PRIVACY POLICY FRIGEL FIRENZE S.P.A.

Frigel Firenze S.p.A., in its capacity as data controller (hereafter: “the Data Controller”) pursuant to the Legislative Decree n. 196/2003 and subsequent amendments (hereafter: “the Italian Personal Data Protection Code”) informs you that your privacy and the protection of your personal data is one of the main objectives of its activity. Therefore, we invite you to carefully read our privacy policy before communicating any of your personal data to the Data Controller. This policy contains important information regarding your privacy, the protection of your personal data and the security measures that are in place for the purpose of guaranteeing the full compliance with the applicable legislation.

Additionally, this Privacy Policy:

  • applies to the current website (hereafter: “the Website”), which is managed by the Data Controller;
  • forms an integral part of the Website and of the services that we offer;
  • is to be construed as an Information Notice given to those who interact with the web services of this Website, in accordance with art. 13 of the Personal Data Protection Code;
  • complies with the Recommendation n. 2/2001 regarding the minimum requirements for the online personal data collection within the European Union, which was adopted by the Article 29 Working Party on the 17th of May 2001.

The data controller informs you that your personal data will be processed according to the principles of correctness, legitimacy, transparency and protection of your privacy and your rights. Your personal data will processed in compliance with the legislative provisions of the Italian Personal Data Protection Code and of the obligations contained therein.

TABLE OF CONTENTS

We hereby provide you with the table of contents of the Privacy Policy, so that you can easily find the information you are looking for:

1. Data controller and data processors
2. Types of data processed

2.1 Browsing data
2.2 Data voluntarily supplied by the user
2.3 Cookies

3. Purposes of the data processing and the compulsory or optional nature of the communication of personal data
4. Data processing methods, data security and place of processing
5. Communication and dissemination of the personal data
6. Your rights
7. Amendments
8. Contact information

1. DATA CONTROLLER AND DATA PROCESSORS

The browsing of this Website may lead to the processing of data relating to persons that are identified or identifiable. The Data Controller and manager of this Website is Frigel Firenze S.p.A., Via Pisana 316, Scandicci (Fi), VAT Number 00390240489, email: privacy@frigel.com.

Your personal data could be communicated to employees or collaborators of the Data Controller, such as those working on administrative, commercial, legal, accounting matters or to system administrators, operating directly under the authority of the data controller and duly appointed as data processors or persons in charge of the data processing, pursuant to articles 29 and 30 of the Italian Personal Data Protection Code and receiving related working instructions.

The data processor is Frigel North America, appointed through the standard model clauses of the European Commission that were approved by the Decision 2010/87/UE. The updated list of other possible data processors is available for consultation at the headquarters of the Data Controller, which you can contact at the following email address: privacy@frigel.com.

2. TYPES OF DATA PROCESSED

2.1 Browsing data

During their normal operation, the computer systems and software procedures used to operate this Website collect some personal data, the transmission of which is an integral part of Internet communication protocols. This information is not collected in order to be associated with identified data subjects but, by its very nature, it may allow users to be identified by processing and associating it with data held by third parties.

This category of data includes the IP address or domain name of the computer used by visitors connecting to the Website, the URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as a reply, the numeric code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding the user’s operating system and computer environment.

This data is used exclusively to obtain anonymous statistics on Website use and to check its proper functioning, and is deleted immediately after processing. The data might also be used to ascertain any liability in cases of alleged computer crimes against the Website or against third parties; without prejudice to this possibility, at present the data of web contacts is not stored for longer than is necessary for the purposes detailed in section 3 below.

2.2 Data voluntarily supplied by the user

The Website gives users the possibility of voluntarily communicating personal data, for instance, through the contact form, the request of services, information or estimated budgets or by means of voluntarily sending an email to the email address indicated on the Website, etc.

2.3 Cookies and their use

Definitions, characteristics and application of the regulations

Cookies are small text files that websites send and record on your computer or mobile device, in order for them to be then retransmitted to the same websites the following time that you access them. It is precisely thanks to the cookies that the Website remembers the actions and preferences of the user (such as, for instance, log in data, the chosen language, the font size, other viewing settings etc.) so that they do not have to be indicated by the user on every single visit to a website or when the user switches from one page of a website to another.

Cookies are, therefore, used to fulfil authentication, session monitoring and information memorisation purposes regarding the activity of users that access a website, and may also contain a unique identification code, which enables the tracking of the user’s browsing within a website, for statistical or advertising purposes. Throughout the browsing of a website, the user may also receive, on his/her computer or mobile device, cookies from websites or web servers other than the ones that the user is browsing (so-called “third party cookies”). Some operations would not be possible without the use of cookies, which are in some cases necessary for the functioning of the website itself, from a technical point of view.

There are various types of cookies, categorised according to their characteristics and functions, and these may be stored in the user’s computer or mobile device for varying periods of time: the so-called session cookies are automatically cancelled when the browser is closed; the so-called permanent cookies remain on the user’s devices for a predetermined time.

According to Italian legislation, the use of cookies does not always require the express consent of the user. In particular, “technical cookies” (the ones that are used for the sole purpose of transmitting a communication through an electronic network, or for the purposes strictly necessary to the performance of a service requested by the user) are exempt from the consent requirement. In other words, cookies that are necessary for the functioning of the Website or for the performance of a service requested by the user do not require the user’s consent.

Amongst the technical cookies, that do not require an express consent in order to be used, the Italian Data Protection Authority also includes (see, to that extent, the Simplified Arrangements to Provide Information and Obtain Consent Regarding Cookies – 8 may 2014):

  • “analytics cookies” (“first-party cookies” or “proprietary cookies”), wherever they are used directly by the website owner, or third-party cookies, wherever appropriate tools are used in order to minimise the identification feature and, at the same time, the owner of the website concluded a contract with the third-party by which the owner takes upon himself to use such cookies exclusively for the provision of the requested services, to store them separately and not to enrich them by cross-referencing the data contained in such cookies with other data;
  • “browsing cookies” or “session cookies” (for authentication/log-in purposes);
  • “functionality cookies”, which enable the user to browse the website according to a series of selected criteria (for example, language, products selected for purchase) in order to improve the service provided to the same user, are also exempt from the requirement of consent.

By contrast, “profiling cookies”, i.e. those aimed at creating a profile of the user for targeted advertising in line with the preferences shown by the same user in his or her internet browsing, require the prior consent of the user.

Types of cookies used by the Website and the possibility of enabling/disabling them

The Website uses the following types of cookies and offers the user the possibility of enabling/disabling them, except for third-party cookies, for which the user is advised to refer to the enabling/disabling methods offered by the respective managers of the cookies (see “third party cookies” below):

  • Technical cookies – browsing or session cookies – are strictly necessary for the functioning of the Website or to provide the users with services or content that has been explicitly requested by themselves;
  • Functionality cookies – used to activate specific features of the website and a number of selected criteria (e.g. language, the product selected for purchase) in order to improve the browsing experience on our Website.
  • Technical-analytics cookies – are used by the owner of the Website in order to understand how the Website is browsed by the users. These cookies do not collect any information on the identity of the user, nor do they collect any personal data. The information is processed in aggregate and anonymous form. For more information on the functioning of such cookies, please refer to the links of the respective information notices of the third parties on the use of cookies, as indicated below.

WARNING: Disabling technical cookies or functionality cookies may result in the website not functioning correctly or in some services or features of the website being unavailable; the user may be required to edit or insert manually some information every time that the website is accessed or whenever the page of the website is switched.

Google Analytics

In particular, the cookies used on the Website are indicated at the following link: Level II Cookie Policy

How to view and edit the cookie settings in your browser

The user can select which cookies to authorize, according to the procedure of the Website, as well as which cookies to authorize, block or delete (in whole or in part) according to the procedures of the browser used.

However, in the event that all or some cookies are disabled, the Website may not function correctly or some services or features of the website may be unavailable; the user may be required to edit or insert manually some information every time that the Website is accessed or whenever the page of the Website is switched.

For more information on how to set up your preferences on the use of cookies through your own browser, please check the instructions below:

3. PURPOSES OF THE DATA PROCESSING AND THE COMPULSORY OR OPTIONAL NATURE OF THE COMMUNICATION OF PERSONAL DATA

The Data Controller processes your personal data for the following purposes:

a) Purposes related to the performance of the services requested (for instance, contact request, request for information, request for the submission of documents or for the possibility of downloading documentation from the Website)

The communication of your personal data for the above-mentioned purpose (a) is optional, but the lack of communication of the data may render the performance of the service impossible.

Pursuant to art. 24, section 1, sub-section b) of the Italian Personal Data Protection Code, we do not request your consent for the processing of your personal data for such purpose, given that the data is necessary for the performance of obligations deriving from a legal agreement and/or for complying with specific requests of the data subject prior to the conclusion of the legal agreement.

b) Purposes related to statistical research/analysis of anonymous or aggregated data, without the possibility of identifying the user, aimed at checking the quality of the services that we offer.

Data processing involving anonymous or aggregated data does not require the application of the Italian Personal Data Protection Code.

c) Purposes related to the compliance with a legal obligation, regulation or EU legislation

The communication of your data for the purposes mentioned above under letter (c) is obligatory. The lack of communication of the data would render the Data Controller unable to comply with legal obligations or obligations stemming from a regulation or from an EU legislation.

It is pointed out that, pursuant to art. 24, section 1, sub-section a) of the Italian Personal Data Protection Code, data processing for this purpose is exempt from the requirement of consent.

4. DATA PROCESSING METHODS, DATA SECURITY AND PLACE OF THE PROCESSING

Your data is processed by the Data Controller – or by third parties, carefully selected for their competence and duly appointed as data processors by the Data Controller – solely for the fulfilment of the purposes for which they were collected, with automated instruments, but also in paper form, in any case only for the time strictly necessary for fulfilling the purposes for which they were collected.

Specific security measures are applied in order to prevent the risk of destruction or loss of data and in order to prevent the non-authorized access, in full compliance with articles 31 et seq. of the Italian Personal Data Protection Code as well as the Technical Regulations – Appendix B to the Code – regarding the minimum security measures.

The processing related to the web services of this Website takes place predominantly at the above-mentioned headquarters of the Data Controller. The data centres of the Data Controller are located on American territory. The Data Controller uses technological/data centre services provided by Bluehost in order to perform some processing of the data for the purposes mentioned above; subsequently, the data may also be stored at the headquarters of this/these entity/entities.

5. COMMUNICATION AND DISSEMINATION OF THE PERSONAL DATA COLLECTED

Your common personal data may be communicated to third parties, if this is necessary and functional for the performance of the services by the Data Controller.

Your personal data may be shared with third parties such as: 1) People, companies or professional offices that offer Data Controller consulting services on legal, accounting, administrative, financial, taxation and credit recovery matters related to the supply of our Services, duly appointed as data processor by the data controller; 2) People, entities or authorities to whom the communication of your personal data is compulsory based on the applicable legal requirements or by order of the authorities; 3) Parties delegated and/or entrusted by Data Controller with the performance of activities strictly related to the provision of the Services or parties delegated and/or entrusted by Data Controller with the performance of technical maintenance activities (including the maintenance of network devices and of electronic communication networks) and who are duly appointed, where necessary, as data processors as per art. 29 of the Personal Data Protection Code, or as persons in charge of the processing; 4). Commercial partners, only where you have provided your specific consent for your data to be communicated to such parties.

As a rule, your personal data will not be disclosed to third parties. The Data Controller reserves the right to carry out processing that may involve dissemination, only where you have given your specific and prior consent and only within the limits established by the applicable law.

6. YOUR RIGHTS

The data subjects have the right, at any time, to obtain confirmation as to whether or not personal data concerning him or her exist and to be informed of the source of the personal data, to obtain updating, rectification or, where interested therein, integration of the data (art. 7 of the Italian Personal Data Protection Code).

Pursuant to the same article, the data subject has the right to demand erasure, anonymization or blocking of data that have been processed unlawfully, and to object, on legitimate grounds, to the processing of personal data concerning him/her.

For requests regarding the above, please send an email to privacy@frigel.com.

7. AMENDMENTS

The Data Controller may modify or simply update the Privacy Policy of the Website, in part or in whole, also in order to comply with the variations or amendments of the applicable legislative and regulatory provisions related to privacy and data protection. Such variations and updates of the Privacy Policy will be notified to the users by displaying a notice on the home page as soon as the new provisions are introduced, and they will be enforceable as soon as they are published on the website. We therefore invite you to regularly check this section in order to learn about the most recent and updated version of the Privacy Policy, so that you can always be informed of the information we collect and of way we intend to process it.

8. CONTACT INFORMATION

If you wish to receive any further information related to the data processing operated by the Data Controller, please send your request by email to privacy@frigel.com.