PRIVACY POLICY

 

Privacy Policy

The use of the Internet pages of VIBAC S.p.A. is possible without any indication of personal data; however, if a Data Subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the Data Subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a Data Subject shall always be in line with the country-specific data protection regulations applicable to VIBAC S.p.A. and the General Data Protection Regulation (GDPR) by means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, Data Subjects are informed, by means of this data protection declaration, of the rights to which they are entitled. VIBAC S.p.A. has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website.

 

OUR DETAILS

This Privacy Policy (“Policy”) describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information. By visiting the Site, or using the Service, you consent to the privacy practices described in this Policy.

We may change this Policy from time to time so please check this page occasionally to ensure that you are happy with any changes.

              You can contact us:

(a)         by post, to VIBAC S.p.A. Strada Ticineto – Salita S. Salvatore - 15040 Ticineto (AL);

(b)         using our website contact form;

(c)          by telephone, on +39 0142 413200 or

(d)         by email, using the email address  privacy@vibac.it

 

DATA CONTROLLER

The Controller for the purposes of the General Data Protection Regulation (GDPR) and other data protection laws applicable in the Member states of the European Union is VIBAC S.p.A. Strada Ticineto – Salita S. Salvatore - 15040 Ticineto (AL)- privacy@vibac.it.

 

DATA PROCESSOR

Our Data Processor contact details are: VIBAC S.p.A. Strada Ticineto – Salita S. Salvatore  - 15040 Ticineto (AL)- privacy@vibac.it

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DEFINITIONS

The data protection declaration of VIBAC S.p.A. is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

·       Personal data

Personal data means any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

·       Data Subject

Data Subject is any identified or identifiable natural person, whose personal data is processed by the Controller.

·       Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

·       Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

·       Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

·       Controller or Controller responsible for the processing

Controller or Controller responsible is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

·       Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

·       Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

·       Third party

Third party is a natural or legal person, public authority, agency or body other than the Data Subject, Controller, processor and persons who, under the direct authority of the Controller or processor, are authorized to process personal data.

·       Consent

Consent of the Data Subject is any freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

 

HOW WE USE YOUR PERSONAL DATA

We may process the following categories of personal data:

  • usage data (data about your use of our website and services) including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use for the purposes of analyzing the use of the website and services. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website and business.
  • account data for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent, performance of our contractual obligations and our legitimate interests, namely the proper administration of our website and business.
  • profile data (your information included in your personal profile on our website). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.
  • enquiry data (information contained in any enquiry you submit to us regarding goods and/or services). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is performance of our contractual obligations and consent.
  • notification data (information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
  • correspondence data (information contained in or relating to any communication that you send to us). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

The GDPR provides derogations from the general prohibition on transfers of personal data outside the EU for certain specific situations. A transfer, or set of transfers, may be made where (i) the transfer is made with the individual’s informed consent; (ii) is necessary for the performance of a contract between the individual and the organization or for pre-contractual steps taken at the individual’s request; (iii) is necessary for the performance of a contract made in the interests of the individual between the Controller and another person;

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

We and our other group companies have offices and facilities in Canada and Serbia. [Your consent to personal data will comprehend the consent to the transfer of data to Canada and/or Serbia. Please also be aware that transfer of personal data to Canada and/or Serbia may be necessary for the performance of contracts.[1] ]

 

RETAINING AND DELETING PERSONAL DATA

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain the personal data collected from a data subject for as long as the use's account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. Personal data used for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information.

Notwithstanding the provisions set out above, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject.

 

YOUR RIGHTS

You may exercise any of your rights in relation to your personal data by written notice to us or by email to be sent to the physical or e-mail addresses set out above as the case may be.

Your principal rights under data protection law are:

(a) the right of confirmation and the right to access. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Provided that the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. More precisely, the European directives and regulations grant the Data Subject access to the following information:

·     the purposes of the processing;

·     the categories of personal data concerned;

·     the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

·     where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

·     the existence of the right to request from the Controller rectification or erasure of personal data, or restriction of processing of personal data concerning the Data Subject, or to object to such processing;

·     the existence of the right to lodge a complaint with a supervisory authority;

·     where the personal data are not collected from the Data Subject, any available information as to their source;

·     the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the Data Subject;

·     Furthermore, the Data Subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the Data Subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

 (b) the right to rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have completed any incomplete any of your personal data.

(c) the right to erasure (Right to be forgotten). Each Data Subject shall have the right granted by the European legislator to obtain from the Controller the erasure of personal data concerning him without undue delay, and the Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

·    The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

·    The Data Subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

·    The Data Subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the Data Subject objects to the processing pursuant to Article 21(2) of the GDPR.

·    The personal data have been unlawfully processed.

·    The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject.

·    The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

Where the Controller has made personal data public and is obliged pursuant to Article 17(1) of the GDPR to erase the personal data, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the Data Subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.

(d) the right to restrict processing. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; the Data Subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the Controller override those of the Data Subject. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public. If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by VIBAC S.p.A., he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of VIBAC S.p.A. or another employee will arrange the restriction of the processing interest.

(e) the right to object to processing. Each Data Subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. The Controller shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the Data Subject, or for the establishment, exercise or defense of legal claims. If the Controller processes personal data for direct marketing purposes, the Data Subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the Data Subject objects to the Controller to the processing for direct marketing purposes, it will no longer process the personal data for these purposes. In addition, the Data Subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by VIBAC S.p.A. for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the Data Subject may directly contact our Data Protection Officer. (f) the right to data portability; Each Data Subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a Controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another Controller without hindrance from the Controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller. Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the Data Subject shall have the right to have personal data transmitted directly from one Controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by VIBAC S.p.A. or another employee.

(g) the right to complain to a supervisory authority; If you think that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

(h) the right to withdraw data protection consent. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

 

COOKIE POLICY

The Internet pages of VIBAC S.p.A. use cookies.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Through the use of cookies, VIBAC S.p.A. can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system.

The Data Subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the Data Subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

We use the most important tools for Analytics to analyze the use of our website. They gather information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. We also use Google Maps to implement the contents of our web site. This service uses cookies. You can view the privacy policy of this service provider at [https://www.google.com/policies/privacy/ ].

 

COLLECTION OF GENERAL DATA AND INFORMATION

The website of VIBAC S.p.A. collects a series of general data and information when a Data Subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, the Controller does not draw any conclusions about the Data Subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Controller analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a Data Subject.

 

REGISTRATION ON OUR WEBSITE

The Data Subject has the possibility to register on the website of the Controller with the indication of personal data. Which personal data are transmitted to the Controller is determined by the respective input mask used for the registration. The personal data entered by the Data Subject are collected and stored exclusively for internal use by the Controller, and for his own purposes. The Controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the Controller.

By registering on the website of the Controller, the IP address—assigned by the Internet service provider (ISP) and used by the Data Subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the Controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the Data Subject, with the voluntary indication of personal data, is intended to enable the Controller to offer the Data Subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the Controller.

The data Controller shall, at any time, provide information upon request to each Data Subject as to what personal data are stored about the Data Subject. In addition, the data Controller shall correct or erase personal data at the request or indication of the Data Subject, insofar as there are no statutory storage obligations. A Data Protection Officer particularly designated in this data protection declaration, as well as the entirety of the Controller’s employees are available to the Data Subject in this respect as contact persons.

 

CONTACT VIA WEBSITE

The website of VIBAC S.p.A. contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (privacy@vibac.it). If a Data Subject contacts the Controller by e-mail or via a contact form, the personal data transmitted by the Data Subject are stored upon obtainment of consent for the purpose of processing or contacting the data subject.

 

SUBSCRIPTION TO OUR NEWSLETTERS

On the website of VIBAC S.p.A., users are given the opportunity to subscribe to our enterprise's newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the Controller.

VIBAC S.p.A. informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the Data Subject if (1) the Data Subject has a valid e-mail address and (2) the Data Subject registers for the newsletter shipping.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the Data Subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a Data Subject at a later date, and it therefore serves the aim of the legal protection of the Controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the Data Subject at any time. The consent to the storage of personal data, which the Data Subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the Controller, or to notify this circumstance to the Controller in a different way.

 

NEWSLETTER-TRACKING PIXELS

The newsletter of VIBAC S.p.A. contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, The Controller may see if and when an e-mail was opened by a Data Subject, and which links in the e-mail were called up by Data Subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the Controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the Data Subject. These personal data will not be passed on to third parties. Data Subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the Controller.  

 

REVIEW OF THIS POLICY

We keep this Policy under periodical review. This Policy was last updated in February 2018.

 

AUTOMATED DECISION-MAKING

We do not use automatic decision-making or profiling unless based on the Data Subject’s explicit consent. Each Data Subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the Data Subject and a data Controller, or (2) is not authorized by the European Union or a Member State law to which the Controller is subject and establishing  suitable measures to safeguard the Data Subject's rights and freedoms and legitimate interests, or (3) is not based on the Data Subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the Data Subject and a data Controller, or (2) it is based on the Data Subject's explicit consent, the Controller shall implement suitable measures to safeguard the Data Subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Controller, to express his or her point of view and contest the decision.

If the Data Subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer.

 

[1] The European Commission has made an "adequacy decision" with respect to the data protection laws of Canada. See http://www.garanteprivacy.it/home/provvedimenti-normativa/normativa/normativa-comunitaria-e-intenazionale/trasferimento-dei-dati-verso-paesi-terzi#1.

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