Privacy policy

PRIVACY POLICY

INFORMATION ON PROCESSING OF PERSONAL DATA

 

 

This information is provided under Article 13 of legislative Decree. nr. 196/2003 – Codex regarding the protection of personal data (the “Privacy Code”) and Article 13 of Regulation (EU) 2016/679 – “European General personal data protection Regulation”.

 

 

The Company TWL Systems S.r.l. having its registered office in Udine (UD), Viale Palmanova, 73/R, in the person of Mr. Giorgio Grifoni, as processing Controller (hereinafter referred to as “Controller”), hereby inform you that, pursuant to the Article 13 of legislative Decree. nr. 196/2003 (hereinafter referred to as “Privacy Code”) and to the Article 13 of Regulation (EU) 2016/679 (hereinafter referred to as “GDPR”), data will be processed as follows:

 

 

  1. Subject

TWL Systems S.r.l. cares about your personal data protection and respect the applicable personal data protection Regulation (Privacy Code and GDPR 2016/679). Your personal data shall be processed as confidential and may be transferred to third-party only in accordance with this Policy or with your consent. We process your personal data you provide us using the website and/or after the registration to the website.

 

In particular, we process:

  1. the personal, identifying and non-sensitive data (particularly, name, surname, tax code, VAT number, e-mail, telephone number – hereinafter “Personal data” or “data”) provided by you during the registration on the website;
  2. any data not provided by you but acquired in compliance with Article 14, paragraph 5 of GDPR, whose transmission is connected to the use of Internet communication protocols (including but not limited to, visits to the page, amount of data transferred, Status message on access, session ID, IP and URL addresses, etc.).

These data allow us to reconstruct the course of your visits to the website.

 

 

  1. Purposes

Your personal data are processed:

  1. A) without your expressed consent (Article 24 (a), (b), (c) of the Privacy Code and Article 6, b), e) of the GDPR) with the following purposes:

 

  1. to process a contract request;
  2. the implementation of pre-contractual measures taken in response to your request;

iii. to compile internal statistics;

  1. to fulfill the pre-contractual, contractual, accounting and fiscal obligations arising from the existing relationships;
  2. to comply with obligations of laws, regulations, Community legislation or as ordered by an authority;
  3. to protect the vital interests of the data subject or of another natural person;

vii. to perform the public interest tasks or related to the exercise of official authority by the Controller;

viii. to prevent the emergence of fraudulent activities or harmful practices affecting the website;

  1. to pursue a legitimate interest by the Controller or third party in compliance with Article 6 (f) of the GDPR;
  2. to exercise the Controller’s rights, (including without limitation, his rights of defense);

 

  1. B) Only with your specific and irrevocable consent (Articles 23 and 130 of the Privacy Code, and Article 7 of the GDPR), for marketing purposes, such as:

 

  1. to send by e-mail any newsletter, commercial communication and/or promotional material on products and/or services offered by the Controller, which are different and/or dissimilar from those already acquired.

 

 

  1. Provision of personal data

The provision of data for the purposes laid down in Article 2 (A), n. i and ii) is necessary, since any refusal to supply the required personal data would not ensure your registration on the website or the reply to your requests.

The provision of data for the purposes laid down in Article 2 (B) is optional. You may decide to not provide any data or to withdraw the possibility of processing previously provided data. In this case, you will not receive our newsletters anymore, while we will continue to offer you our services and you will retain the right of registration on the website.

 

 

  1. Methods of data processing

The processing of your personal data is carried out by means of the procedures as mentioned in Article 4, n. 2 of the GDPR, namely: the collection, recording, organization, retention, consultation, processing, alteration, selection, extraction, comparison, use, networking, blocking, notification, erasure and destruction of data. The processing of your personal data shall be based on the principles of correctness, lawfulness and transparency and may be carried out electronically to store, manage and transfer them; it will be carried out using instruments which are, mutatis mutandis and according to the state of the art, suitable to guarantee the security and the confidentiality and procedures suitable to prevent the risk of loss, the unauthorized access, the illicit use and the dissemination of data.

 

 

  1. Retention period of data

The Controller will process your personal data as long as to fulfill the purposes mentioned above but not later than 10 years from the termination of the relationship with the service purposes and not later than 2 years from the collection of data with marketing purposes. Upon expiry of this period, data will be erased or made anonymous.

 

 

  1. Data access

The personal data processed by the Controller won’t be disseminated or give access to undetermined people in any form, including their public disclosure or their merely consultation. Your data may, however, be disclosed to the Controller’s employees and to certain external parties working with them. Your data may be made accessible to:

 

  1. the Controller’s employees and associate workers, qualified consultants managing the website and the provision of the related services, in their capacity as internal managers and/or as personal data processors and/or as system administrators;

 

  1. third parties (including but not limited to, credit institutions, professional firms, consultants, insurances companies, etc.) performing outsourcing activities on the Controller’s behalf, in their capacity as external managers and/or as personal data processors.

 

Your data may be made accessible to persons eligible pursuant to any legal provisions, regulations and Community legislations.

 

 

  1. Disclosure of data

Without your express consent (ex Article 24 (a), (b), (d) of the Privacy Code and Article 6 (b), (c) of the GDPR), the Controller may disclose your data with the above-mentioned purposes to supervisory bodies, judicial authorities and to any third-party to which the disclosure of data is mandatory under the law.

 

 

  1. Data processing

The data will be managed and stored on the Controller’s server and/or the third-party companies’ server – involved and duly named as data controllers – which are located within the European Union, in accordance with the Article 45 and followings of the GDPR.

The server is currently located in Codroipo via Gortani 13. Your data won’t be processed outside the European Union. It is understood in any case that, if it shall become necessary to move the location of the server to Italy and/or to the European Union and/or to countries outside the European Union, this shall always take place in accordance with the Article 45 and followings of the GDPR. In such a situation, however, the Controller ensures that the data processing outsite the European Union will take place in accordance with the applicable law, also, if necessary, entering into agreements to guarantee an adequate data protection level and/or adopting the European Commission’s standard contractual clauses.

 

  1. Navigation data

IT systems and software procedures for the functioning of the website shall acquire, during the normal course of operation, some personal data whose transmission is implicit in the communication protocols of Internet. It concerns information that is not collected to be associated with specific individuals, but by their own very nature could, through the processing and association with data held by third parties, allow users to be identified (i.e. other parameters related to the operating system and the user). Those data shall be used by the Controller only in order to draw some anonymous statistical information about the use of the site and also to check their correct use, and they are erased immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Site.

 

  1. Cookies

When using our website, cookies are stored on your computer. Cookies are small text files stored on your computer, which provide us certain information. They are widely used for the functioning or the better functioning of the websites to improve the user experience and to provide certain information to the website owners. Our website uses cookies remaining on your computer with different times. Some expire at the end of each session and some remains longer in such a way that when you come back on our website, you could get a better experience as a user. The web browsers allow you to exercise some control over the cookies through the browser settings. Most web browsers allow you to block all cookies or cookies from certain websites. Browsers could help you to delete cookies when closing themselves. However, you should bear in mind that any opt-out or preferences set up in the website could be lost. We encourage you to consult the technical information of your browser for instructions. If you choose to disable cookies or if you refuse to accept a cookie, certain part of the service may not work properly or may work considerably slower.

 

 

  1. Data subject’s rights

In your capacity as the data subject, you are entitled to exercise the rights granted in Article 7 of the Privacy Code and the Article 15 of the GDPR, namely:

  1. to obtain confirmation of the existence or not of personal data relating to you, although not yet recorded, and the communication of the same in an intelligible form;
  2. to obtain information about: a) the source of the personal data; b) the purposes and methods of the processing of data; c) the method applied in electronical processing of data; d) the identification details of the Controller, the managers and the appointed representative pursuant to the Article 5, n.2 of the Privacy Code and the Article 3, n. 1 of the GDPR; e) to whom the personal data may be communicated or who may access them in their capacity as designated representative in the territory of the Country, managers or agents;

iii. to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

  1. to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning the same, even though they are relevant to the purpose of the collection; b) the processing of your personal data carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys through the use of automated calling systems without human intervention, by electronic mail and/or by traditional marketing means such as telephone and/or paper-based mail. It should be noted that the data subject’s right to object, as explained above in recital b), for direct marketing purposes through automated systems shall extend to the traditional ones and it is still his/her right to object even only in part.

The data subject could therefore decide to receive only traditional communications, only electronical ones, or neither of the two types.

If applicable, you have also the rights according to the Articles 16 – 21 of the GDPR (the rights of reply, to be forgotten, of restriction of processing, to data portability and to object) and the right to lodge a complaint with the Supervisory Authority.

 

 

  1. Procedure for the exercise of any right

You have the right to ask to the Controller to access to your personal data, its rectification and removal, the integration of the complete data and the limitation of the processing; to receive your data in a structured, commonly used and automatic device readable format; to withdraw at any time the given consent to your data processing and to object in part or fully to the use of your data; to lodge a complaint with the Supervisor Authority as well as to exercise your rights pursuant to the applicable law.

You may, at any time, exercise your rights sending:

a registered letter to TWL Systems S.r.l. having its registered office in Udine (UD), Viale Palmanova, 73/R;

or sending an e-mail to giorgio.grifoni@twl-systems.com.

 

  1. Minors

If the data subject is younger than 16 years of age, the data processing is lawful only if and to the extent that the consent is given or authorized by the child’s parent or custodian, for which the identification data and copies of ID documents have been acquired.

 

  1. Controller, data processors and persons in charge of the processing

The data Controller is TWL Systems S.r.l. having its registered office in Udine (UD), Viale Palmanova, 73/R, Tax Code IT02830180309 in the person of Mr. Giorgio Grifoni.

The updated list of data processors and persons in charge of the processing is kept at the Controller’s registered office.

 

  1. DPO – Data Protection Officer (if necessary)

Enter here the DPO’s contacts (if necessary).

 

  1. Changes to the present document

This Privacy Policy may be subject to changes. We encourage you to check this Privacy Policy regularly and to check the latest version.

 

Place and date

 

Controller’s signature

Privacy Preference Center

Necessary

Advertising

Analytics

Other