INFORMATIVE NOTE ON PERSONAL DATA PROCESSING (Articles 5-6-7-12-13 EU Regulation No. 679/2016)

PROCESSING CONTROLLER CONTACT DATA  AND INFORMATION ART. 13, PARAGRAPH 1, LETTER A) OF UE REGULATION NO. 679/2016

PROCESSING CONTROLLER
Silta S.n.c., Via Carlo Farini 78 – 20159 Milano – Italy

PROCESSING CONTROLLER CONTACT DATA
privacy@silta.it

DATA PROTECTION OFFICER CONTACT DATA
Silta does not fall within the hypotheses provided for in article 37 of UE Regulation No. 679/2016

PROCESSOR
Website manager as responsible for the management and maintenance of the web portal www.silta.it, ex articles 28 and 29 of the EU Reg. No. 679/2016

Silta s.n.c., with registered office in Via Carlo Farini 78, 20159 Milan Italy VAT number 11013200156, as Data Controller of your personal data, informs you, according to the articles 12 and 13 of EU Regulation No. 679/2016 (General Data Protection Regulation, henceforth referred to as “GDPR” ), that your personal data will be processed by specifically authorized parties and limited to the purposes and methods specified below.

OBJECT AND PURPOSE OF DATA PROCESSING

Silta, as Data Processing Controller, informs you that it will process your personal data (specifically and limited to your personal , tax, postal and e-mail, and identification data and IP addresses or domain names), which you have communicated, for the sole purpose of registering with the www.silta.it service,  allowing Silta to carry out the following activities and services: sending newsletters, information and regulatory updates, sending commercial proposals, managing technical assistance, labor managing in warranty, reporting of advertising events, sending promotional communication for a similar service, management of direct relationships and company / client-user contacts, through e-mail, between Silta and users and visitors of its web portal www.silta.it (Article 13, paragraph 1, letter C of the GDPR). This information is effective only with reference to the aforementioned web portal www.silta.it, and not with reference to other and different portals or websites that may be consulted through the links therein, of which, of course, the undersigned company Silta is in no way the owner.

The optional, explicit and voluntary sending of emails to the addresses indicated on this site implies, therefore, the subsequent acquisition of the sender’s email address, necessary to respond to requests, as well as any other personal data included in the message.

Moreover, 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 is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified.

This category of data includes IP addresses or domain names of the computers used by users connecting to the site, the addresses in  Uniform Resource Identifier (URI) notation of the requested resources, 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 relating to the operating system and the user’s computer environment.

These data are used for the sole purpose of obtaining anonymous statistical information on the site use and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site: except for this eventuality, the data on web contacts do not persist for more than 360 days.

Apart from that specified for navigation data, the communication from you, to the undersigned company, of the personal data above better specified, has the sole condition of lawfulness of the processing, pursuant to art. 6, par. 1, letter a of the GDPR, your express consent, and therefore, is purely optional and not mandatory, having no other consequence if not the impossibility for the owner to perform the aforementioned activities and services. And, in any case, the consent you may have provided may be revoked by you at any time, with immediate effect on the aforementioned business activities and services.

DATA PROCESSING METHOD

Il Trattamento dei dati personali da Lei comunicati è realizzato per mezzo delle operazioni indicate all’art. 4 Codice Privacy e all’art. 4 n. 2) del GDPR, e precisamente: “raccolta, registrazione, organizzazione, conservazione, consultazione, elaborazione, modificazione, selezione, estrazione, raffronto, utilizzo, interconnessione, comunicazione, cancellazione e distruzione dei dati”.

The processing of personal data communicated by you is carried out by means of the operations indicated in art. 4 of the Privacy Code and art. 4 No. 2 of the GDPR, namely: “collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, communication, cancellation and data destruction and wiping.

The personal data communicated by you are processed in paper, computerized and telematic form and entered in the relevant personal data and related databases (customers, users) for the time strictly necessary to achieve the purposes for which they were collected, using technical and organizational measures, taken to prevent data loss, illicit or incorrect use and unauthorized access, and therefore, to guarantee a level of security appropriate to the risk pursuant to art. 32 of the GDPR 2016/679, by specifically authorized subjects, in compliance with the provisions of art. 29 of the GDPR 2016/679, or employees and / or collaborators of Silta in their capacity as authorized subjects and / or internal delegated representatives and / or system administrators, who may carry out operations of consultation, use, processing, comparison and any other appropriate operation, including automated, in compliance with the provisions of the law necessary to ensure, inter alia, the confidentiality and security of data as well as the accuracy, updating and relevance of the data in accordance with the purposes and methods stated.

It should be noted, in particular, that the personal data you have communicated will be processed only at the headquarters of the data controller, will not be disseminated, and, pursuant to art. 13, paragraph 1, lett. (e), they may be processed only by authorized persons and / or delegated internal delegates within the company of the functions assigned to it (see Organigram and Mansion Privacy) and / or also by external processors (in person of individual professionals) and / or complex professional associations), but only and exclusively for the purposes expressly and specifically indicated above.

In particular, in relation to the purposes indicated above, the data may be disclosed to the following persons and / or categories of persons indicated below, or may be disclosed to companies and / or persons, both in Italy and abroad, who provide services , also external, on behalf of the Data Controller.

Among these, they are indicated for greater clarity, by way of example but not exhaustively: internal or external subjects to the company that provide computerized and telematic services for the management of the information system used by Silta and the telecommunications networks (including the post office) electronic and management of web portals and internet sites – hosting); subjects that carry out user assistance activities; professional studies; financial administrations and other companies or public bodies in fulfillment of regulatory obligations; competent authorities and / or Supervisory Bodies for the fulfillment of legal obligations; consulting company; companies and law firms for the protection of contractual rights; subjects that carry out control, revision and certification of the activities carried out by Silta it is specified that the subjects belonging to the aforesaid categories are all appointed by the undersigned company as External Responsible for data processing pursuant to art. 28 of the GDPR, or operate in total autonomy as separate Data Controllers. The list of external data processors is constantly updated and available at the Silta office.

In case of need, the data related to the newsletter service can be processed by authorized personnel of the company that manages the management and maintenance of the technological part of the site, (web site manager), appointed external responsible for the processing of personal data, at the headquarters of the society

We point out that, in compliance with the principles of lawfulness, limitation of purposes and the conservation and minimization of data, pursuant to art. 5 GDPR 2016/679, except as specified above for data on web contacts for which the retention period corresponds to no more than 7 (seven) days, the retention period of your personal data is established for a period of time not superior to the achievement of the purposes for which they are collected and processed, or for the entire duration of registration to the service www.silta.it

Silta informs you that, for the purposes of processing your personal data, it does not make use of automated decision-making processes, i.e. those aimed at making decisions based solely on technological means on the basis of predetermined criteria (that is without human involvement), or conducting profiling, that is, the one aimed at using your personal data to analyze or predict aspects of professional performance, economic situation, health, personal preferences, interests, reliability, behavior, location or travel, etc.

DATA SUBJECT RIGHTS

Right of access pursuant to art. 15 of the GDPR and Right of Rectification pursuant to art. 16 of the GDPR

As a data subject, pursuant to art. 15 GDPR, You have the right to obtain from Silta, as the data controller, confirmation of the existence or otherwise of processing of personal data concerning you, to obtain access to them and to all the information referred to in the same art. 15, paragraph 1, letters (a) to (h), by issuing a copy of the data processed in a structured format, in common use, readable by an automatic and interoperable device.

You, pursuant to art. 15 GDPR, also has the right to obtain from Silta the rectification and / or integration of the data being processed if they are not updated and / or inaccurate and / or incomplete, by requesting and simultaneously issuing an additional declaration to be sent to the email address privacy@silta.it.

Silta will confirm the receipt of your request and provide you with information on the action taken, with reference to the exercise of your rights provided for in articles. From 15 to 22 GDPR, within 1 day from receipt of the request. If necessary, and taking into account the complexity and the number of requests, Silta will be able to extend this deadline of 1 day, subject to a reasoned communication to be sent within 1 day from receipt of the request.

Silta will communicate any rectification and / or integration to all recipients, as identified by the art. 4, paragraph 1, n. (9) of the GDPR, to which such data have been transmitted, unless this proves impossible and / or involves a disproportionate effort.

After sending your request for access or correction, if Silta has reasonable doubts about your identity, we will ask you for further information to confirm it. These communications will be sent by email from the address privacy@silta.it, and will be processed by the person specifically authorized for the purpose.

In the event that Silta does not comply with your request within the period of 2 days from receipt of the request, Silta will inform you of the reasons for the non-compliance, informing you from now on your right to propose a complaint to a Supervisory Authority, as specified pursuant to art. 13, paragraph 2, letter (d).

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Cancellation right pursuant to art. 17 of the GDPR and the right to limit the processing pursuant to art. 18 of the GDPR

As a data subject, you have the right to obtain, without undue delay, from Silta, exclusively in the cases referred to in art. 17, paragraph 1, letters from (a) to (f), of the GDPR, the deletion of data concerning them – with the exception of the hypotheses specifically provided for by art. 17 paragraph 3.

As a data subject, and in the case one of the hypotheses referred to in art. 18, paragraph 1, letters from (a) to (d), of the GDPR, you have the right to request and obtain from Silta, by communication via email to privacy@silta.it, or by registered mail to the AR address Via Carlo Farini 78, 20159 Milano Italy, the limitation of the processing of your personal data, or that such data are not subject to further processing and can no longer be modified. Silta ensures that the limitation of the treatment is implemented through appropriate technical devices that guarantee its inaccessibility and immutability,
Silta will communicate any cancellation of your data and / or limitation of processing to all recipients, as identified by the art. 4, paragraph 1, n. (9) of the GDPR, to which these data have been transmitted, unless this proves impossible and / or involves a disproportionate effort.

Silta will confirm the receipt of your request and provide you with information on the action taken within 1 day from receipt of the request. If necessary, and taking into account the complexity and the number of requests, Silta may extend this deadline of 1 day, subject to a reasoned communication to be sent within one month of receiving the request.

If your request is manifestly unfounded or excessive, especially in terms of repetition of the same, Silta may charge a reasonable fee to provide the information, communication or take the action requested, or refuse to meet the request.

In the event that Silta does not comply with your request within the term of 1 day from receipt of the request, Silta will inform you of the reasons for the non-compliance, informing you from now on your right to propose a complaint to a Supervisory Authority, as specified pursuant to art. 13, paragraph 2, letter (d).

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Right to data portability pursuant to art. 20 of the GDPR

As a data subject, you have the right to receive from Silta personal data concerning you in a structured format, commonly used and readable by automatic device, and you also have the right to transmit such data to another data controller, or to obtain from Silta, where technically feasible, the direct transmission of such data to another Data Controller specifically identified, upon request to be sent by e-mail to the address privacy@silta.it or by means of the Registered Address Via Carlo Farini 78 , 20159 Milan Italy.

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Right to oppose treatment pursuant to art. 21 of the GDPR

You have the right to object at any time to the processing of personal data concerning you, for reasons related to your particular situation, in cases where the processing of your data is necessary (1) for carrying out a task of public interest and / or connected to the exercise of public authority of which Silta is invested; (2) for the pursuit of a legitimate interest of Silta or a third party; (3) for profiling activities performed by Silta based on the previous points.

You also have the right to object to the processing of your personal data for reasons related to your particular situation if they are processed for scientific or historical research purposes or for statistical purposes in accordance with Article 89 (1) of the GDPR, except in the case where the processing is necessary for the performance of a task of public interest.

The will to exercise the right to object to the processing of your data must be communicated to Silta by e-mail to privacy@silta.it, or by registered mail to the address Via Carlo Farini 78, 20159 Milano Italy. The company Silta will confirm, without undue delay, the receipt of your communication.

Following your communication, Silta, except to prove the existence of binding legitimate reasons to proceed with the processing of your data that prevail over your interests, rights and liberties, or that the treatment is necessary for the assessment, exercise or defending a right in court, or that processing for the purposes of scientific, historical or statistical research is necessary for the performance of a task in the public interest, will refrain from further processing your personal data.

You have the right to oppose the processing even if your personal data are processed by Silta for the purposes of direct marketing and / or profiling activities linked to direct marketing. In such cases, Silta, having received your notice in the manner indicated above, will refrain from further processing your personal data.