Privacy Policy – Gruppo Fabbri Vignola S.p.A.
According to Regulation (EU) 2016/679
Dear User,
Gruppo Fabbri Vignola S.p.A. with registered offices in Vignola (MO), Via Per Sassuolo n. 1933, VAT No. 07222950961, as Data Controller (hereinafter: „Gruppo Fabbri Vignola“ or the „Data Controller“) considers privacy and the data protection one of its main goals. This document has been drafted pursuant to art. 13 of EU Regulation 2016/679 (hereinafter: „Regulation“ or „GDPR“) in order to allow you to know about our policy concerning privacy. We therefore invite you to read this Privacy Policy carefully before communicating any personal data to the Controller, as it contains important information on the protection of your personal data. This Privacy Policy is intended for the www.gruppofabbri.com website (hereinafter also only the „Website“) and is an integral part of the services offered through the Website. Please note that this Privacy Policy does not apply to the processing of personal data carried out through email addresses linked to third parties (i.e., companies belonging to the Gruppo Fabbri network) and published on the Website. For data processing carried out through these contact channels, we invite you to check the privacy policies of such third parties.
The processing of your personal data will be based on the principles of fairness, lawfulness, transparency, purpose and storage limitation, data minimization and accuracy, integrity and confidentiality, as well as the principle of accountability referred to in Article 5 of the Regulation. Your personal data will therefore be processed in accordance with the legal provisions of the Regulation and the confidentiality obligations provided therein.
By processing of personal data, we mean any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form of making available, comparison or interconnection, limitation, deletion or destruction.
INDEX
1. Data controller
2. Personal Data we process
a. Browsing data
b. Data provided voluntarily by the user and third-party data
c. Reserved Area for Customers
d. Reserved Area for Service Centers
e. Spare parts purchasing
f. Cookies
3. Purpose of processing
4. Legal basis and mandatory or optional nature of the provision of data
5. Recipients of Personal Data
6. International transfers of Personal Data
7. Storage of Personal Data
8. Exercising data protection rights
9. Changes to this privacy policy
10. Contact information
1. Data controller
The “Data Controller” for the processing of your personal data is Gruppo Fabbri Vignola S.p.A. as defined above.
2. Personal Data we process
After you browse the Website, Gruppo Fabbri Vignola will process certain personal data belonging to you, which may consist of an identifier such as a name, identification number, on-line identifier or one or more characteristic elements of your physical, physiological, psychological, economic, cultural or social identity, which make it possible to identify you as the Data Subject (hereinafter, simply the “Personal Data”). The Personal Data we process are the following:
a. Browsing data
In their normal operation, the computer systems and software procedures used to operate the Website acquire certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information not collected for association with identified data subjects, but information which, by its very nature could, through processing and association with data held by third parties, permit the identification of users. This category of data includes IP addresses or domain names of the computers used by users connecting to the Website, the URI (Uniform Resource Identifier) addresses 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 (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment. This data is used in the form of server side “logs” for the sole purpose of obtaining information on the use of the Website and to check its correct operation, to permit – given the architecture of the systems used – the correct provision of services, security and to ascertain liability in the event of possible cyber-crime against the Website or third parties; this data is processed in accordance with the GDPR and kept for the time strictly necessary to achieve the aforementioned purpose. Such personal data is stored for fifteen (15) days.
b. Data provided voluntarily by the user and third-party data
The Website allows users to provide personal information voluntarily, for example, through registration on the Website contact forms, requests for services or information, and the facultative, explicit and voluntary transmission of e-mails to the addresses listed on the Website, etc. This Privacy Policy therefore applies to the processing of any Personal Data voluntarily provided through the Website. This category also includes Personal Data disclosed to the Data Controller in the context of the use of social networks and interaction with the Fabbri Vignola Group, such as in the case of LinkedIn.
Should you provide third-party data in the use of these areas of the Website – for example, by filling in the „reason of your request“ field in the contact form on the Website -, you act as an independent data controller, and therefore assume all relevant legal obligations and responsibilities. As such, you will be required to fully indemnify Gruppo Fabbri Vignola against any complaint, claim or demand for compensation for damages caused to any third party whose Personal Data has been processed through your use of the Website in violation of applicable data protection regulations. In any case, should you provide or otherwise process third party Personal Data in your use of the Website, you must guarantee – assuming all related responsibilities – that such processing has a suitable legal basis under art. 6 of the Regulation on the lawfulness of Processing.
c. Reserved Area for Customers
Your e-mail address, password and an identification code will be collected in the “Reserved Area for Customers” of the Website in order to allow you to register in Gruppo Fabbri Vignola’s customer area and provide you with access credentials which you must change at the first login.
After logging into this area of the Website, you will be able to consult a section dedicated to technical and information sheets of the products purchased from Gruppo Fabbri Vignola.
d. Reserved Area for Service Centers
If you are a Gruppo Fabbri Vignola employee or a collaborator of a service center (hereinafter „SC“) you will be provided with credentials to access your personal area. You must change your password the first time you log in to the Website.
If you have received credentials to access this area as a collaborator of a SC, after authentication, you will be able to access your personal area to manage the activities performed during a service intervention on behalf of Gruppo Fabbri Vignola, as well as all service orders, shipments, scheduled maintenance activities, the order book, and in general, all interventions on the Data Controller’s clients that are entrusted to you.
e. Spare parts purchasing
If you are a customer of Gruppo Fabbri Vignola, you will be provided with credentials to access the “Spare parts purchasing” section of the Website. You must change your password the first time you log in to the Website. By logging in this area of the Website, you will display the spare parts catalog and the prices reserved for you; you will also be able to purchase products that you are interested in.
Please note that it is not possible to make online payments through this section of the Website: you will only be able to generate a product order. You will then receive of a communication from Gruppo Fabbri Vignola containing all the necessary information to finalize your order, including information on payment methods.
f. Cookies
Definitions, characteristics and application of the legislation
Cookies are text files containing minimal information that are sent to your browser and stored on your computer, cell phone or other device every time you visit a website. At each link, the cookie sends the information back to the referring site.
Through the use of cookies, Websites remember your actions and preferences (such as, for example, login data, the chosen language, font size, other display settings, etc.) to avoid having to enter them again when you return to the Website or browse its pages. Cookies are mainly used for authentication purposes, session monitoring and to save information on the activities of users and may also contain a unique identification code that tracks the activities of users while browsing the Website itself, for statistical or advertising purposes. While browsing a website, you may also receive cookies from websites or web servers different to the one you are currently browsing (known as “third-party” cookies). Some operations would be impossible without the use of cookies, which in certain cases are technically necessary for the Website to operate.
There are various types of cookies with different characteristics and functions, which can remain on your computer for different periods of time: session cookies, for example, are automatically deleted when the browser is closed; persistent cookies, on the other hand, remain on your device for a predetermined length of time.
According to current legislation, the use of cookies does not always require your consent. In particular, “technical cookies”, cookies used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user (for example, for authentication, language preferences), do not require this consent. In short, these cookies are either essential for the operation of the Website, or necessary for the activities requested by the user.
The technical cookies do not require express consent of the user to be installed.
On the other hand, “profiling cookies”, meaning cookies that are used to create user profiles and send advertising messages corresponding to the preferences expressed by the users while browsing the internet, require the prior consent of users.
Types of cookies used by the Website and the possibility to enable/disable them
Except for third-party cookies, for which you should refer directly to the corresponding disable/enable procedures indicated in the links below, the Website uses the following cookies, which can be disabled:
- Technical browsing or session cookies are strictly necessary for the operation of the Website or to permit use of the requested content and services;
- Technical analytics cookies are used to analyze the Website usage of users. These cookies do not collect information on the user’s identity or any personal data. The information is processed in aggregate and anonymous form.
- Functionality cookies are used to enable specific functions of the Website and a series of selected criteria (for example, the language) to improve the service.
Gruppo Fabbri Vignola uses third-party cookies, meaning cookies from websites or web servers other than Gruppo Fabbri Vignola’s Website for the purposes of such third parties. Please note that these third parties, listed below with links to their privacy policies, are typically independent data controllers for all data collected through the cookies they serve, or act as data processors for Gruppo Fabbri Vignola (in other words, they process Personal Data on behalf of Gruppo Fabbri Vignola).
The Cookies sent by Gruppo Fabbri Vignola through the Website are listed in the Cookie Policy.
How to display and manage cookies
You can select which cookies you wish to enable through the cookie control panel, as well as enable, block or delete cookies (entirely or in part) using the specific functions of your browser: however, if you disable technical and/or functional cookies, the Website may not be available, or some of its services or functions may not work properly, and you will have to modify or enter certain information or preferences manually each time you visit the Website. You can obtain more information on how to set your cookie preferences on your browser through the following links:
You can also use the AdChoices tool provided by the Digital Advertising Alliance or the YourOnlineChoice tool provided by European Interactive Digital Advertising Alliance.
3. Purpose of processing
Your Personal Data will be processed by Gruppo Fabbri Vignola for the following purposes:
- to permit provision of the requested services (for example, to respond to a request for contact, information, request assistance, including customer assistance services, also submitted through the Website contact forms, the Reserved Area for Customers or the Spare parts purchasing section etc.), and permit browsing of the Website (“Provision of Services”);
- to conduct marketing activities, such as surveys and market research, and send information and promotional material on the activities, products and services of Gruppo Fabbri Vignola. If you consent to receiving information on promotional activities, including market research, we inform you that these activities may be conducted, as required by current regulations, by mail, phone (“traditional methods”), as well as e-mail, SMS-type messages and via social networks (“automated methods”). We likewise inform you that you can revoke your previously given consent by traditional or automated methods at any time, by writing informally to the Data Controller at privacy@gruppofabbri.com, or through the link at the bottom of our commercial e-mails, without prejudice to the lawfulness of processing carried out prior to revocation of your consent („Marketing„);
- to send commercial communications and conduct direct marketing campaigns via e-mail for similar products and services to the ones you purchase, unless you explicitly refuse to receive such communications when requesting a service or purchasing a product, or at a later date by writing to privacy@gruppofabbri.com (“Soft-spam”);
- to fullfil any obligations under applicable laws, regulations or community legislation, or comply with requests by authorities (“Compliance”);
- to communicate your Personal Data to our branch-office or network company located in the Country of your choice („Communication„).
- to interact with you through social networks (e.g. LinkedIn), by engaging with posts and/or comments that mention the Fabbri Vignola Group (“Social Interaction”).“
4. Legal basis and mandatory or optional nature of the provision of data
Gruppo Fabbri Vignola applies the following lawful bases for processing your Personal Data for the purposes indicated in Section Purpose of processing above:
– Provision of Services: The lawful basis of this processing activities is art. 6(1)(b) of the Regulation (“[…] processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”). You can choose not to provide your Personal Data for this purpose, but if you do not complete the fields marked with an asterisk (*) it will not be possible to provide the Services through the Website or respond to your requests;
– Marketing: processing for Marketing purposes is based on your specific consent in accordance with art. 6(1)(a) of the Regulation (“[…] the data subject has given consent to the processing of his or her personal data for one or more specific purposes”).
The provision of your Personal Data for this purpose is therefore entirely optional and does not affect use of the Services. Note also that if you have otherwise provided or denied Gruppo Fabbri Vignola such consent, the chronologically most recent action will be taken as the reference. If you wish to withdraw your consent, you can do so at any time by writing to privacy@gruppofabbri.com;
– Soft-spam: the current personal data protection legislation permits to Gruppo Fabbri Vignola to process your data for this purpose without your explicit consent. You can oppose the processing of your Personal Data for this purpose when requesting products and services, or later by writing to the Data Controller at privacy@gruppofabbri.com;
– Compliance: the processing of your Personal Data for this purpose is based on art. 6(1)I of the Regulation (“[…] processing is necessary for compliance with a legal obligation to which the controller is subject”);
– Communication: the processing of your Personal Data is based on art. 6(1)(b) of the Regulation, i.e. the execution of a contractual obligation or pre-contractual measures taken at your request. Gruppo Fabbri Vignola will connect you with its branch-offices or network companies located in the Country of your choice. The provision of your Personal Data for this purpose is optional; however, the failure to provide it would make it impossible for Gruppo Fabbri Vignola to get you in touch with the company that can best meet your needs as it is located in the Country you indicated.
– Social Interaction: the processing of your Personal Data is based on Article 6(1)(f) of the Regulation (“the processing is necessary for the pursuit of the legitimate interest of the data controller or a third party, provided that the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, do not override it”), that is, on the legitimate interest of the Fabbri Vignola Group in managing its image and brand on social networks and, more generally, on the internet.
5. Recipients of Personal Data
For the purposes defined in the Purpose of processing Section above, your Personal Data may be shared with:
a. Persons authorized by us, such as Gruppo Fabbri Vignola employees, for conducting activities strictly related to the provision of the services, who adhere to adequate confidentiality and non-disclosure agreements.
b. Subjects who typically act as data processors, namely: i) people, companies or professional firms that provide administrative and legal services and assistance to Gruppo Fabbri Vignola on the provision of services; ii) subjects with whom it is necessary to interact for the provision of services (for example hosting providers) or; iii) subjects delegated to carry out technical maintenance activities (including maintenance on network equipment and electronic communications networks).
c. Law enforcement agencies, bodies or other authorities to whom your Personal Data must be sent by law, court order or other provisions of the authorities, or if necessary for defence in legal proceedings.
d. Companies belonging to Gruppo Fabbri Vignola, strictly for administrative-contractual purposes connected with activities of an organizational, administrative, financial and accounting nature.
e. branch-offices or other companies in the network of Gruppo Fabbri Vignola, with reference to the purpose of Communication described in paragraph 3.e above.
6. International transfers of Personal Data
Your Personal Data may be shared with recipients who could be located outside the European Economic Area. Gruppo Fabbri Vignola ensures that the processing of your Personal Data by said recipients is conducted in compliance with the Regulation and other applicable laws. Such transfers may be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another suitable legal basis. You can get more information from the Data Controller by writing to the addresses indicated in the “Contacts” section of this Privacy Policy.
7. Storage of Personal Data
Personal Data processed for the provision of services as described in the Purpose of processing and Communication Sections of the Privacy Policy will be kept for the time strictly necessary to achieve that purpose. In any case, given that such processing is conducted for the provision of services, the data controller will process and store your Personal Data for the period allowed by applicable law for the protection of its interests.
For the storage period applied to the Cookie processed through the Website see the Cookie Policy.
Personal Data processed for Marketing purposes will be processed until you withdraw your specific consents.
Personal Data processed for the Soft-spam purposes will be processed until you oppose such processing.
Personal Data processed for Compliance purposes will be kept for the period required by the specific obligation or applicable law.
Personal Data processed for the purposes of Social Interaction will be processed only for the time necessary to pursue the aforementioned purpose, without the need for further retention.
More information on Personal Data storage times and the criteria applied to determine this period can be obtained by writing to: privacy@gruppofabbri.com.
8. Exercising data protection rights
In accordance with article 15 and the following of the Regulation, you have the right to ask Gruppo Fabbri Vignola, at any time, for access to your Personal Data, to rectify or delete your data or to object to their processing pursuant to art. 21 of the Regulation. You also have the right to request the restriction of the processing of your Personal Data in the cases provided for by art. 18 of the Regulation, as well as to receive your Personal Data in a structured, commonly used and machine-readable format in the cases provided for by art. 20 of the Regulation.
Any requests to exercise your data subject rights can be directed in writing to privacy@gruppofabbri.com.
In all cases, users can always lodge a complaint with the competent Data Protection Supervisory Authority (Garante per la Protezione dei Dati Personali), pursuant to art. 77 of the Regulation, if you consider the processing of your Personal Data to be in violation of the legislation in force.
9. Changes to this privacy policy
The Data Controller may modify or simply update this Privacy Policy, in part or in full, also due to changes in the laws and regulations that govern this subject and protect your rights. These changes and updates to the Privacy Policy will be notified to users on the home page of the Website. We therefore invite you to regularly visit this section to be aware of the most recent and updated version of this Privacy Policy so that you are always up to date on the information we collect and how we use it.
10. Contact information
To exercise your rights as data subject or for any other request, you can write to the registered offices of the Data Controller: Gruppo Fabbri Vignola S.p.A., at Via Per Sassuolo 1933, Vignola (MO), Italy, or e-mail to: privacy@gruppofabbri.com.
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