INFORMATION ON THE PROCESSING OF PERSONAL DATA (PRIVACY POLICY) COLLECTED IN THE WEBSITE FORM
This information integrates our website navigation policy, in order to illustrate how the Controller will process the data provided in this form. Would you kindly read the information on navigation [add link]
Identity and contact details of the process Controller
COMACCHIO S.p.a., hereinafter also “Comacchio” or “Controller”, with registered office in via Callata 24/b) 31011 RIESE PIO (TV), and available at the e-mail address privacy@comacchio.com, at the certified e-mail address (PEC) comacchiosrl@legalmail.it or on phone number 0423 7585.
Purpose and legal basis
| Purpose | Description |
|---|---|
| A. | Management of requests for information: personal data are processed for all needs connected to requests for information and/or estimates. |
| B. | Newsletter: personal data are processed to send periodical information and promotional communications by e-mail to the addresses provided by the data subject, in order to keep him/her updated on products, services, initiatives and content of interest. |
| C. | Managing the event and revoking consent: The Controller processes the personal data to confirm that registration for marketing communications takes place with checked consent (double opt-in). The Controller records the revocation of consent to avoid sending further information to whoever does not want it (blacklist). |
| D. | Defence purposes: The Controller may need to process personal data to manage any disputes and out-of-court or legal litigation. |
| Purposes | Legal basis (common data) | Legal basis (special data) |
|---|---|---|
| A. |
Performance of pre-contractual measures; Legitimate interest of the Controller and respond to requests received. |
/ |
| B. | Consent. | / |
| C. | Legitimate interest of the Controller to collect consent expressed validly and to keep track of any revocation to avoid unwanted contact. | / |
| D. | Legitimate interest of the Controller to ascertain, exercise or defend a right. | Access, exercise or defend a right. |
Storage period
| Purposes | Storage time |
|---|---|
| A. | Time needed to satisfy the requests received and subsequent interactions. |
| B. | Until consent is revoked. |
| C. | 1 month from registration of data. Data stored in the black list is kept for 3 years. |
| D. | 10 years from the final resolution of the dispute. |
Nature of data provision and the consequences of a refusal
| Purposes | Nature | Consequences |
|---|---|---|
| A. | Needed | Impossible to receive the information requested. |
| B. | Optional | Impossible to receive information and promotional communications. |
| C. | Optional | Impossible to receive information and promotional communications. |
| D. | Needed | Impossible to manage the dispute. |
Area of communication
The data are processed by internal personnel authorised to perform specific tasks and are communicated externally based on the following rules.
| Purposes | External recipient categories |
|---|---|
| A. | Agents, commercial consultants. |
| B. | External consultants, companies offering hosting/technological platform management services |
| C. | External consultants, companies offering hosting/technological platform management services |
| D. | Legal firms, credit recovery or supply companies; Legal authorities. |
Seeing that the data are also processed using computer tools, they could also be visible to parties performing assistance/maintenance on those systems.
Transfer of data to a third country or an international organisation
The data of the data subject could be transmitted to third parties located outside the European Economic Area who offer services connected to the processing performed by the Controller and described herein.
That transfer, if necessary, will be regulated, based on the recipient, through use of standard contractual clauses adopted by the European Commission in decision 2021/914 of 4 June 2021 as amended or, alternatively, based on a Commission adequacy decision and/or any other tool permitted by the law. Where applicable, the transfer will be based on conditions established by art. 49 GDPR under conditions envisaged by it.
To obtain information of the place the data have been sent to, the data subject may contact the Controller at numbers indicated in the paragraph “Rights of the data subjects”.
Rights of the data subjects
The subjects the personal data refer to are attributed the following rights:
| Right | Description |
|---|---|
| Access | they can know whether their personal data are being processed and, if so, have access to them and request a copy. |
| Rectification | they may ask for the personal data to be updated, corrected (if incorrect) and integrated if not complete. |
| Erasure | they may have the personal data erased in certain situations (for more information contact the Controller). |
| Restriction | they may ask for their data to be marked, in order to restrict any further processing, in certain situations (for more information contact the Controller). |
| Object | they may object to the processing of their personal data, for reasons connected to their specific situation, when processing is based on legitimate interest or is needed to perform a task of public interest or connected to exercising the public powers that the Controller is assigned. It is also possible to object to processing of personal data for direct marketing purposes. |
| Portability | they can receive the personal data supplied to the Controller in a structured form and transmit them to another process controller if the processing is based on consent or contract and is performed by automated means. |
| Revoke consent | they may revoke consent for purposes that required it, without prejudice to the legality of processing performed until that moment. |
The rights effectively exercisable for the processing actions performed are:
| Purposes | Access | Rectification | Erasure | Restriction | Objection | Portability | Revoke consent |
|---|---|---|---|---|---|---|---|
| A. | X | X | X | X | X | ||
| B. | X | X | X | X | X | X | X |
| C. | X | X | X | X | X | ||
| D. | X | X | X | X | X |
To exercise the above rights, they may use the form available at the following link https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1089924 and send it to the following address: privacy@comacchio.com. The data subject may ask the same address for more details on the above information (e.g. test balancing legitimate interest or a list of the data processors).
A complaint may be lodged with a supervising Authority: for Italy, Authority for the Protection of Personal Data (www.garanteprivacy.it).