36 31044 Montebelluna (TV) – VAT NUMBER IT00301810263

• an e-mail to roces@pec.roces.it

11. Minors

This website and the services of the Data Controller are not intended for minors under the age of 18 and the Data Controller does not intentionally collect personal information about minors. In the event that information about minors were unintentionally registered, the Data Controller will delete them in a timely manner, at the request of users.

12. Data Controller, processors and other authorized subjects

The Data Controller is Roces S.r.l. with its registered office in Via G. Ferraris 36 31044 Montebelluna (TV).

The updated list of data processors and subjects authorized to data proceeding is kept at the Data Controller’s headquarter.

13. Changes to this Statement

This information may change. It is therefore advisable to regularly check this information and refer to the latest version.

Privacy Policy

This Website collects some Personal Data from its Users.

Data Controller

Roces S.r.l.- Via G. Ferraris 36 31044 Montebelluna (TV) – VAT NUMBER IT00301810263
Email address of Data Controller: roces@pec.roces.it

Data collected

Among the Personal Data collected by this Website, independently or through third parties, may be present the following: name, surname, company name, phone number, mobile phone number, email address, country, province, email, postal code, Cookies and Data Usage.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information displayed before the data are collected.
Personal Data may be freely provided by the User or, in the case of Data Usage, collected automatically during the use of this Website.

Unless otherwise specified, all the Data requested by this Website are mandatory.

If the User refuses to communicate them, it may be impossible for this Website to provide the Service. In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.

Users who have doubts about which data are mandatory, are encouraged to contact the Data Controller.

Any use of Cookies – or other tracking tools – by this Website or by third party service providers used by this Website, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the other purposes described in this document.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Website and warrants that he has the right to communicate or disseminate them, freeing the Data Controller from any liability to third parties.

Mode and place of processing of collected data

Processing

The Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

Processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external subjects (as suppliers of third party technical services, postal carriers, hosting providers, IT companies, communication agencies) may have access to the Data, also appointed, if necessary, Data Processors by the Data Controller. The updated list of Data Processors can always be requested to the Data Controller.

Legal basis of the processing

The Data Controller processes Personal Data relating to the User in the event one of the following conditions exists:

• the User has given consent for one or more specific purposes; in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, provided that the User does not object to “opt-out” treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation regarding the protection of Personal Data;
• the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;

• the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
• processing is necessary for the performance of a task carried out in the public interest or for the exercise of public authority the Data Controller is assigned;

• processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

It is however always possible to request the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Place of processing

The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For more information, contact the Data Controller.

To obtain further information on the processing site, the User can refer to the section concerning the processing of Personal Data.

The User has the right to obtain information on the legal basis of any transfer of Data outside the European Union or to an international organization of public international law or consisting of two or more countries, as well as with regard to security adopted by the Data Controller to protect the Data.

If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Data Controller by contacting him at the opening dates.

Data Conservation

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

• Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of the contract is completed.
• Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is met. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the consent of the User, the Data Controller may retain the Personal Data for a longer period until such consent is revoked, and never beyond the needs related to the purposes for which such data were collected. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or an order of an authority.

At the end of the retention period the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purposes of processing of collected data

The Data concerning the User is collected to allow the Data Controller to provide its Services, as well as for the following purposes: Contacting the User, Remarketing and Behavioral Targeting, Analytics, Displaying content from external platforms, Management of User databases.

To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant to each purpose, the User can refer to the relevant sections of this document.

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Contact the User

Contact form (This Website)

By filling out the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other kind indicated by the form header.
Personal Data collected: surname, first name, email address, postal address, country code, phone number, mobile phone number, company name, status and various types of Data as specified in the privacy policy of the service.

Contact by phone (This Website)

Users who provided their telephone number may be contacted for commercial or promotional purposes connected to this Website, as well as to satisfy requests for support.
Personal Data collected: telephone number.

Management of User database

This type of service allows the Data Controller to build user profiles starting from an email address, the name or any other information that the User provides to this Website, as well as to track the User’s activities through statistical functions. These Personal Data could also be crossed with information about the User available publicly and used to build private profiles that the Data Controller can view and use to improve this Website.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses Personal Information collected for the purpose of evaluating the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the advertisements of its advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out

Google Tag Manager (Google Inc.)

Google Tag Manager is a statistical service provided by Google Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: USA – Privacy Policy

Tracking conversions of Google AdWords (Google Inc.)

Google AdWords Conversion Tracking is a statistics service provided by Google Inc. that links data from the Google AdWords ad network with the actions performed within this Website.
Personal Data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy

Displaying content from external platforms

User Rights

Users may exercise certain rights with reference to the Data processed by the Data Controller.
In particular, the User has the right to:
• withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.
 oppose the processing of your data. You may object to the processing of your data when it occurs on a legal basis other than consent. Further details on the right of opposition are indicated in the section below.
• access your data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
• verify and request correction. The User can verify the correctness of his Data and request its updating or correction.
• obtain treatment limitation. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose other than their conservation.
• obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Data Controller.
• receive your data or have it transferred to another controller. You have the right to receive your data in a structured format, commonly used and readable by automatic device and, where technically feasible, to obtain the transfer without hindrance to another controller. This provision is applicable when the Data are processed with automated tools and the processing is based on the User’s consent, on a contract of which the User is a party or on contractual measures connected to it.
• propose a complaint. The User can lodge a complaint with the competent personal data protection authority or act in court.

Details on the right of opposition

When Personal Data is processed in the public interest, in the exercise of public authority to which the Data Controller is invested or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons related to their particular situation.
Users are reminded that, if their data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Data Controller deals with data for direct marketing purposes, Users may refer to the respective sections of this document and to the privacy notice issued when providing consent to the provision of data.

How to exercise the rights

To exercise the rights of the User, Users can direct a request to the contact details of the Data Controller indicated in this document. Requests are filed for free and processed by the Data Controller as soon as possible.

More information about data processing

Defense in court

The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages of its possible establishment for the defense against abuse of the use of this Website or the related Services by the User.

The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of the public authorities.

Specific information

At the request of the User, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For needs related to operation and maintenance, this Website and any third-party services used by it may collect System Logs, which are files that record the interactions and that may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time to the Data Controller using the contact details.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details held by the Data Controller. Please therefore consult this page regularly, referring to the date of last modification.
If the modifications concern data processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.


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