Information on the treatment of personal data pursuant to art. 13-14 of the (EU) Reg. 2016/679 GDPR (General Data Protection Regulation) and of art. 13 of the Legislative Decree 30 June 2003 n. 196 (Privacy Code)
1. Data Controller of the personal data
The Data Controller is the company Pneumax S.p.A., a Unipersonal Company subject to the direction and coordination of Pneumax Holdings S.p.A. (C.F. and P. IVA: 02893330163 – Cap. Soc. € 2.700.000 I.V. – Reg. Imprese MI n. 02893330163 R.E.A. MI 1670562 – R.E.A. BG n. 331626 – N. Ident. IT 02893330163 – P. +39 035 41 92 777 – F. +39 035 41 92 740/1 – email@example.com), with a legal office in Milan (Mi) – 20129 – Via Archimede, n. 57, and the administration office/production in Lurano (Bg), in via Cascina Barbellina, n. 10, and is its pro tempore legal representative (hereafter also referred to as the “Company”, “Pneumax” or the “Data Controller”. Pneumax S.p.A. guarantees compliance regarding the protection of personal data by providing the following information about data communicated or collected in the course of navigation on this site, or in the execution of trade relations, inspired by the principles of lawfulness, fairness and transparency in relation to the person concerned and the minimisation and accuracy of the agreements.
2. Data processing, purpose and legal basis of the treatment
2.1. Data generated by access to the website
The computer systems and software procedures involved in the operation of this site acquire, during their normal operation, certain personal data, the transmission of which is implied in the use of Internet communication protocols.
This data (for example domain name, IP address, operating system used, type of browser used to connect) which is accompanied by some personal information which is used for i) obtaining anonymous, statistical information regarding the use of the website; ii) to manage the control requirements of how to use the website; iii) to ascertain responsibility in case of possible computer crimes.
The legal basis that legitimates the processing of such data is the need to make the functionality of the site usable as a result of the user’s access.
2.2. Data voluntarily provided by the user or collected through access to the “Reserved Area”
The personal data provided by the user, that the interested parties voluntarily confer to the company at the time of registration and by the use of the portal “Reserved Area”, is collected and processed for the following purposes:
a. Conducting all activities regarding relationships with customers and suppliers on the basis of contractual agreements and for conducting pre-contractual negotiations.
b. Enabling and facilitating the possibility for interested parties to view catalogues of Pneumax products
c. To implement trade agreements and contracts with the parties concerned;
d. Administrative, accounting, tax, managerial, organisational and legal purposes
e. Study, research and development of company products
f. The preparation, organization and execution of training courses, open to interested parties;
g. In the presence of specific consent, to receive:
- updates on our activities and reports on the publication of our social media
- periodically, via email newsletters and advertising material
- promotional information and invitations to events, exhibitions, training courses, webinars, special promotions or to participate in market research and analysis
h. To send curriculum vitae exclusively for selection purposes
The legal basis for the treatment is the execution of a commercial relationship or a contract of which the person concerned is a party or the execution of pre-contractual measures adopted at the request of the same. Only in the case of free, specific, express and detailed consent Pneumax has the possibility to carry out the actions referred to in point G above). In the latter, expressly indicated, the legal basis is the consent freely provided by the person concerned.
For complete information we specify that the collection of data through the service “Reserved Area” of this site is functional to the use of the platform itself and is an integral part of the functionality of the system.
The legal basis which legitimates the processing of such data is the execution of a commercial relationship or a contract of which the person concerned is a party or the implementation of pre-contractual measures adopted at the request of the same, or the use of the services relating to the dedicated “Reserved Area” portal.
In the event that the Company becomes aware of the personal data of the interested parties by means other than those indicated in this paragraph 2, the holder shall communicate to the interested parties as soon as possible, or at the time of the first communication to the person concerned, and in any case within one month the information provided for in articles 13 of Legislative Decree No. 196/2003 and 13 of Reg. 2016/679/EU, specifying also the source from which the personal data originated and, where appropriate, the possibility that the data came from sources accessible to the public.
3. Nature of the provision
Apart from what is specified regarding navigation data and the data collected through access to the “Reserved Area”, the conferral of the data:
- With respect to the purposes referred to in c) and d); they are obligatory and therefore, any refusal will make it impossible for Pneumax to give course to the pre-contractual and/or contractual commitments assumed.
- With respect to the purposes referred to in a), b), e), f); they are optional, but any refusal will make it impossible for Pneumax to give course to the pre-contractual and/or contractual commitments assumed.
- With respect to the purposes set out in g); they are also optional and their use is conditional upon the issuance of explicit consent. Any refusal will make it impossible for Pneumax to send newsletters and advertising material or invitations to events and Pneumax initiatives, without further consequences.
4.Treatment methods and data retention time
The data collected will be processed through electronic, computer and telematic instruments, or through manual processing with logic closely related to the purposes for which personal data has been collected and, in any case, to guarantee the safety of the same.
The data is kept only for the time strictly necessary for the management of the purposes for which the data itself is collected, in compliance with current regulations and statutory obligations.
In any case Pneumax adopts rules that prevent the retention of data indefinitely and therefore limits the retention time in compliance with the principle of minimisation of data processing. It is stated that the holder does not use personal data for the execution of automated decision-making processes and/or for profiling activities.
5. Persons authorised for the handling, management and communication of the data
The processing of the data collected is carried out by Pneumax internal staff to this end identified and authorised to treat according to specific instructions given in compliance with the current regulations.
The data collected, if necessary or instrumental for the performance of the indicated purposes, may be handled by third parties appointed in charge of or externally responsible for the handling, or, as appropriate, communicated to the same as the autonomous holders, and precisely:
companies belonging to our company group in accordance with art. 2359 C.C., or companies subject to common control (as shown in the relevant area of the website) for the purposes set out in point 2. a), b), c), d), e), f), g) and h), and in any case for administrative-accounting purposes, as defined by art. 34, paragraph 1 of Legislative Decree No. 196/2003;
persons, companies, associations or professional studies that provide assistance and consultancy activities for our society, for the purposes set out in point 2. c), d) and f) and for the administrative-accounting purposes, as defined by art. 34, paragraph 1 of Legislative Decree No. 196/2003;
companies, entities and associations that carry out related services instrumental to the execution of the above mentioned objectives (market research and analysis services, credit card management, maintenance of computer systems).
The data collected may also be transferred abroad, among companies belonging to the Pneumax corporate group, also outside the European Union in the forms and in the manner envisaged by the current legislation, guaranteeing in any case an adequate level of protection, limited to the purposes indicated in points a), b), c), d), e) and g).
In any case, personal data will never be disseminated.
6.Rights of the person concerned
The user can access all personal data provided, request the modification or deletion of it at any time. In particular it is possible to obtain confirmation of the correct handling of your personal data as expected and access the data processed, even before this is recorded, as provided by art. 15 of Regulation (EU/2016/679). In addition to the confirmation of the correct handling, the rectification or deletion of the data (arts 16-17 GDPR), the limitation of the handling (if it is one of the hypotheses provided for by art. 18 GDPR), the entitlement to the portability of the data (art. 20 GDPR) and to oppose the handling (art. 21 GDPR).
The person concerned has the right to obtain from the Data Controller the rectification of inaccurate personal data concerning him without undue delay. Taking into account the purpose of the handling, the person concerned has the right to obtain the integration of incomplete personal data, including by providing an additional statement.
The person concerned has the right to obtain from the Data Controller the deletion of personal information concerning him without undue delay and the Data Controller has an obligation to cancel without undue delay the personal data within the limits and in the cases covered by the current legislation. The Data Controller shall communicate to each of the recipients whose personal data has been transmitted, the possible corrections or cancellations or limitations of the handling within the limits and in the forms provided for by the current regulations.
The person concerned has the right to receive in a structured format, in common use and readable by an automatic device, the personal data relating to him provided to a data controller and has the right to transmit such information to another data controller without Impediments by the data controller which provided them.
In order to know in more detail your rights regarding your personal data we invite you to consult the text of articles 15, 16, 17, 18, 19, 20, 21, 22 of the Regulation (EU/2016/679).
Requests must be addressed to Pneumax S.p.A. with the address: firstname.lastname@example.org.
According to art. 13, par. 2, let. d) of Regulation No 2016/679/EU, the Company shall inform you at any time to file a complaint with the European Data Protection Supervisor using the methods contained on this page.
Lurano, 24 May 2018