PRIVACY POLICY
1. Scope of application and sources of processing
In compliance with the obligations deriving from national law (Italian Legislative Decree 30 June 2003 no. 196, Privacy Code, as amended) and Community law (General Data Protection Regulation no. 679/2016, GDPR), the Company Giusto Faravelli S.p.A., a sole shareholder company with registered office in Milan, Via Medardo Rosso 8, tax code and VAT no. 03224410153, in its capacity as Data Controller, hereby informs you of the methods and purposes of the processing of Personal Data collected while browsing on this website. The purpose of this privacy policy is to provide the utmost transparency in relation to the information collected by the website and the methods of its use.
This privacy policy concerns only Personal Data collected while browsing the websites:
• https://www.faravelligroup.com
• https:// www.faravelli.com.cn
This website can generally be used without providing Personal Data which, if requested, will only be processed on the basis of consent expressed by you, the data subject. In any case, in the capacity of manager of these websites, Giusto Faravelli undertakes to protect the Personal Data collected and will ensure that the same are processed confidentially and in compliance with existing rules. However, Giusto Faravelli notes that the transmission of data via the Internet (for example, by email communication) is not always secure, as it is not possible to ensure complete protection against access by third parties.
2. Data processed
2.1. Data collected by applications, used for Website functioning
The applications in charge of
the functioning of the websites listed in point 1. may collect, during
browsing, some data not associated directly with you, the transmission of which
is implicit in the use of internet communication protocols. The data collected may
include, by way of example but without limitation, IP addresses, domain names
and the type of browser of the computers used for the connection, the URI
(Uniform Resource Identifier) addresses of the requested resources, the time of
the request and other parameters concerning the operating system and computer
environment used by you.However, those data do not
allow Giusto Faravelli to ascertain your identity and they are therefore to be
considered anonymous.
2.2.
Data collected by way of Cookies
Part of this website uses
Cookies, which are text files deposited by the Website on your computer to
allow the website itself to analyse the methods of use by users and to exchange
information between the server and those users. No sensitive data are
exchanged via cookies. The cookies created by Giusto
Faravelli and by the companies used by the Controller to manage the services do
not store Personal Data allowing for your identity to be traced and/or known
directly. The cookies used by Giusto Faravelli do not represent a risk to
privacy or to the integrity of the IT systems used by you when accessing the
internet communication network or the Website.
2.3. Data collected via
Google Analytics
Giusto Faravelli uses the
statistical services known as Google Analytics, offered by Google LLC. Google Analytics facilitates
the tracking of accesses to the Website and allows the Website administrators
to generate and view data in aggregated and anonymous form, in order to
understand how the Website is used by visitors and to produce statistics. Google Analytics requires, in
order to function, the presence on the Website pages of a so-called tracking
code. The purpose of this code is to
identify, for the purposes indicated below, the pages visited by you during the
browsing session on the Website. In addition to the pages
visited, the data collected may also include, by way of example but without
limitation, the domain names and type of browser of the computers used to
connect to the Website, the addresses in URI (Uniform Resource Identifier)
notation of the requested resources, the time of the request and parameters
concerning the operating system and the IT environment used by you. However, these data do not allow for your
identity to be known and due to their nature and the methods of their
processing, they are therefore to be considered anonymous
2.4. Data collected by
completing forms for registration to the Newsletter service and sending of
contact emails
You are free to provide the
personal data requested in the registration forms for the services (to send
contact emails, information requests, to register to the newsletter). In particular, the optional,
explicit and voluntary transmission of Personal Data by completing the specific
Forms or by email to the contact addresses indicated on the website involves
the acquisition by Giusto Faravelli of data provided by you, including your
email address, required to respond to requests. For the purposes of
registration to the Newsletter, the following Personal Data are requested and
therefore processed by Giusto Faravelli:
- Name;
- Surname;
- Company name;
- Home nation;
- E-mail;
- Sectors of interest.
All of the aforementioned data are required for registration to our Newsletter,
but only some of them are marked as mandatory and are therefore considered
necessary to provide the requested service. If the mandatory Data are not
provided, the requested service may not be provided and the related
opportunities may not be used.
2.5. Data collected with the
use of “plugin” services
Facebook Plugins (Like button): The pages include the plugins of the Facebook social network, provider Facebook Inc, 1 Hacker Way, Menlo Park, California 94025, USA. Facebook plugins can be recognised by way of the Facebook logo or the “Like” button on our page. An overview of the Facebook plugins can be found here: https://developers.facebook.com/docs/plugins/. The plugin establishes a direct connection between your browser and the Facebook server when browsing on the Giusto Faravelli Website. Facebook receives information regarding consultation of our website with your IP address. If you select the Facebook “Like” button when connected to your Facebook account, you can link the contents of the Website pages to your Facebook profile. This allows Facebook to associate the visit to the pages with your account. As provider of the pages, we do not have any knowledge of the content of the data sent or their use by Facebook. For further information, consult the Facebook privacy policy at the address https://de-de.facebook.com/policy.php. If you do not want Facebook to associate your visit to our pages with your Facebook account, please disconnect from your Facebook account.
Twitter plugins: Our pages include functions of
the Twitter service. These functions are provided by Twitter Inc, 1355 Market
Street, Suite 900, San Francisco, CA 94103, USA. Using Twitter and the
"Re-Tweet" function, the Websites visited by you are connected to
your Twitter account and made known to other users. The data are also sent to
Twitter. In the capacity of provider of the pages, we are not aware of the
content of the data sent or how it is used by Twitter. For further information, consult the
Twitter privacy policy at the address https://twitter.com/privacy. The Twitter privacy settings can be modified in the account settings
at the address: https://twitter.com/account/settings.
Google Maps Plugins: Our pages use the Google Maps functions. The provider is Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. The Google Maps API is used for the visual display of geographically information. When Google Maps is used, Google collects, processes and uses the data relating to use of the Maps functions by Website visitors. Further information on the processing of data by Google is available in Google’s privacy policy.
Instagram plugins: Our pages include functions of the Instagram service. These functions are provided by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are connected to your Instagram account, you can connect the contents of our pages to your Instagram profile by clicking on the Instagram icon. This allows Instagram to associate the visit to our pages with your account. In the capacity of provider of these pages, we are not aware of the content of the data sent or of how it is used by Instagram. For further information, consult the Instagram privacy policy: https://instagram.com/about/legal/privacy/
LinkedIn Plugins: Our website uses the functions of the LinkedIn network. The provider of the service is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Every time one of our pages which contains LinkedIn functions is visited, a connection is established to the LinkedIn servers. LinkedIn is informed that you have visited our Website. If you select the LinkedIn "Recommend" icon while you are connected to your LinkedIn account, LinkedIn is able to associate the visit to our Website with you and your account. As providers of the page, we do not know the content of the data sent and their use by LinkedIn. For further information, consult the LinkedIn privacy policy at the address: https://www.linkedin.com/legal/privacy-policy
XING Plugins: Our website uses the functions of the XING network. The provider is XING AG, Dammtorstraße 29-32 20354 Hamburg, Germany. Every time you access one of our pages that contains XING functions, a connection is established to the XING server. To our knowledge, the personal data will not be archived. In particular, no IP addresses are stored or usage behaviour assessed. Further information on data protection and the XING Share button is available in the XING data protection statement at the address: https://www.xing.com/app/share?op=data_protection.
YouTube Plugin: Our Website uses plugins from Google’s YouTube website. This Website is managed by YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. If you visit one of our pages that has YouTube plugins, a connection is established with the YouTube servers. The YouTube server will be informed of which of our pages have been visited. If you access your YouTube account, YouTube may associate your browsing behaviour directly with your personal profile. You can avoid the association of data by disconnecting from your YouTube account while browsing on our website. Further information on how your data are managed is available in the YouTube privacy policy at the address: https://www.google.de/intl/de/policies/privacy.
3.
Purpose and legal basis of processing
3.1.
Purpose of processing of data collected by way of the website applications, by
cookies and by the service offered by Google Analytics
Data collected by the Website are used for statistical purposes, to
guarantee service continuity and to improve the internet website. Cookies allow some operations to be automated so that you can avoid some
complex procedures; they are sometimes essential for the correct functioning of
the Website. The data collected by Google Analytics are processed for the purpose of
tracking and examining use of the Website, compiling reports on the activities
of the same, which can be read by authorised operators, and providing other
services relating to the Website activities and use of the Internet.
The legal basis of the processing is the legitimate interest of the
Controller in the correct management of its internet website and the
customisation of the website to improve your browsing experience and to analyse
the effectiveness of the website, analysing the number of users and the
consulted areas.
The website uses technical and third party cookies. It does not use
first party profiling cookies.
The Website, in particular, uses technologies such as cookies to
customise the contents and to analyse traffic to the website. Information on
your use of the website is shared with our partners, which operate in the
sector of social media and statistical data.
On this website, cookies are used to:
• remember your preferences, also in relation to your consent to the use
of cookies;
• collect anonymous information on the pages visited and on how the visitor
reached the website, with the aim of obtaining useful information to improve
the organisation and presentation of the website contents (the "Google
Analytics" service is used for this purpose);
• offer third party services such as, by way of example:
o The simplified sharing of our contents on your social networks (e.g.
the buttons "Like” and "Share" of the Social Network)
o The interactive geographical and road maps (e.g. Google Maps).
The statistical service known as Google Analytics allows for accesses to the
Website to be tracked and for the Website administrators to generate and view
data in aggregated and anonymous form in order to understand how the Website is
used by visitors and to process statistics.
The Cookies used by the website and by Google Analytics do not, in any
case, allow the identity of visitors to be tracked, and they do not allow the
cross-referencing of the information collected with other information that is
already known.
Google guarantees that it does not associate the IP address of the Website
visitors with any other data relating to users that may be held by it, except
where the users themselves use other services offered by Google which involve
that association and for which the same have accepted the respective privacy
rules prepared by Google itself.
In any case, the aforementioned association has been prohibited by the Controller, which has expressly established its settings within the Google Analytics account by anonymising the IPs and deactivating the authorisations relating to “Google Products and Services”, “Benchmarking”, “Technical Support” and “Account Expert”.
3.2. Data collected by
completing forms for registration to the Newsletter Service and sending of
contact emails
If you provide data directly by completing the specific forms on the
Website (registration to the newsletter) the processing is carried out by
Giusto Faravelli based upon your free and informed consent, expressed
specifically and documented in the form envisaged by law.
In particular, personal data provided by you for the purposes of
insertion into the newsletter list are processed, only subject to your specific
and separate consent, exclusively to allow the Controller to send, to the email
address communicated, the newsletter about the activities, products or services
offered by Giusto Faravelli.
The data collected when you send contact emails will be processed in
order to respond to you and to provide the requested services to you. To offer
the requested services, obviously, your fax and telephone numbers may also be
used, in addition to your email address, if freely provided by you. It is
therefore clear that if those data are not provided, the services requiring use
of those data may not be provided.
4. Methods and duration of processing
4.1 Data collected through website applications, cookies and services
offered by Google Analytics
The data collected through
website applications are processed using automated tools, in anonymous and
aggregated form, for the purposes illustrated above and they will be processed
exclusively for the time strictly necessary to pursue the above purposes.
The processing of data
collected by Google LLC is managed by way of IT and electronic tools with
logics closely related to the purposes highlighted below and, in any case, so
as to guarantee the security and confidentiality of the data.
In order to function, Google
Analytics uses cookies; the information on use of the Website generated by them
are sent to Google and deposited on its servers in the United States.
In relation to the purposes
described above, the data are, therefore, aggregated with other data collected
relating to other Website visitors. Their processing does not allow for your
identity to be known or your identity to be traced in any way.
In any case, Google guarantees
that it does not associate the IP address of the Website visitors with any
other data relating to users that may be held by it, except where the users
themselves use other services offered by Google which involve that association
and for which the same have accepted the respective privacy rules prepared by
Google itself. In any case, the aforementioned association and use of the above
services are not considered to be connected to use or browsing of this Website,
given that the Controller and its officers do not have direct or indirect
access to the data collected and/or processed by Google while users are
browsing on other websites.
In that regard, you are invited to read the Google Analytics Privacy Policy
found at the link www.google.com/intl/it_it/analytics/learn/privacy.html.
4.2.
Data collected by completing forms for registration to the Newsletter service
and sending of contact email
The processing of personal
data provided by completing forms for registration to the newsletter and to
manage responses to contact emails is carried out through their collection,
recording, organisation, storage, consultation, use, erasure and destruction
using IT tools, with logics closely related to the purposes highlighted above
and, in any case, so as to guarantee the security and confidentiality of those
data. To provide and manage the Newsletter, Giusto Faravelli uses the
SendBlaster service offered by the Company eDisplay S.r.l. based in Milan, Via
Palmanova 24. The data collected for that purpose are stored on secure servers
of SendBlaster, which processes them on behalf of Giusto Faravelli in the
capacity of Processor, as well as on the servers of Giusto Faravelli. In
accordance with the SendBlaster privacy policy, data collected through the
Giusto Faravelli website will never be used directly by SendBlaster, or sold by
it to third parties. SendBlaster uses appropriately authorised operators to
maintain the service and, in the exercise of that function, those operators may
have access to your data.
The data provided for registration to the
newsletter service are processed by the Controller until otherwise notified by
you. If consent to processing is withdrawn, the data will be immediately erased
from all servers and applications on which they were recorded and archived and
will no longer be stored.
5. Nature of provision of data and consequences of lack of provision
5.1. Data collected through website applications, cookies and the service offered by Google Analytics
The collection by the Website
of the data described above is necessary in order to allow you to browse on the
website. According to the regulations in force, this website is not required to
request consent for technical cookies and anonymised Google Analytics cookies,
as they are necessary to provide the requested services. For all types of
cookie, you may deny consent by one or more of the following methods:
• By modifying the
configuration of the browser used to access the Website pages. (Whereby
"browser" means any software used to access the Website pages.)
• By modifying the settings used for third
party services.
Both these solutions may
prevent you from using or viewing parts of the Website. Below are links to the
instructions for managing cookies for the most popular browsers:
• Chrome
• Mozilla Firefox
• Internet Explorer
•Safari
• Safari iOS (mobile device)
•Opera
• Xoom (Android and Motorola smartphone)
If your browser does not appear in the list or if the link is temporarily
inaccessible, please refer to the specific guide incorporated therein or
provided by the respective provider. Below is a list of links for managing
preferences or cookie policies for the most popular services of the Website
(our Partners whose third party cookies we install):
• Google Analytics
•Facebook
• Twitter
You cannot, on the other hand,
refuse the collection of other data by the Google Analytics software. If you do
not agree, in whole or in part, with its presence on the Website pages, you are
invited to leave the website, immediately ceasing your browsing. For the
purposes of browsing on the website, the communication of personal data is not
required, except for the anonymous data described above which are strictly
necessary for the above purposes.
5.2.
Data collected by completing forms for registration to the Newsletter service
and sending of contact emails
The
compilation of the forms involves the communication to Giusto Faravelli of
Personal Data additional to the anonymous data required for simple browsing.
Those data are used for the sole purpose of providing any requested services
and they will be processed according to the specific policies prepared for that
purpose and cited in the specific sections. The provision of data is optional.
You may therefore decide not to provide any data or subsequently deny the
possibility of processing data already provided: in that case, you may not
receive the Services offered by the Controller.
6.
Access to data
The Data collected by the
Website can only be accessed directly by the Controller.
The provider of the Hosting service is the company Boken s.r.l which may potentially
have access to the Data, exclusively for technical reasons of need and urgency
that require an intervention so as not to affect the Website functionalities
and security.
The Personal Data collected through Google Analytics are transferred to the
servers of Google LLC and processed there. Google may also transfer this
information to third parties where required by law or where those third parties
process the aforementioned information on behalf of Google. We note that the
Website administrators or the Controller of data on the same cannot in any way,
directly or indirectly, connect the data collected with your identity.
The data provided by completing the forms contained on the Website are made
accessible to employees ad collaborators of the Controller, in their capacity
as internal processing officers and/or external processors or system
administrators. In particular, the data provided for registration to the
newsletter service are also accessible to the company SendBlaster which offers
to the Controller the newsletter management service, and which manages the data
on behalf of the Controller, in its capacity as external processor.
7.
Communication of data without the need for express consent (pursuant to Art. 6
letter b) and c) GDPR)
The Controller may communicate
the data collected for the purposes illustrated above to judicial authorities,
as well as to those entities to which the communication is mandatory by law for
the conduct of those purposes. Those entities will process the data in their
capacity of autonomous processing controllers.
8.
Dissemination of data
The data indicated in point 1
and collected for the purposes indicated in point 2 will not be disseminated.
9. Data transfer
Personal data collected by way
of the Website are stored on servers located in the European Union. However,
the Controller, where necessary, will have the right to move the servers even
outside the EU. In that case, the Controller hereby guarantees that the
transfer of data outside the EU will occur in conformity with applicable
provisions of law, subject to signing the standard contractual clauses
envisaged by the European Commission. Personal data collected via Google
Analytics are transferred to the Google LLC servers and processed there.
10. Rights of the data subject
In relation to the processing
purposes, you are granted the exercise of the rights envisaged by Articles 15
et seq. of the GDPR, and in particular the right to:
• access, or obtain
confirmation of the existence or otherwise of personal data relating to you, to
know of its origin, as well as the logic and purposes on which the processing
is based, the recipients or categories of recipients to which the data may be
communicated, the determination of the storage period, if it can be defined;
• rectify inaccurate data;
• erasure (known as right to
be forgotten), if the data are no longer necessary for the processing purposes,
or if you have withdrawn consent to processing (if that consent is optional or
there is no other legal basis for processing);
• restriction, the right to
obtain from the Controller the restriction of access to your personal data by
all entities that have a service contract or an employment contract with the
Controller;
• portability, the right to
receive in a structured, commonly-used and machine readable format the personal
data relating to you, with the possibility of sending them to another
Controller. That right does not apply to non-automated processing (for example,
archives or paper records); in addition, only data processed with your consent
are subject to portability and only if the data have been provided by you
personally;
• object, namely the right to
object to the processing for reasons connected to your particular situation;
• lodge a complaint with the
Data Protection Supervisory Authority.
In addition, in accordance with Art. 7, paragraph 3 of the GDPR, you are
granted the right to withdraw consent at any time; the withdrawal of consent
does not prejudice the lawfulness of processing based upon consent prior to the
withdrawal.
11. Methods of exercising rights
You may, at any time, exercise
your rights, indicated in the point above, by sending:
- a recorded delivery letter with notice of receipt to Giusto Faravelli S.p.A.
Sole Shareholder Company, Via Medardo Rosso 8, 20159 Milan
- an email to the address privacy@faravelli.it
12. Controller, processors and officers
The Data Controller is Giusto
Faravelli S.p.A., a Sole Shareholder Company with registered office in Milan,
Via Medardo Rosso 8.
The updated list of processors
and officers is kept at the Data Controller’s registered office.