Sophisticated

Privacy Policy

In this page FIAM ITALIA S.r.l. describes the management of this site (the “FIAM ITALIA Site”) with reference to the processing of the personal data of Users who consult it or send email messages to the email addresses available on the FIAM ITALIA Site.

If you have any doubts, please contact us at privacy@fiamitalia.it.

WHY THIS PRIVACY POLICY?

From 25 May 2018, each Member State of the European Union was required to implement new privacy rules, under EU Regulation 2016/679 (the General Data Protection Regulation, hereafter GDPR), as well as domestic laws, such as Italian Legislative Decree 101/18.

The GDPR provides for greater protection of users and imposes new obligations and responsibilities on those parties who process personal data, including data through websites.

For more information on the GDPR, refer to the useful and informative Section edited by the Italian Data Protection Authority: this well help you understand the new rules and will advise you of your rights.

Transparency is a fundamental principle: users must know, in advance, in a clear and comprehensive way, what personal information will be collected, the party or parties who will process this information, the reasons for such processing and the time for which the data may be processed, whether this data will be used for trade or commercial purposes or for profiling purposes, whether the data will be communicated to any third party, and how users can effectively check how their data is being managed or handled.

This information is provided in accordance with article 13 of the GDPR, in Legislative Decree 101/18 and is also inspired by the working Group Guidelines pursuant to Article 29 on Transparency.

The privacy policy is addressed to all those who interact with the FIAM ITALIA Site, accessible by telematic means from the address www.fiamitalia.it corresponding to the initial page or “home page” of the FIAM ITALIA Site. In the consultation of the FIAM ITALIA Site, besides sending communications to the contacts present on the FIAM ITALIA Site, data can be processed that make it possible to identify – directly or indirectly – the users.

TO WHICH WEBSITES DOES THE FIAM ITALIA PRIVACY POLICY APPLY?

The information is provided only for the FIAM ITALIA Site and not for other websites that may be consulted by the user through the links (hypertext links) present in the FIAM ITALIA Site.

The existence of one or more links to a site not belonging to FIAM ITALIA does not imply the approval or acceptance of liability by FIAM ITALIA regarding the content or use of said third-party site.

Users who wish to send data to or through third-party sites should read the privacy statements carefully before providing personal data.

THE CONTROLLER AND CONTACT DETAILS

The Controller of the processing of your personal data referred to in this privacy policy is FIAM ITALIA S.r.l., registered office Via Ancona 1/B, 61010, Tavullia (PU); Tax Code 00335410437; VAT No. 01014250417; Companies Register PS 101539, Certified email fiam@cert.fiamitalia.it, reachable for any communication or request regarding your own data also to the email address privacy@fiamitalia.it for the provisions pursuant to Regulation 2016/679 and to Legislative Decree 101/18.

TYPES OF DATA PROCESSED

Access to and consultation of the FIAM ITALIA S.r.l. Site does not provide for the collection of personal data by FIAM ITALIA S.r.l., except for:

in the “Contacts” section, here is a specific form, the compilation of which involves the subsequent acquisition of the email address and of the user data, necessary to follow up the requests for information formulated by the user;

in the Newsletter subscription form, the optional completion of the form involves the acquisition of the name and email address required to register.

A specific Privacy Policy will be provided for each of the forms, as well as email contacts to submit requests for information.

Browsing data

It should be noted that the computer system may need to store some of your browsing data as part of its normal operation. The transmission of this data is automatic and is necessary for the operation of the FIAM ITALIA Site, being linked to the use of the Internet communication protocols. Such data is not collected in order to be associated with your identity, but may indirectly – through processing and association with data held by third parties – allow your identification. For this reason, they may be considered “personal data” according to the GDPR.

This data category includes, for example, the IP addresses or domain names of the computers utilised by users who connect to the FIAM ITALIA Site, Uniform Resource Identifier (URI) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters related to the operating system and the computer environment of the user.

Cookies

The cookies used by the FIAM ITALIA Site are first-party technical and analytical cookies.

The FIAM ITALIA Site does not use first-party profiling cookies to carry out statistics and samples related to the commercial activity and to send advertising messages in line with the preferences that the user manifests while browsing the web.

The FIAM ITALIA Site does not use persistent cookies of any kind.

The use of so-called session cookies (which are not permanently stored on the user’s computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow the safe and efficient exploration of the FIAM ITALIA Site. The so-called session cookies used in the FIAM ITALIA Site avoid the use of other computer techniques potentially prejudicial to the privacy of the users’ browsing and do not allow the acquisition of personal data identifying the user.

You can find more information in our Cookie Policy.

Data provided voluntarily by the user

The optional, explicit and voluntary sending of email messages to the addresses indicated on the FIAM ITALIA Site implies the subsequent acquisition of the sender’s e-mail address, necessary to respond to requests, as well as any other personal data included in the message.

In all the pages of the FIAM ITALIA Site, in which there are features or forms that allow users to voluntarily provide personal data, specific privacy statements are provided, directly and easily accessible from each page so that users can be fully aware of the use that, on a case-by-case basis, will be made of their personal data.

FIAM ITALIA S.r.l., as the Data Controller, states that if the user voluntarily and spontaneously gives personal data belonging to particular categories pursuant to art. 9 of the GDPR (i.e. information suitable to reveal racial origin, religious, philosophical or other beliefs, political opinions, membership in parties, trade unions or organisations of a religious, philosophical, political or trade union nature, as well as personal data suitable to reveal the state of health and sexual orientation), FIAM ITALIA S.r.l. will treat them with the utmost confidentiality, in compliance with the law in force and for the exclusive purposes indicated in the privacy policy specifications. This information will only be disclosed to the recipients listed in each specific Privacy Policy and will not be used for commercial purposes unless you give your express consent, as specified below.

Commercial communications

FIAM ITALIA S.r.l. may send commercial communications only to those users who have given specific consent by accessing specific pages on the FIAM ITALIA Site.

Before giving their consent, users are duly informed that FIAM ITALIA S.r.l., in accordance with the provisions of art. 13 GDPR and arts. 8 and 9 of Legislative Decree no. 70/03, can send to the email address, and/or to the User’s home address, messages with commercial and/or promotional content related to its services or organised activities.

The User who has consented to the sending of commercial communications may, at any time, decide to withdraw his or her consent. In this case, FIAM ITALIA S.r.l. will stop sending the User future communications. You may revoke your consent through the same, simple means by which consent was provided.

As per the GDPR, revoking consent does not prejudice the lawfulness of processing done on the basis of consent previously given.

 

PURPOSES FOR WHICH PROCESSING IS DONE AND THE LEGAL BASIS FOR DOING SO

Browsing data

The data collected automatically by the system are used:

  • in order to allow the User to use the functions of the FIAM ITALIA Site;
  • in order to obtain anonymous statistical information on the use of theFIAM ITALIA Site and to check its correct functioning and are destroyed immediately after being processed;
  • for the determination of liability in case of possible computer crimes against the FIAM ITALIA Site.

 Data provided voluntarily by the user

The data acquired by FIAM ITALIA S.r.l. with the optional, explicit and voluntary sending of emails to the addresses indicated on the FIAM ITALIA Site, as well as through the forms present on specific pages of the FIAM ITALIA Site, will be processed only as necessary in order to respond to any requests of the users.

The data acquired by FIAM ITALIA S.r.l. with the optional, explicit and voluntary sending of curriculum vitae by aspiring collaborators will be treated only for the purpose of evaluating the applications for possible recruitment and collaboration.

Specific summary information is shown or displayed on the pages of the FIAM ITALIA Site from which personal data are collected by means of forms, with details of the purposes of the processing.

The legal basis for the processing of the above mentioned data is the express consent of the user, acquired in accordance with the GDPR.

RECIPIENTS OF PERSONAL DATA

Browsing data

The recipients of the browsing data are:

  • employees and contractors of FIAM ITALIA S.r.l.;
  • service providers related to the management and operation of the FIAM ITALIA Site.

Data provided voluntarily by the user

The recipients of the data provided voluntarily by the user – as specifically detailed also in the individual Privacy Policies – will be the following subjects, indicated individually or by categories:

  • employees and contractors of FIAM ITALIA S.r.l.;
  • suppliers of email services;
  • service providers linked to the management and operation of the FIAM ITALIA Site;
  • any employees involved in occasional maintenance and repair operations;
  • suppliers of cloud services;
  • suppliers of hosting and virtual server services;
  • suppliers of connection and telephony services;
  • suppliers of chat and communication services;
  • suppliers of mailing list services;
  • suppliers of file transfer services;
  • suppliers of remote assistance services;
  • social networks.

Data will not be communicated to other categories of recipients, nor disclosed or made public in any way whatsoever.

Data may be communicated to a competent Authority if required by current regulation or at the request of a legitimate party.

INTENTION TO TRANSFER DATA TO A THIRD COUNTRY OR TO AN INTERNATIONAL ORGANISATION

Browsing data and data sent by users of their own volition through the various channels made available by the FIAM ITALIA Site may be transferred to servers located in non-EU countries if the suppliers of IT services and the programmes used by FIAM ITALIA S.r.l., listed above as recipients, provide for it or employ cloud computing technology which makes it impossible to determine, with any certainty, exactly where your data is located.

Pursuant to the law, it should be noted that, currently, the European Commission has adopted an adequacy decision for a limited number of countries (Andorra, Argentina, Australia, PNR, Canada, the Faroe Islands, Guernsey, the Isle of Man, Israel, Jersey, New Zealand, Switzerland, Uruguay) and that, therefore, your personal data could be transferred by the Services used (e.g. Skype, Gmail) to countries for which no adequacy decision has been adopted, nor, at this time, for which FIAM ITALIA S.r.l. is able to provide, independently, appropriate guarantees.

However, it should be remembered that FIAM ITALIA S.r.l. has carefully selected just those service providers who offer a superior level of security and protection in terms of personal data.

DATA RETENTION PERIOD

Browsing data

This data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site, without this occurring, the data are deleted immediately after processing.

Cookies

Cookies are stored for 12 (twelve) months, but only in aggregate form and do not allow users to be identified.

Data provided voluntarily by the user

The data provided voluntarily by the users with the sending of emails requesting information to the contacts present on the FIAM ITALIA Site will be stored only for the time necessary to give feedback to the interested parties and will be subsequently destroyed.

The data provided voluntarily by the users with the sending of emails to the contacts present on the FIAM ITALIA Site for the sending of CV aimed at the application as collaborators will be stored only for the time necessary to give an answer to the interested parties and will be stored for 1 year in order to consult them if the need arises to hire a new professional figure or to start a new collaboration.

YOUR RIGHTS AS A DATA SUBJECT

We inform you that, as a Data Subject, you are entitled to specific rights under the GDPR:

  • Right of access (art. 15);
  • Right to rectification (art. 16);
  • Right to deletion (the so-called “Right to cancellation”) (art. 17);
  • Right to restriction of processing (art. 18);
  • Right to which the Controller shall provide recipients with the rectification or deletion notification (art. 19);
  • Right to data portability (art. 20);
  • Right to object (art. 21).

You also have the right to revoke, at any time, consent to the processing of data. Such revocation will take effect the moment at which FIAM ITALIA S.r.l. becomes aware of it.

It should be remembered that, as per the GDPR, revoking consent does not prejudice the lawfulness of processing done on the basis of consent previously given.

Finally, you have the right to lodge a complaint with a Supervisory Authority, as specified below. The Italian Supervisory Authority is the Italian Data Protection Authority, whose contact details are available from http://www.garanteprivacy.it/web/guest/home/footer/contatti

In all the cases described, the exercise of your rights is brought to the attention of those to whom your data have been communicated, with the exception of the cases of exemption provided for by the GDPR, by referring to the reading of all contents at the following link http://www.garanteprivacy.it/regolamentoue/diritti-degli-interessati.

In some cases (cancellation, limitation, opposition) the exercise of your rights may not make it possible, in whole or in part, to follow up your requests made by email or through the web forms, nor to provide any performance and/or services for you.

All the rights described are exercised with request addressed without formality or by email to the address privacy@fiamitalia.it to FIAM ITALIA S.r.l., also through a representative, to whom is provided suitable feedback without delay.

THE RIGHT TO REVOKE CONSENT

Data Subjects have the right to revoke any consent previously given using the same means by which such consent was given or, in any case, by sending an email to privacy@fiamitalia.it.

Emails take effect upon receipt and, therefore, will, once received, initiate the process to interrupt any processing and to communicate to each Processor and sub-Processor to take note of the same.

It should be remembered that any revocation of consent does not prejudice the lawfulness of the processing done on the basis of the consent previously given.

THE RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

Data Subjects have the right, in the event of a breach of the regulations to the detriment of their rights and freedoms, to lodge a complaint with a Supervisory Authority. Complaints may be made via the web by completing an appropriate form, available on its site, www.garanteprivacy.it.

THE OBLIGATORY NATURE AND NEED TO PROVIDE YOUR DATA

Except as specified for the browsing data, it is up to the user to voluntarily provide personal and identification data if he or she so wishes.

Failure to provide the data requested by each page of the FIAM ITALIA Site, such as by way of example, name, surname, email address, will result in the impossibility of obtaining what is requested by the user.

PROFILING AND AUTOMATED DECISION-MAKING PROCESSES

Browsing data

Your browsing data is not used by FIAM ITALIA S.r.l. for profiling purposes or to activate automated decision-making processes.

Data provided voluntarily by the user

The data you spontaneously and voluntarily provide through the email addresses on the FIAM ITALIA Site and/or through the compilation of forms present in specific pages of the FIAM ITALIA Site will not be used for profiling purposes or to activate automated decision-making processes.

SECURITY MEASURES

The Controller has and will adopt suitable technical and organisational security measures, in compliance with the GDPR, in order to minimise the risks to your personal data such as destruction and loss, even accidental, unauthorised access and processing that is not permitted or that does not comply with the reasons for which the data has been collected, as defined in this Privacy Policy.

METHODS BY WHICH DATA IS PROCESSED

Data will be processed in compliance with article 32 of the GDPR and will be done using IT and telematic means as well as manual and paper methods.

Following periodic checks, the Controller will verify the strict relevance and non-excessive nature of the data collected with regard to the obligations and purposes of processing.

RULES OF BEHAVIOUR – THE COMMUNICATION AND DISCLOSURE OF DATA

The Controller, in order to comply with the provisions of the law in force, in the event that the user improperly uses the FIAM ITALIA Site in order to commit illegal acts and/or to carry out any criminal conduct that may be prosecuted, reserves the right to inform the public authority, in full compliance with the law.

 

CHANGES TO THE PRIVACY POLICY

This Privacy Policy may be changed in the event of new functions added to the FIAM ITALIA Site or following comments and suggestions from our users.

The same Privacy Policy may be modified at any time by publishing an updated version on the website effective from the date of publication of the same.

PRIVACY POLICY FIAM ITALIA CONTACTS

On this page, FIAM ITALIA S.r.l. describes the methods by which your personal data, sent via the form (the “Form”) on the FIAM ITALIA S.r.l. Contacts page, accessible through the link, www.fiamitalia.it/it/contatti, on this site (the “ FIAM ITALIA Site”), is processed.

If there are any doubts, you may contact us at privacy@fiamitalia.it

WHY IS THERE THIS POLICY?

From 25 May 2018, each Member State of the European Union was required to implement new privacy rules, under EU Regulation 2016/679 (the General Data Protection Regulation, or GDPR), as well as domestic laws, including Italian Legislative Decree 101/18.

The GDPR provides for greater protection of users and imposes new obligations and responsibilities on those parties who process personal data, including data acquired through websites.

For more information on the GDPR, refer to the useful and informative Section edited by the Italian Data Protection Authority: this will help you understand the new rules and will advise you of your rights.

Transparency is a fundamental principle: users must know, in advance, in a clear and comprehensive way, what personal information will be collected, the party or parties who will process this information, the reasons for such processing and the time for which the data may be processed, whether this data will be used for trade or commercial purposes or for profiling purposes, whether the data will be communicated to any third party, and how users can effectively check how their data is being managed or handled.

This policy is provided in compliance with article 13 of the GDPR and is based on article 29 of the Group’s guidelines on Transparency.

The policy is for users who complete the contact form in order to send a message to FIAM ITALIA S.r.l. In receiving your message and in responding to your request for information, FIAM ITALIA S.r.lwill process your personal data that you provide voluntarily. Detailed information is given below on how this data will be handled.

THE CONTROLLER AND CONTACT DETAILS

The Controller, in terms of processing your personal data referred to in this policy, is FIAM ITALIA S.r.l., with registered office at Via Ancona 1/B, 61010, Tavullia (PU), Italy; Tax Code and VAT no. 00335410437; Companies Register no. PS 101539, Certified Email address fiam@cert.fiamitalia.it, also reachable for any communication or request regarding your data via email at privacy@fiamitalia.it under EU Regulation 2016/679 and Italian Legislative Decree 101/18.

 

TYPES OF DATA PROCESSED

In addition to that specified in the FIAM ITALIA S.r.l. Privacy Policy for browsing data and email messages, FIAM ITALIA S.r.l. will request, through the Form, your name and email address (needed to reply to your requests), as well as any other personal data that you might include of your own volition in your message.

Any information you might voluntarily and of your own volition include in the Form may belong to a special category under article 9 of the GDPR, (i.e. information that could be used to reveal your race, convictions of a religious, philosophical or any other nature, political opinions, membership of a party, trade union or an organisation formed on the basis of a particular religious, philosophical, political or trade union nature, as well as personal data that could be used to reveal your state of health or sexual orientation). FIAM ITALIA S.r.l. will process this data solely with your consent, with the greatest confidentiality, in compliance with current regulations and exclusively for the following specific purposes.

PURPOSES FOR WHICH PROCESSING IS DONE AND THE LEGAL BASIS FOR DOING SO

Data acquired by FIAM ITALIA S.r.l. through the Form will be processed solely to the extent needed to respond to your requests.

The legal basis for processing such data is your express consent, as the Data Subject, as acquired in compliance with the GDPR.

 

Commercial communications

The personal data you provide through the Form will not be processed for informational, commercial or advertising purposes, unless you specifically request it.

If you wish, you may receive updates from FIAM ITALIA S.r.l. regarding its services and news by clicking LINK in order to subscribe to receive the FIAM ITALIA S.r.l. newsletter. Before giving your consent, you will be duly informed of the fact that FIAM ITALIA S.r.l., in compliance with article 13 of the GDPR and articles 8 and 9 of Italian Legislative Decree 70/03, may send messages containing commercial and/or promotional content regarding its services and its organised events to your email address.

If you consent to commercial communications being sent to you, you may, in any case and at any time, choose to revoke your consent. In this case, FIAM ITALIA S.r.l. will stop sending you future communications.

It should be remembered that, as per the GDPR, revoking consent does not prejudice the lawfulness of processing done on the basis of consent previously given.

You may revoke your consent through the same, simple means by which consent was provided.

 

RECIPIENTS OF PERSONAL DATA

The data you send through the Form will be processed exclusively by:

  • employees and contractors of FIAM ITALIA S.r.l.;
  • suppliers of IT services;
  • suppliers of email services;
  • suppliers of services connected to the management and operation of the FIAM ITALIA S.r.l. Site; 
  • any employees involved in occasional maintenance and repair operations;
  • suppliers of cloud services;
  • suppliers of hosting and virtual server services;
  • suppliers of management software;
  • suppliers of connection and telephony services;
  • suppliers of chat and communication services;
  • suppliers of file transfer services;
  • suppliers of remote assistance services.

Data will not be communicated to other categories of recipients, nor disclosed or made public in any way whatsoever.

Data may be communicated to a competent Authority if required by current regulation or at the request of a legitimate party.

INTENTION TO TRANSFER DATA TO A THIRD COUNTRY OR TO AN INTERNATIONAL ORGANISATION

Your data may be transferred to servers located in non-EU countries if the suppliers of IT services and the programs used by FIAM ITALIA S.r.l. provide for it or employ cloud computing technology which, by its very nature, makes it impossible to determine, with any certainty, exactly where your data is located.

Pursuant to the law, it should be noted that, currently, the European Commission has adopted an adequacy decision for a limited number of countries (Andorra, Argentina, Australia, PNR, Canada, the Faroe Islands, Guernsey, the Isle of Man, Israel, Jersey, New Zealand, Switzerland, Uruguay) and that, therefore, your personal data could be transferred by the Services used (e.g. Skype, Gmail) to countries for which no adequacy decision has been adopted, nor, at this time, for which FIAM ITALIA S.r.l. is able to provide, independently, appropriate guarantees.

However, it should be remembered that FIAM ITALIA S.r.l. has carefully selected just those service providers who offer a superior level of security and protection in terms of personal data.

 

DATA RETENTION PERIOD

The personal data you provide in completing the Form will be stored solely for the time needed to respond to you. The data will then be erased unless you consent to it being stored for other purposes such as, for example, to establish a commercial relationship. In that case, you will be provided with comprehensive, specific information.

YOUR RIGHTS AS A DATA SUBJECT

We inform you that, as a Data Subject, you are entitled to specific rights under the GDPR:

  • Right of access (art. 15);
  • Right to rectification (art. 16);
  • Right to erasure (the “Right to be forgotten”) (art. 17);
  • Right to restrict processing (art. 18);
  • Right to which the Controller shall provide recipients with the rectification or erasure notification (art. 19);
  • Right to data portability (art. 20);
  • Right to object (art. 21).

You also have the right to revoke, at any time, consent to the processing of data. Such revocation will take effect the moment at which FIAM ITALIA S.r.l. becomes aware of it.

It should be remembered that, as per the GDPR, revoking consent does not prejudice the lawfulness of processing done on the basis of consent previously given.

In some situations (erasure, restriction, objection), exercising your rights might make it impossible, in whole or in part, to follow up on any further requests made through the Form, or to provide any services or details you might request.

The rights described can be exercised by making a request, without any need for formality, or by sending an email to privacy@fiamitalia.it, to FIAM ITALIA S.r.l., including through a representative, to whom a suitable response will be sent without delay.

THE RIGHT TO REVOKE CONSENT

Data Subjects have the right to revoke any consent previously given using the same means by which such consent was given or, in any case, by sending an email to privacy@fiamitalia.it.

Emails take effect upon receipt and, therefore, will, once received, initiate the process to interrupt any processing and to communicate to each Processor and sub-Processor to take note of the same.

It should be remembered that any revocation of consent does not prejudice the lawfulness of the processing done on the basis of the consent previously given.

THE RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

Data Subjects have the right, in the event of a breach of the regulations to the detriment of their rights and freedoms, to lodge a complaint with a Supervisory Authority. Complaints may be made via the web by completing an appropriate form. The Italian Data Protection Authority has made a form available on its site, www.garanteprivacy.it.

THE OBLIGATORY NATURE AND NEED TO PROVIDE YOUR DATA

Users are free to provide the personal data requested through the Form. However, contact details are needed in order to carry out user requests.

Failing to provide the data requested in those fields duly marked on the Form will make it impossible to provide a response to a User’s request.

 

PROFILING AND AUTOMATED DECISION-MAKING PROCESSES

The data you provide voluntarily and of your own volition in completing the Form will not be used for profiling purposes, nor for automated decision-making processes.

 

SECURITY MEASURES

FIAM ITALIA S.r.l., as the Controller (in terms of processing personal data), has and will adopt suitable technical and organisational security measures, in compliance with the GDPR, in order to minimise the risks to your personal data such as destruction and loss, even accidental, unauthorised access and processing that is not permitted or that does not comply with the reasons for which the data has been collected, as defined herein.

METHODS BY WHICH DATA IS PROCESSED

Data will be processed in compliance with article 32 of the GDPR and will be done using IT and telematic means as well as manual and paper methods.

Data will be stored electronically as well as in paper archives in such a way as to allow, where required, aggregated data to be identified and selected, for the time not exceeding the duration and the processing needs as defined in the policy covering the collection of a Data Subject’s data.

Following periodic checks, the Controller will verify the strict relevance and non-excessive nature of the data collected with regard to the obligations and purposes of processing.

RULES OF BEHAVIOUR – THE COMMUNICATION AND DISCLOSURE OF DATA

In order to comply with current regulations, in the event that you use the Form improperly in order to commit an offence and/or to engage in any unlawful conduct, FIAM ITALIA S.r.l. reserves the right to inform a Public Authority, in full compliance with the law.

CHANGES TO THIS POLICY

This policy may be changed as a result of new features being added to the Services made available through the FIAM ITALIA Site or as a result of comments or suggestions sent by Users.

This same policy may be changed at any time by publishing a new, updated version on the FIAM ITALIA Site, with effect from the date on which the same is published there.

Should this policy change during the period in which we are in contact with you, we will duly inform you of it.

POLICY AUTHORISING NEWSLETTERS TO BE SENT

WHY IS THERE THIS POLICY?

From 25 May 2018, each Member State of the European Union was required to implement new privacy rules, under EU Regulation 2016/679 (the General Data Protection Regulation, or GDPR), as well as domestic laws, such as Italian Legislative Decree 101/18.

The GDPR provides for greater protection of users and imposes new obligations and responsibilities on those parties who process personal data, including data acquired through websites.

For more information on the GDPR, refer to the useful and informative Section edited by the Italian Data Protection Authority: this well help you understand the new rules and will advise you of your rights.

Transparency is a fundamental principle: users must know, in advance, in a clear and comprehensive way, what personal information will be collected, the party or parties who will process this information, the reasons for such processing and the time for which the data may be processed, whether this data will be used for trade or commercial purposes or for profiling purposes, whether the data will be communicated to any third party, and how users can effectively check how their data is being managed or handled.

This policy is provided in compliance with article 13 of the GDPR and is based on article 29 of the Group’s guidelines on Transparency.

The policy is for users who sign up for our Communications, by providing their email address.

Since acquiring some of your personal data – pursuant to the GDPR – is needed to sign up for our Communications, you will find detailed information below on how FIAM ITALIA S.r.l. will process your personal data.

THE CONTROLLER AND CONTACT DETAILS

The Controller, in terms of processing your personal data referred to in this policy, is FIAM ITALIA S.r.l., with registered office at Via Ancona 1/B, 61010, Tavullia (PU), Italy; Tax Code and VAT no. 00335410437; Companies Register no. PS 101539, Certified Email address fiam@cert.fiamitalia.it, also reachable for any communication or request regarding your data via email at privacy@fiamitalia.it under EU Regulation 2016/679 and Italian Legislative Decree 101/18.

TYPES OF DATA PROCESSED

To subscribe to the Newsletter, FIAM ITALIA S.r.l. will request the following personal data:

first name and last name;

email address;

country of origin;

whether you are a Reseller, Architect/Interior Designer or a Private Individual.

Providing this personal data is a necessary requirement in order to be able to send you Communications which are in line with your interests, as well as to confirm that you are at least 14 years old pursuant to Italian Legislative Decree 101/18.

FIAM ITALIA S.r.l. will process this data with the greatest confidentiality, in compliance with current regulations and exclusively for the following specific purposes.

 

PURPOSES FOR WHICH PROCESSING IS DONE AND THE LEGAL BASIS FOR DOING SO

Your personal data, as specified above, will be processed by FIAM ITALIA S.r.l. exclusively for the purposes of registering you on our mailing list and sending you Communications including, by way of example, preview offers for customers registered to receive our Newsletter and discount codes for any later purchases.

The legal basis for processing such data is your express consent, as the Data Subject, as acquired pursuant to article 6(1)(a) of the GDPR.

You may, at any time, choose to revoke your consent.

In this case, FIAM ITALIA S.r.l. will stop sending you future Communications.

You may revoke your consent through the same, simple means by which consent was provided. Each message will contain a link to unsubscribe.

RECIPIENTS OF PERSONAL DATA

Your personal data acquired and processed by FIAM ITALIA S.r.l. to manage and to send Communications will be processed exclusively by employees and contractors of FIAM ITALIA S.r.l. as well as by providers of IT services related to the management and operation of the mailing list service, in addition to any employees involved in occasional maintenance and repair operations.

Your data may also be communicated to a competent Authority where required or envisaged by law. Data will not be disclosed in any way whatsoever.

INTENTION TO TRANSFER DATA TO A THIRD COUNTRY OR TO AN INTERNATIONAL ORGANISATION

Browsing data and data sent by users of their own volition through the various channels made available by the FIAM ITALIA Site may be transferred to servers located in non-EU countries if the suppliers of IT services and the programs used by FIAM ITALIA S.r.l., listed above as recipients, provide for it or employ cloud computing technology which makes it impossible to determine, with any certainty, exactly where your data is located.

Pursuant to the law, it should be noted that, currently, the European Commission has adopted an adequacy decision for a limited number of countries (Andorra, Argentina, Australia, PNR, Canada, the Faroe Islands, Guernsey, the Isle of Man, Israel, Jersey, New Zealand, Switzerland, Uruguay) and that, therefore, your personal data could be transferred by the Services used (e.g. Skype, Gmail) to countries for which no adequacy decision has been adopted, nor, at this time, for which FIAM ITALIA S.r.l. is able to provide, independently, appropriate guarantees.

However, it should be remembered that FIAM ITALIA S.r.l. has carefully selected just those service providers who offer a superior level of security and protection in terms of personal data.

 

DATA RETENTION PERIOD

The personal data acquired and processed by FIAM ITALIA S.r.l. to manage and to send Communications will be stored for the entire time that you are registered to receive the same.

If you decide to unsubscribe from the Communications, your email address will be added automatically to a “contacts black list” to indicate that it can no longer be used. This is an automated procedure provided by the supplier of the mailing list service. FIAM ITALIA S.r.l., in order to guarantee and safeguard your personal data, will periodically destroy the black list database.

YOUR RIGHTS AS A DATA SUBJECT

We inform you that, as a Data Subject, you are entitled to specific rights under the GDPR:

  • Right of access (art. 15),
  • Right to rectification (art. 16),
  • Right to erasure (the “Right to be forgotten”) (art. 17),
  • Right to restrict processing (art. 18),
  • Right to which the Controller shall provide recipients with the rectification or erasure notification (art. 19),
  • Right to data portability (art. 20),
  • Right to object (art. 21).

You also have the right to revoke, at any time, consent to the processing of data. Such revocation will take effect the moment at which FIAM ITALIA S.r.l. effectively becomes aware of it.

It should be remembered that, as per the GDPR, revoking consent does not prejudice the lawfulness of processing done on the basis of consent previously given.

Finally, you have the right to lodge a complaint with a Supervisory Authority, as specified below. The Italian Supervisory Authority is the Italian Data Protection Authority, whose contact details are available from http://www.garanteprivacy.it/web/guest/home/footer/

In all the cases described, exercising your rights is brought to the attention of those parties to whom your data may have been communicated, except for those exemptions provided for by the GDPR, by referring to the letter of each point at  http://www.garanteprivacy.it/regolamentoue/diritti-degli-interessati 
In some situations (erasure, restriction, objection), exercising your rights might make it impossible to send you Communications.

All the rights described above may be exercised by making a request, without any need for formality, or by sending an email to privacy@fiamitalia.it, including through a representative. Suitable responses will be provided to your requests without delay.

THE RIGHT TO REVOKE CONSENT

Data Subjects have the right to revoke any consent previously given using the same means by which such consent was given or by sending an email to privacy@fiamitalia.it.

Emails take effect upon receipt and, therefore, will, once received, initiate the process to interrupt any processing and to communicate to each Processor and sub-Processor to take note of the same.

It should be remembered that any revocation of consent does not prejudice the lawfulness of the processing done on the basis of the consent previously given.

THE RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

Data Subjects have the right, in the event of a breach of the regulations to the detriment of their rights and freedoms, to lodge a complaint with a Supervisory Authority. Complaints may be made via the web by completing an appropriate form. The Italian Data Protection Authority has made a form available on its site, www.garanteprivacy.it.

THE OBLIGATORY NATURE AND NEED TO PROVIDE YOUR DATA

Providing your personal data is optional: You are free to voluntarily and of your own volition provide your personal data to FIAM ITALIA S.r.l. or not.

However, processing the personal data requested in the Form is a necessary requirement to be able to register you. Failure to provide this data will make it impossible to register you on the mailing list and, therefore, to send you Communications.

 

PROFILING AND AUTOMATED DECISION-MAKING PROCESSES

The personal data you provide voluntarily and on your own volition to register yourself on the mailing list in order to receive Communications will not be used for profiling purposes, nor to initiate automated decision-making processes.

SECURITY MEASURES

The Controller (in terms of processing personal data) has and will adopt suitable technical and organisational security measures, in compliance with the GDPR, in order to minimise the risks to your personal data such as destruction and loss, even accidental, unauthorised access and processing that is not permitted or that does not comply with the reasons for which the data has been collected, as defined herein.

METHODS BY WHICH DATA IS PROCESSED

Data will be processed in compliance with article 32 of the GDPR and will be done using IT and telematic means as well as manual and paper methods.

Following periodic checks, the Controller will verify the strict relevant and non-excessive nature of the data collected with regard to the obligations and the purposes of processing, as well as compliance with current legislation.

CHANGES TO THIS POLICY

This policy may be changed, for example to adapt it to future regulations.

Should this policy change during the period in which we are in contact with you, we will duly inform you of it.

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