1. De Rosso Srl, registered in Via Sernaglia 32/A, Farra di Soligo, TV (Italy) (the "Society", "De Rosso Srl" or the "Holder") guarantees the respect of personal and sensitive data in its possession by supplying the following information concerning the processing of such data that has been communicated or collected during the navigation on the present website
2. Processed data, purpose and legal ground of the processing
Data generated by access to the website
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols.
This data (e.g domain names, IP addresses, operating systems, device of the browser used for the connection), are not accompanied by any additional personal information and are used to:
1) obtain anonymous statistics related to website's use;
2) control the correct functioning and use of it;
3) establish liability in the event of hypothetical cybercrimes .
The legal basis that legitimates the processing of such data is the need to make the functionalities of the website usable, following the access of the user to it.
Data provided voluntarily by the user
Personal data voluntarily provided through forms are collected and processed for the following purposes:
- for carrying out the activities of relationship with the customer based on the customer's needs that were previously expressed in the data collection form
- for administrative purposes and for the fulfilment of legal obligations such as those of accounting, fiscal nature, or to give way to requests from a judicial authority.
- In case of specified agreement, for periodical newsletters and advertising material to be send by e-mail;
- in case of specified agreement, to receive updates about our activities and for notifications about the posts publication on our blog;
- in case of specified agreement, to receive promotional communications and invitations to events, training courses, webinars, special promotions or proposals to participate in analysis and market researches;
- in case of CVs being sent, exclusively for the purpose of selection whose acceptation is bounded to the authorization on the CV to the data processing, specifically expressed in the terms of the EU regulations otherwise the resume after a first check, if it does not bear the consent will be deleted and the sender informed.
The legal basis that legitimates the data processing is the performance of a contract with the data subject as a part of it or the performance of pre-contractual measures requested by the subject itself. In the cases above the legal basis is the voluntarily provided agreement submitted by the person concerned.
Data collected through the MailUp Platform
For complete information we precise that to send communication, De Rosso Srl uses its own MailUp Platform. Through statistical tracking systems (e.g. web beacons), it allows to detect the opening rate, the clicks on the hyperlinks present in the e-mail, from which IP address and with which browser the e-mail is read and other similar details. The data collection is functional for the use of the platform and it is an integral part of the system's functionality for the sending of e-mails. The legal basis that legitimates the data processing is the performance of a contract with the data subject as a part of it.
3. The data providing
Besides what already indicated for the surfing data and for the data collected through the MailUp Platform, the data providing:
- in relation to the purpose as per letters a), b) and f) it is optional but an eventual denial will incapacitate De Rosso Srl to respect its contractual obligations and respond to the customers' needs that were previously expressed through the requests form available on the website.
- In relation to the purpose as per letters c), d) and e) it is also optional and their use is strictly conditioned to the release of an explicit agreement. The eventual denial will incapacitate De Rosso Srl from sending newsletters and advertising material or invites to events and other initiatives that De Rosso Srl might perform.
4. Methods of data processing and data retention
The personal data processing is carried out by electronic, automated, computerised and telematic instruments and/or are manually processed with methods and tools that are strictly related to the purposes of which they were collected and anyhow in a way to guarantee the safety of the data. The same data will be kept for a period not exceeding the purposes for which they were collected in compliance with the existing rules, regulations and legal obligations.
In any case, De Rosso Srl follows rules that prevent the indefinite time conservation of the data and so it limits, the time of conservation in compliance with the principals of minimization of data processing .
5. Subjects authorized to the processing, data controllers and data diffusion
The processing of the collected data is carried out by De Rosso's internal personnel that is specifically chosen and authorized to the data processing following specific instructions based on the respect of the legal obligations.
The collected data, where necessary or functional for the already indicated purposes, could be processed by third parties appointed as the Responsible outside the processing i.e. depending on the cases, the data could be communicated to them being also data holders and precisely:
- Individuals, societies, associations or professional studies that provide assistance and expertise to our Company for the purposes as per point 1 letter b) and f)
- Societies, institutions, associations that perform services that are connected or functional to the execution of the abovementioned purposes (the service of analysis and market research, managing of credit card payments, maintenance of IT services, credit verification societies).
The collected data shall not be transferred abroad.
Anyhow, the personal data shall not be diffused.
6. Rights of the data subject
At any time it is possible to access the data, to deny them to be processed or to ask for their deletion, modification or update of all the personal information collected by De Rosso Srl by exercising the right of processing limitation and the right to the data portability by sending an e-mail to the address firstname.lastname@example.org
7. Data Controller
The holder took care to nominate the Data Controller that may be contacted at the following e-mail address email@example.com
Last update: 23rd May 2018