according to Italian Legislative Decree no. 196/2003 and art. 13 of the Regulation no. 2016/679/ EU
we inform you that Legislative Decree no. 196/2003, and related amendments, and Regulation no. 2016/679/EU (hereafter the “applicable legislation“) regulate the protection of the fundamental rights and freedoms of natural persons (hereafter “data subject“), concerning the processing of personal data.
Cefla S.c./Finishing B.U., acknowledging the importance of the protection of personal data processed and considering their protection as one of the main target of its business, provides this information (hereinafter “Notice “), in order to describe the processing methods of personal data collected through its website (hereinafter referred to as the “Website“).
1. Contact details of the Controller
Name: Cefla S.c., in the person of the legal representative pro tempore
Address: Via Selice Provinciale, 23/A, 40026, Imola (BO), Italy
Contact details: e-mail email@example.com
Internal Privacy Manager - Finishing B.U.: Mr. Alberto Maestri.
2. Type of personal data processed
In the BU Finishing Website, may be collected and processed the following data:
I. common personal data (by way of example but not limited to: name, surname, tax code, address, telephone number, e-mail, contact details) provided by the data subject to register and / or log into a reserved area or to receive a specific service;
II. navigation data (by way of example but not limited to: IP address, location – country -, information on the pages visited, access and navigation time on each page, clickstream analysis);
3. Legal basis, purposes of the processing and nature of collection of data
Personal data collected may be processed for the following purposes:
a) Purpose of service
executing a specific request of the data subject and / or providing a requested service;
and/or allow browsing and use of the services offered through the Website;
b) Statistical purpose
doing statistical research/analysis on aggregated or anonymous data, aimed at measuring the functioning of the Website, measuring traffic and evaluating usability and interest;
c) Marketing purpose
sending promotional and/or commercial mailing lists/ newsletters relating to Cefla S.c. products and activities; and/or analyzing behaviours, attitudes and propensities to the consumption of the data subject, in order to improve products and services provided by Cefla S.c.
The treatments put in place for the purposes of service are necessary for the fulfilment of contractual obligations and, therefore data subject specific consent is not required.
The treatments put in place for statistical purposes are based on aggregate and / or anonymous data and data subject specific consent is not required.
The treatments put in place for marketing purposes are carried out only with the specific consent of the data subject.
4. Transfer of data
Personal data may be communicated and processed:
– to/by Cefla’s employees and / or collaborators belonging to the offices involved for the purposes set out above as data processors;
– to/by agents, distributors and the entire commercial network of Cefla S.c. or to/by Cefla S.c. subsidiaries, affiliates or, in any case, companies of the Cefla group, in Italy, in the European Economic Area (EEA) or to countries outside the European Economic Area (EEA), by virtue of specific contractual restrictions;
– to/by Cefla S.c. suppliers, such as the suppliers of technology services, email marketing service, consultants and/or freelancers who provide assistance, consultancy or collaboration in accounting, administrative, legal, tax and financial matters and who have Cefla S.c. to security and confidentiality;
– to/by persons in charge/delegated by Cefla S.c. for the performance of the activities or part of the activities related to sales and after-sales services;
– to/by judicial authorities and/or public administration in the exercise of their institutional functions.
5. Data transfer in the EEA and non-EEA territory
Exclusively for purposes related to the requested services and occasionally, some data may be transferred outside the EEA territory, also by including them in databases managed by third-party companies, operating on behalf of Cefla S.c.
In particular, it should be noted that the company that manages the sending of replies to requests for the Finishing B.U., as well as the supplier of the CRM software (and in particular the services of Salesforce Services - i.e. Sales Cloud, Service Cloud, Chatter and Communities - and Marketing Cloud services) is currently saleforce.com EMEA Limited, with registered office in the UK.
Saleforce.com has adopted the Binding Corporate Rules ("BCR") for Processors to legitimise the transfer of personal data outside the European Union to companies of its group that process such data on behalf of Data Controllers based in a member state as Processors and/or Sub-Processors.
The Saleforce's Processor Binding Corporate Rules can be viewed at the following link: https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/misc/Salesforce-Processor-BCR.pdf
For more information, please check the following links https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Agreements/EU-Data-Transfer-Mechanisms-FAQ.pdf and https://help.salesforce.com/articleView?id=000314281&type=1&mode=1 ("Where is my Salesforce instance located?")
6. Method of treatment and retention period
The personal data will be processed according to the principles of correctness, loyalty and transparency, using manual, computerized and telematic tools with logic strictly related to the purposes of the processing and, in any case, in order to guarantee the security and confidentiality of the data .
With reference to the service purpose, personal data will be kept for the period strictly necessary for the related contractual fulfillment and in compliance with the terms of the law for storage.
With reference to the marketing purpose and without the revocation of the consent by the data subject, the personal data will be kept for a maximum period of 24 months starting from the date of collection of the same and, in any case, within the limits term permitted by current legislation.
At the end of the data processing period, the data will be deleted, or permanently anonymised.
7. Rights of data subjects
A data subject may, at any time, exercise the following rights:
– obtain access to personal data;
– obtain confirmation of the existence of personal data concerning him and their communication in intelligible form;
– obtain the rectification, integration, erasure or restriction of the processing of personal data;
– oppose the treatment;
– data portability;
– withdraw the consent at any time without prejudice to the lawfulness of the treatment based on the consent previously given;
– lodge a complaint with the competent Supervisory Authority (Privacy Guarantor).
To exercise the above rights, report problems or request clarification on the processing of personal data, the data subject may send a registered letter to Cefla S.c., Via Selice Provinciale, 23/A, 40026, Imola (BO), Italy or write an e-mail to: firstname.lastname@example.org
8. Links and other websites and social networks
Links to third-party websites are provided only for user convenience. The interactions and consequent processing of personal data carried out by and on external platforms are to be considered regulated and subject exclusively to the privacy policies established by the respective data controllers, i.e. the companies that manage the related websites and social networks.
This Notice is updated to 20th March 2020. In case of future amendments, Cefla S.c. will give appropriate communication by publishing the updated version of the Notice on this Website.