DATA CONTROLLER AND DATA PROTECTION OFFICER (DPO)
WEB PAGE MISSION WWW.ALMECOGROUP.COM
PRINCIPLES
SOURCES OF THE PERSONAL DATA
CATEGORIES OF SUBJECTS and CATEGORIES AND PERSONAL DATA PROCESSED ON THE WEB
PURPOSES OF THE PROCESSINGCONTACT METHODS FOR MARKETING PURPOSES
COOKIES
MONITORING OF COMMUNICATIONS SENT
RECIPIENTS OF THE DATA
NATURE OF THE PROVISION OF THE DATA
PARTIES AUTHORISED TO PROCESS THE DATA
TRANSFER OF THE PERSONAL DATA TO NON-EU COUNTRIES
RIGHTS OF THE DATA SUBJECT – LODGING COMPLAINTS WITH THE SUPERVISORY AUTHORITY
ALMECO S.P.A.
Address: Via della Liberazione,15 – 20098, San Giuliano Milanese (MI)
Telephone: +39 02 9889631
Fax: +39 02 98896399
Email: info.it@almecogroup.com; privacy@almecogroup.com
PEC certified email: almeco@registerpec.it
VAT no. and tax code and ITVAT: 00772590154
Share capital: € 30.000.000 fully-paid
Economic and Administrative Index (REA): 687991
Milan Chamber of Commerce
www.almecogroup.com and related subdomains
DATA PROTECTION OFFICER (DPO)
MICROELL Srl (contact Francesco Traficante))
Via Mazzini 19b, 21052 Busto Arsizio VA
Email: dpo@almecogroup.com
WEB PAGE MISSION WWW.ALMECOGROUP.COM
Owned by Almeco S.p.A., the website www.almecogroup.com, aims to provide the user with detailed, specific information in a clear, transparent manner for every need regarding our products and services.
The user may also have reached this web page through an advertisement on the Internet or through an informative or promotional communication after providing specific consent to us or to one of our suppliers (Lead or List Provider) to be contacted for commercial communications from Third Parties, including for products and/or services other than those for which such consent was granted.
The user can:
- Be constantly updated about services and products that are among the most sophisticated in the world, including through Almeco's blog (https://blog.almecogroup.com/);
- Request catalogues, free information and/or quotes on certain products through the use of contact forms;
- Participate in the blog.
One of our fundamental objectives is the protection of personal data.
The data are processed in a lawful, proper and transparent manner, must be adequate, relevant and limited to what is necessary, accurate and, if necessary, updated, collected for specific, explicit and legitimate purposes pursuant to articles 5 and 6 of the EU Data Protection Regulation 2016/679 and based on the provision of consent where needed.
The data are processed in such a way as to ensure their adequate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage (integrity and confidentiality) through appropriate technical and organisational measures.
We notify users in the event of substantial changes to this Privacy Policy and the related data processing, providing the option to authorise us or otherwise to process the data for the purposes set out below.
SOURCES OF THE PERSONAL DATA
Collected from the Data Subject:
- Web pages and/or Social Profiles of the Data Controller li>
- Internet / Search Engines/ Social Networks;
- Web Pages and/or Social Profiles of the Suppliers-Lead Providers;
- Private Databases (Purchase and/or Rental from Suppliers-List Providers).
Users: natural and legal persons and other operators in the sector, including workers and similar of Customer Companies and potential Customers.
CATEGORIES OF PERSONAL DATA PROCESSED ON THE WEB:
COMMON:
Data provided by the User in the contact form: Identifying and contact information and any other information provided by the User (Name and Surname, Telephone, Email, Country, Company Name, Reason for the request - Message)
Possible additional data collected by the website, where applicable: IP, Date and Time of Registration, IMEI and MAC, any additional data associated with the device being used.
Interests expressed by the User while browsing, subject to express consent (see the Cookie Policy).
PURPOSES OF THE PROCESSING
1. Execution of pre-contractual measures
DESCRIPTION OF THE PURPOSES, LEGAL BASIS FOR THE PROCESSING AND DURATION
Purposes connected to the establishment and execution of pre-contractual measures (Request for information, quotes, catalogues, white papers, registration for events):
- Information, consulting, feasibility, quotations, assistance, monitoring of quotation status and measurement of satisfaction limited to the management of the request, and commercial negotiations, etc.;
- Sending of catalogues, white papers, registration for events, etc.;
- Including the necessary processing of other parties used for the promotion, placement and conclusion of the contract, subject to communication, which contribute to the proper and complete management of requests (Commercial Sales Network).
- Execution of pre-contractual measures.
- For a period strictly necessary for the proper and complete management of the request. Subsequently for a period of 12 months for further processing and storage upon the specific request of the Data Subject.
- Halting of processing and deletion at the end of the management of the request or after 24 months in case of Marketing Consent.
DESCRIPTION OF THE PURPOSES AND LEGAL BASIS FOR THE PROCESSING AND DURATION
Advertising campaigns (initiatives, events, information, new products and new offers) as well as measurement of customer satisfaction and market research. Personalised advertising campaigns may also be carried out, depending exclusively on the product categories for which the data subject has expressed an interest (e.g. by requesting the relevant catalogue) and which are available in the geographical area that the data subject may have specified in the contact form. Note that a segmented and targeted profile will not be created on a granular level and no tracking will be performed.
Legal Basis for Processing:
- Consent (optional and may be withdrawn at any time).
- So-called Soft Spam: Communications by email for the purpose of the direct sale of products or services similar to the object of a previuous contact with the Customer (Legitimate interest of the Data Controller (LIA) for the legal persons and pursuant to art. 130, paragraph 4 of the Privacy Code as amended for natural persons. In the absence of initial refusal and without prejudice to the right to object at any time).
Duration of the processing and storage period
- Duration and Retention up to 24 months from the expression of the Consent.
- 12 months after the conclusion of the last contract for Soft Spam.
- Near the expiration of these terms, new request for consent, otherwise halting of processing and/or deletion and only statistics in aggregate mode.
DESCRIPTION OF THE PURPOSES, LEGAL BASIS FOR THE PROCESSING AND DURATION
Fulfilment of precise obligations envisaged by regulations and applicable European and national laws.
Legal Basis for Processing:
Compliance with legal obligations.
Duration of the processing and storage period
Duration and Storage dictated by legal provisions.
4. Defensive rights
DESCRIPTION OF THE PURPOSES, LEGAL BASIS FOR THE PROCESSING AND DURATION
Assessment, exercise or defence of the rights of Data Controller in and out of court.
Legal Basis for Processing:
- Legitimate Interest of the Data Controller;
Traditional:
- Telephone call to landline with operator and/or traditional Post (Italy: after verification of the Register of Objections / Outside of Italy: after verification of the legislation in force in the country where the Data Subject is based).
- Automated telephone call to landline or cell phone (Italy: verification of the Register of Objections / Outside of Italy: after verification of the legislation in force in the country where the Data Subject is based).
- Fax
- Text message
- Multimedia message
- Chat or messaging systems (WhatsApp and other comparable instant messaging solutions)
- Web advertising: advertisement on the Internet
COOKIES
Please read the extended Cookie Policy
We use technological solutions aimed at monitoring the progress of campaigns involving the sending of commercial or marketing communications.
These tools allow us to simultaneously deliver the same promotional content to multiple recipients through the contact methods used for marketing purposes listed above.
These solutions also allow us to know the progress of advertising campaigns through the monitoring of visitor interactions and the storage of statistical information relating to user browsing in an anonymous, aggregated database, for example the number of users who clicked on a link and opened the message, the content within the message that received the most interest, the geographical location of the various users who opened the email, etc.
RECIPIENTS OF THE DATA
The data may be disclosed and processed by external parties acting as independent data controllers such as, by way of example:
Italy
a. Authorities and supervisory and control authorities;
b. Police and judicial authorities;
c. Parties who are transferees of a company, of a business unit, of legal relationships that can be identified as a whole or of individual legal relationships (e.g. the transfer of receivables, contracts);
d. Parties that offer professional consulting services, including in associated form.
If the requests from the User concern geographical areas of competence of other Almeco Group companies:
European Union (Germany):
e. Companies – foreign or otherwise – that are associates or belong to the same group or parent company, ALMECO GROUP (Italy).
USA:
f. Companies – foreign or otherwise – that are associates or belong to the same group or parent company.
China:
g. Companies – foreign or otherwise – that are associates or belong to the same group or parent company.
The data may also be processed in the name and on behalf of the Data Controller by external parties designated as data processors or sub-processors, to which appropriate operating instructions are given. These parties are essentially included in the following categories:
Italy:
h. Parties that carry out control, review and certification activities, including in the interest of customers;
i. Parties that offer ongoing compliance support services;
j. Parties that offer IT, ICT, cloud, web and digital marketing services;
k. Parties that offer paper, digital and alternative storage services;
l. Parties that offer traditional and automated postal services;
m. Parties that offer support in preparing market studies.
n. Parties that offer ICT services (Hosting/Data Centre);
o. Companies or consultants offering other sundry services;
European Union
p. Agents or other commercial entities authorised to distribute our products based on their territorial coverage corresponding to the same area as the customer or potential customer;
q. Parties that offer IT, ICT, cloud, web and digital marketing services.
For the execution of the pre-contractual measures requested by the User the provision of the Data is necessary but optional, therefore the failure to provide complete, correct data will make it impossible to manage what is requested by the User, without any consequence on the ability to browse the Website.With regard to the purposes of marketing, the provision of data is necessary but optional, therefore the failure to provide complete, correct data will make it impossible to send marketing communications, without any consequence on the ability to browse the Website.
PARTIES AUTHORISED TO PROCESS THE DATA
The data may be processed by employees and contractors of company functions – including the sales network – assigned to pursue the aims indicated above, who have been specifically authorised to process data and adequately sensitised and trained and have received adequate operating instructions.
The data of the Data Subjects, Legal Persons – including the data of the workers of the Customer Companies and potential customers – located in countries outside Europe may be transferred to the USA, China and to Agents or other commercial entities located in countries outside the EU that are authorised to sell, promote and distribute the products based on their territorial coverage corresponding to the same area as the customer or potential customer.
For this reason, pursuant to art. 3, paragraph 2 of the GDPR the Regulation does not apply.
Therefore, the regulations on the protection of personal data in force in the States in which the Recipients are based shall be applied.
A copy of the data can be obtained in the manner outlined in the section “Rights of the Data Subject – Lodging complaints with the Supervisory Authority”.
RIGHTS OF THE DATA SUBJECT – LODGING COMPLAINTS WITH THE SUPERVISORY AUTHORITY
By contacting the Data Controller by email at privacy@almecogroup.com, Data Subjects may ask the Data Controller to give them access to their data, block and anonymise their data, correct inaccurate data, complete incomplete data, restrict processing in the cases envisaged by article 18 of the GDPR, as well as object to processing in the case of the legitimate interest of the Data Controller.
The data controller shall provide the data subject with the information relating to the request for the exercise of the data subject's rights (pursuant to articles 15 to 22 of the GDPR) without undue delay, and in any event at the latest within one month of receiving the request, as envisaged in article 12 of the GDPR.
Furthermore, in the event that the processing is based on consent or a contract and is performed with automated tools, the data subjects have the right to receive the data in a structured, commonly used and machine-readable format, and, if technically feasible, to have them sent to another data controller without impediment (Right to Portability), and to request the simultaneous or subsequent definitive cancellation of such data (Right to Be Forgotten).
Data Subjects have the right to withdraw the consent given at any time for marketing purposes, objecting to such processing, using the link in each email or by sending an email to the above address, including in the subject, for example, “delete me - email” or “delete me - telephone” or “delete me - specify other method of contact in use”.
If no advertising communications are desired at all, include in the subject “delete me - marketing”.
In the case of promotional advertisements (Targeted or Customised Advertising) on websites and/or search engines and/or social networks, if a promotional advertisement is seen the platform in use could allow one to know why they are part of a target or customised audience, and how they can leave that audience: objection at any time, even revocable by removing Follow or Like or “Hide Advertisement or Advertiser” in the “Why you’re seeing this advertisement” section, which can be selected directly from the Promotional Post.
If the processing is based on consent for one or more purposes (art. 6, paragraph 1, letter A of the GDPR) and for the processing of particular data (art. 9, paragraph 2, letter A of the GDPR), the withdrawal of consent at any time does not affect the legality of the processing based on consent before such withdrawal.
Data subjects shall have the right to lodge a complaint with the Supervisory Authority having jurisdiction in the Member State of their habitual residence, place of work or place of the alleged infringement.
2021 previous version