PRIVACY POLICY

METALTRONICA

Policy on the processing of personal data

PRIVACY POLICY

Personal data, cookies
and
 
web navigation data.
Controller Metaltronica S.p.A.
with registered office in Via delle Monachelle, 66 - 00071 Pomezia (Rome) - Italy, VAT no. 01123731000
Contact details of the Controller
Ph: 06 66160206
Fax: 0666160357
Mail: privacy@metaltronica.com
Contact details of the Data Protection Officer
Metaltronica S.p.A. does not come under the grounds provided for by Article 37 of the EU Reg.no. 679/2016
Processor
Orbital Waves s.r.l. insofar as it is responsible for the management and maintenance of the web portal www.metaltronica.com, under articles 28 and 29 of the EU Reg.no. 679/2016
Metaltronica S.p.A with registered office in Via delle Monachelle, 66 - 00071 Pomezia (RM) - Italy, VAT No. 01123731000, as Data Controller of Your personal data, hereby informs You, pursuant to articles 12 and 13 of EU Regulation no. 679/2016 (General Data Protection Regulation, hereinafter referred to as "GDPR"), that Your personal data will be processed by specifically authorized parties and for the purposes and in the manner specified below.

OBJECT AND PURPOSE OF PROCESSING

Metaltronica S.p.A., in its capacity as Data Controller, hereby informs You that it will process Your personal data (specifically and limited to Your personal details, tax data, postal data, including e-mail data, and IP identifiers and addresses or domain names), which You have communicated, solely for the purposes of registering for the service www.metaltronica.com to allow Metaltronica S.p.A. to carry out the following activities and services: sending of newsletters, information and updates on laws and regulations, sending of commercial proposals, management of technical assistance, management of labor under warranty, reporting of advertising events, sending of promotional communications for similar service, management of direct relations and contacts company / customer / user, by e-mail, between Metaltronica S.p.A. and users and visitors of its web portal www.metaltronica.com (art. 13 (1) c) of GDPR). This information is effective only with reference to the aforesaid web portal www.metaltronica.com, and not with reference to other and different portals or web sites that may be consulted through the links therein, of which, of course, the undersigned company Metaltronica S.p.A. is not in any way owner.

The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site involves, therefore, the subsequent acquisition of the sender's email address, necessary to respond to requests, as well as any other personal data included in the message.

Furthermore the IT systems and software procedures provided to operate this web site acquire, during their normal operation, certain personal data which are implicitly transmitted when using the Internet communication protocols.

This information will not be acquired for it to be associated with identified data subjects. However for its very nature, such information may be used to identify Users through its specific processing and matching to other data held by third parties.

The IP addresses or the domain names of the computers used by the Users who connect to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used for submitting the request to the server, the size of the file received in response, the numeric code indicating the status of the response given by the server (successful, error, etc.) and other parameters relative to the operating system and the IT environment of the User come under this category.


Those data will solely be used to obtain anonymous statistical information on the use of the website and control its correct operation and will be deleted immediately after processing. The data could be used to verify responsibility, in case of hypothetical IT crimes detrimental to the site: except for this possibility, web contact data currently do not persist for more than 7 (seven) days.

Apart from what is specified for navigation data, the disclosure by You to the undersigned company of personal data as specified above, has Your express consent as the sole lawful basis for processing, pursuant to Article 6 (1) point (a) of the GDPR and therefore is purely optional and not mandatory, and has no effect other than the impossibility for the Data Controller to carry out the aforesaid activities and further services. And, in any case, any consent given by You may be revoked by You at any time which will give immediate effect to the interrupting of the aforementioned company activities and services.


PROCESSING MODALITIES

Processing of Your personal data disclosed by You is carried out by means of the operations outlined in Article 4 of the Italian Privacy Code and Article 4(2) of the GDPR and, more specifically: “collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, communication, erasure and destruction of data”.

The personal data You disclose will be processed in paper, electronic and computerized form and included in the relevant personal data and databases (customers, users) for the time strictly necessary to achieve the purposes for which they were collected, with technical and organizational methods, adopted to prevent the loss of data, illegal or incorrect use and unauthorized access, and such, therefore, to ensure a level of security appropriate to the risk under Article 32 of GDPR 2016/679, by persons specifically authorized to do so, in compliance with the provisions of Article 29 of GDPR 2016/679, or employees and/or coworkers of Metaltronica S.p.A. in their capacity as authorized persons and/or internal delegated representatives and/or system administrators, who may carry out operations of consultation, use, processing, comparison and any other appropriate operation, including automated operations, in compliance with the provisions of the law necessary to guarantee, among other things, the confidentiality and security of data as well as the accuracy, updating and pertinence of data in accordance with the declared purposes and methods.


SCOPE OF DISSEMINATION

Please note, in particular, that the personal data You provide will be processed only at the headquarters of the data controller, will not be disclosed, and, pursuant to Article 13, (1), point (e), the same may be processed only by authorized persons and/or delegated persons within the company with the functions assigned to them (see Organigram and Privacy Job Description) and/or also by external data processors (in the person of individual professionals and/or complex professional associations), but only and exclusively for the purposes expressly and specifically indicated above.

In particular, in relation to the purposes indicated above, the data may be disclosed to the following entities and / or categories of entities listed below, or may be disclosed to companies and / or persons, both in Italy and abroad, providing services, including external, on behalf of the Data Controller.

These include, but are not limited to, the following for clarity: entities - internal or external to the company - that provide IT and computerized services for the management of the information system used by Metaltronica S.p.A. and telecommunications networks (including e-mail and management of web portals and websites - hosting); entities carrying out user support activities; professional studies; financial authorities and other companies or public bodies in compliance with regulatory requirements; competent authorities and/or Supervisory Bodies for the fulfilment of legal obligations; consultancy firms; companies and law firms for the protection of contractual rights; entities that carry out control, revision and certification obligations of the activities carried out by Metaltronica S.p.A. It should be noted that the entities belonging to the above categories are all appointed by the undersigned company as external Processors pursuant to Article 28 of the GDPR, or operate completely independently as separate Data Controllers. The list of external data processors is constantly updated and available at the Metaltronica S.p.A. offices.

In case of necessity, the data related to the newsletter service can be processed by the authorized personnel of the company that oversees the management and maintenance of the technological part of the site, Orbital Waves s.r.l. which has been appointed as external processor of personal data at the headquarters of the company.

Metaltronica S.p.A. reserves the right, pursuant to Article 13, (1), point (f), to transmit Your personal data for the sole purpose of administrative, technical and commercial management to its foreign subsidiary company, Metaltronica USA INC. with Principal Office located in New York (USA), 1350 Broadway N.Y. 10018, for the purposes and in the manner described above and specified, which shall be deemed to have been reproduced and reported in full herein.


STORAGE PERIOD

Please note that, in accordance with the principles of lawfulness, limitation of purposes and storage and minimization of data, pursuant to Article 5 GDPR 2016/679, except as specified above for web contact data for which the storage period is no more than 7 (seven) days, the storage period of Your personal data is set for a period of time no longer than the achievement of the purposes for which they are collected and processed, or for the duration of the registration to the service www.metaltronica.com.

After the expiry of the storage term as identified above, Your data will be deleted from each Database, application and paper archive in which they were registered and stored.


AUTOMATED DECISION MAKING AND PROFILING

Metaltronica S.p.A. hereby informs You that, for the purposes of processing Your personal data, it does not use automated decision-making processes, or those designed to make decisions based solely on technological means according to predetermined criteria (i.e. without human involvement), nor does it carry out profiling activities, or use Your personal data to analyze or predict aspects relating to professional performance, financial situation, health, personal preferences, interests, reliability, behavior, location or travel, etc.


RIGHTS OF THE DATA SUBJECT

Right of Access under Article 15 of GDPR and Right of Rectification under Article 16 of GDPR


As data subject, pursuant to Article 15 of GDPR, You have the right to obtain from Metaltronica S.p.A., as data controller, confirmation of whether or not personal data concerning You are being processed, to obtain access to the same and to all the information referred to in the same Article 15(1), points (a) to (h), by issuing a copy of the data being processed in structured format, in common use, readable by an automatic and interoperable device.

You, according to Article 15 of GDPR, also have the right to obtain from Metaltronica S.p.A. the rectification and/or completion of the data being processed if they are out of date and / or inaccurate and / or incomplete, by request together with the release of a supplementary statement to be sent to the email address privacy@metaltronica.com. 

Metaltronica S.p.A. will confirm receipt of Your request and provide You with information on the action taken, with reference to the exercise of the rights under Articles 15 to 22 GDPR, within 1 (one) month of receipt of the request. If necessary, and taking into account the complexity and number of requests, Metaltronica S.p.A. may extend this period by 2 (two) months, subject to a communication justifying this to be sent within 1 (one) month from receipt of the request.

Metaltronica S.p.A. will communicate any rectification and/or integration to all recipients, as identified by Article 4, (1), point (9) of GDPR, to which these data have been transmitted, unless this proves impossible and/or involves a disproportionate effort. 

Following the sending of Your request for access or rectification, if Metaltronica S.p.A. has reasonable doubts about Your identity, it will request further information to confirm it. Such communications will be sent by e-mail from the address privacy@metaltronica.com, and will be processed by the person specifically authorized for the purpose.

In the event that Metaltronica S.p.A. does not comply with Your request within the term of 1 (one) month from receipt of the request, Metaltronica S.p.A. will inform You of the reasons for the non-compliance, and inform You as of now of Your right to lodge a complaint with a Supervisory Authority, as specified in accordance with Article 13, (2), point (d).

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Right of erasure under Article 17 of the GDPR and Right of restriction of processing under Article 18 of the GDPR

As data subject, You have the right to obtain, without undue delay, from Metaltronica S.p.A., but only on the grounds referred to in Article 17 (1) points (a) to (f) of the GDPR, the erasure of personal data concerning you - with the exception of the grounds specifically provided for in Article 17 (3).

As data subject, and in the event of one of the grounds referred to in Article 18 (1), points (a) to (d), of the GDPR, You have the right to request and obtain from Metaltronica S.p.A., by means of a communication sent by email to the address privacy@metaltronica.com, the restriction of processing of Your personal data, or that such data are not subject to further processing and may no longer be modified. Metaltronica S.p.A. ensures that the restriction of processing is implemented through technical devices that guarantee the inaccessibility and immobility,

Metaltronica S.p.A. will communicate any erasure of Your data and / or restriction of processing to all recipients, as identified by Article 4(1), point (9) of the GDPR, to which these data have been transmitted, unless this proves impossible and/or involves a disproportionate effor

Metaltronica S.p.A. will confirm receipt of Your request and provide You with information on the action taken within 1 (one) month of receipt of the request. If necessary, and taking into account the complexity and number of requests, Metaltronica S.p.A. may extend this period by 2 (two) months, subject to a communication justifying this to be sent within one month from receipt of the request.

If Your request is manifestly unfounded or excessive, especially in terms of its repetition, Metaltronica S.p.A. may charge a reasonable contribution towards providing You with the information, communication or action requested, or refuse to satisfy the request.

In the event that Metaltronica S.p.A. does not comply with Your request within the term of 1 (one) month from receipt of the request, Metaltronica S.p.A. will inform You of the reasons for the non-compliance, and inform You as of now of Your right to lodge a complaint with a Supervisory Authority, as specified in accordance with Article 13, (2), point (d).

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Right to the portability of data pursuant to Art. 20 of the GDPR - in the cases provided for by law
  

As data subject, You have the right to receive from Metaltronica S.p.A. Your personal data, in a structured format, commonly used and readable by an automatic device, and You also have the right to transmit such data to another data controller, or to obtain from Metaltronica S.p.A., where technically feasible, the direct transmission of such data to another data controller specifically identified, upon request to be sent by email to privacy@metaltronica.com.

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Right of Objection to processing under Art. 21 GDPR


You have the right to object at any time to the processing of personal data concerning You, for reasons related to Your particular situation, in cases where the processing of Your data is necessary (1) for the performance of a task in the public interest and / or related to the exercise of public authority entrusted to Metaltronica S.p.A.; (2) for the pursuit of a legitimate interest of Metaltronica S.p.A. or a third party; (3) for profiling activities performed by M.T.M. based on the above points.

You also have the right to object to the processing of Your personal data on grounds relating to Your particular situation if they are processed for the purposes of scientific or historical research or for statistical purposes in accordance with Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

The will to exercise the right of objection to the processing of Your data must be communicated to Metaltronica S.p.A. by email to privacy@metaltronica.com. Metaltronica S.p.A. will confirm, without undue delay, the receipt of Your communication.

Following Your communication, Metaltronica S.p.A., unless it can demonstrate the existence of legitimate compelling reasons to proceed with the processing of Your data that prevail over Your interests, rights and freedoms, or that the processing is necessary to ascertain, exercise or defend a right in court, or that the processing for the purpose of scientific research, history or statistics is necessary for the performance of a task of public interest, will refrain from further processing Your personal data.

You have the right to object to processing even if Your personal data are processed by Metaltronica S.p.A. for the purposes of direct marketing and / or profiling activities related to direct marketing. In such cases Metaltronica S.p.A., upon receiving Your communication in the manner indicated above, will refrain from further processing Your personal data.

COOKIES 

Cookies are small text files that sites visited by users send to their terminals, where they are stored and then transmitted to the same sites the next time they visit. “Third party” cookies are set by a different website from the one the user is visiting. This is because on each site there may be elements (images, maps, sounds, specific links to web pages of other domains, etc.) that reside on servers other than that of the site visited.

The Metaltronica website uses 'technical' cookies, which are necessary for an optimal browsing experience:

1) We store language preferences according to the settings of the browser or the choice expressed on the site
2)  We store the preference obtained in the choice of the initial pop-up relating to art.21 of Legislative Decree 24 February 1997 no.46
3) We use Google Analytics cookies exclusively for statistical purposes for internal use and in relation to the interaction of users with the website with the aim of improving the experience and use (traffic data such as turnout, origin, content). Metaltronica does not use Google's advertising functions, so the data is anonymized upstream by masking the IP address. 

(Further details: https://support.google.com/analytics/answer/2763052?hl=it&ref_topic=2919631 )