THE PRIVACY POLICY OF WWW.SPOTTI.COM WEBSITE

USERS’ PERSONAL DATA PROCESSING BY WWW.SPOTTI.COM WEBSITE

This page describes the management modalities of the WWW.SPOTTI.COM website, particularly on how it handles users’ personal data. This information is provided pursuant to Art. 13 of the legislative decree n. 196/2003 – personal data protection code – to those who interact with the website services of Spotti Srl for the protection of personal data that can be accessed electronically from the address www.spotti.com.
This information is aligned with the Recommendation n. 2/2001 issued by the European authorities to protect personal data, gathered in the Group established by Art. 29 of the Directive n. 95/46 / EC, adopted on 17 May 2001 to identify certain minimum requirements for the collection of online personal data, and, in particular, the modality, time and nature of the information that the data controllers must provide to users when they link to a web page, regardless of the purposes of the connection.

Please note that this information is provided only for the Spotti Srl website and not for other websites possibly consulted by the user via link.

1) WHO IS THE HOLDER OF THE DATA PROCESSING AT SPOTTI Srl?

Following consultation of this site, data relating to identified or identifiable persons may be processed.
The holder of the processing is the Società SPOTTI SRL, located in MILANO, IT- 20129, Viale Piave, n.27

C.F./P.Iva 12645280152
FAX: 02794272
E-MAIL : info@spotti.com
PEC: spotti@postacertificata.com

2) WHO IS THE RESPONSIBLE FOR THE PROCESSING?

SPOTTI Srl has designated as responsible for the processing pursuant to Article 29 of the personal data protection cod, Mr. MAURO SPOTTI, legal representative of SPOTTI Srl.
The designated person responsible for the processing will also manage the business relations with the Società……., in charge of the maintenance of the technological part of SPOTTI Srl website.

3) WHERE IS THE DATA PROCESSING LOCATED?

The processing operations connected to the web services of this site take place at the aforementioned SPOTTI Srl headquarters and are only handled by personnel in charge of processing and under the aegis of the Responsible person.
Always under the aegis of the designated Responsible person, the data related to the “newsletter” service can be processed by the staff of the Società SPOTTI Srl, or in case of need, by the Società……….. responsible for the maintenance of the technological part of the site, at the headquarters of the company itself.

4) WHAT TYPES OF DATA ARE TREATED?

A) WEB BROWSING DATA

During their normal operation, computer systems and software procedures used to operate this website acquire some personal data, the transmission of which is implicit in the use of internet communication protocols.
This information is not collected with the intent of having it associated with the identification of users interested but, by its nature, it could lead to the identification of users through processing and association with data held by third parties.
This category of data includes IP addresses or domain names of computers used by persons who connect to the site, the URI (Uniform Resource Identifier) of requested resources, the time of request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding the user’s operational system and computer environment.
This data is used only to obtain anonymous statistical information about website usage and to check its correct functioning, being deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the website: except for this possibility, data concerning web contacts are not kept for more than seven days.

B) DATA PROVIDED VOLUNTARILY BY THE USER

The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this website entails the subsequent acquisition of the sender’s address, which is necessary to respond to requests, as well as any other personal data included in the message.
Specific summary information will be progressively shown or displayed on the website pages dedicated to particular on-demand services.

C) COOKIES

WHAT COOKIES ARE: cookies are small files stored on your computer’s hard drive and are used to provide services and/or information. There are two types of cookies: technical (session, analytic and functionality) cookies and profiling cookies.

– Technical cookies are used for normal usability of navigation on the site and to improve the service. Session cookies guarantee the normal navigation and use of the web; analytic cookies are used to collect information, in an anonymous and aggregate form, on how many users visit the site; the functionality cookies allow the user to browse according to a series of criteria selected (for example, choosing the language) in order to improve the service rendered.
– Profiling cookies, on the other hand, are used to outline the profile of the user and his interests, to send him/her advertising messages in an effective and targeted manner, even by third parties.

WWW.SPOTTI.COM website uses the following COOKIES:

D) SETTING COOKIES:

The user can, at any time, decide on whether to allow or not cookies on his computer, through the browser settings.
Below you will find the links to the instructions on how to disable cookies, according to the type of browser used: (TO VERIFY!)

-Opera – https://support.apple.com/kb/PH19214?viewlocale=it_IT&locale=en_US
-Chrome – https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies
-Firefox – https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
-Internet Explorer – http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies

However, it should be noted that the deactivation of cookies could cause some website features to be disabled. Even with all cookies disabled, your browser will continue to store a small amount of information needed for the website’s basic functionality.
By no means is users’ personal data acquired from WWW.SPOTTI.COM website in this regard.
We do not use cookies to transmit information of a personal nature nor are the so-called persistent cookies, i.e. systems for tracking users, of any kind used.
The use of the so-called session cookies (which are not persistently stored on the user’s computer and disappear when the browser is closed) is strictly limited to the transmission of session’s identifiers (consisting of random numbers generated by the server) necessary to allow the user to browse the site efficiently and securely.
The so-called session cookies used on this website do not resort to other computer techniques that are potentially detrimental to the confidentiality of its users’ navigation, and do not allow for the acquisition of personal data that identifies the user.

5) PURPOSE OF DATA PROCESSING

Personal data will be processed:

A) without the user’s explicit consent (Article 24, letters (a), (b), and (c) of the Privacy Code and Article 6, letter (b) and GDPR) for the following Service Purposes:

– Allow the user to browse the SPOTTI Srl website;
– Fulfil the obligations established by law, by a regulation, by community legislation or by an order of the Authority;
– Prevent or discover fraudulent activities or malicious activities that could cause damage to the website;
– Exercise the rights of the Holder, for example, the right to defense in court.

B) Only subject to specific and distinct users’ consent (art. 23 and 130 of the Privacy Code and Article 7 GDPR), for the following Marketing Purposes:

– Send via email newsletters, commercial communications and/or advertising material on products or services offered by the Holder;

It should also be noted that if the user is already a customer, Spotti Srl may send commercial communications relating to services and products of the Data Holder similar to those of which he/she has already used, subject to his/her disagreement (Article 130 c. 4 Privacy Code).

6) OPTIONALITY OF USERS’ DATA PROVISION

Given the explicit and specified for navigation data, the user is free to provide personal data contained in the request forms prepared by SPOTTI Srl or as indicated in the modality of contact with SPOTTI Srl offices to request that they send the user the newsletter, informative material or other communications.
Failure to provide this data can prevent users to obtain the requested service.
For completeness it should be remembered that in some cases (not subject to the ordinary management of this website) the Privacy Authority can request that the holder, the responsible, the interested party or even third parties present information and documents pursuant to Article 157 of the Personal Data Protection Code , aiming to control personal data processing. In these cases, the holder’s or data controller’s response to the Authority’s request is mandatory, being subject to administrative sanction otherwise.

6) MINORS

This Website and the Services to the Holder are not intended for children under the age of 18 and the Holder does not intentionally collect personal information about minors. In the event that information on minors is involuntarily recorded, the Holder shall promptly delete it, at the users’ request.

7) WHAT IS DATA PROCESSING MODALITY?

Your personal data is processed using the operation modalities indicated in Article 4 of the Privacy Code and Article 4, n. 2 of the GDPR, and more precisely: data collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, termination, and destruction. Your personal data are subjected to both paper and electronic and/or automated processing.

The Holder will process your personal data for the time necessary to fulfil the aforementioned purposes and for a period not exceeding 10 years from the termination of the relationship for Servicing Purposes and no exceeding 2 years from the date on which the data was collected for Marketing Purposes.
Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which it was collected.
In any case, SPOTTI Srl has specific security measures to prevent data loss, illicit or incorrect use and unauthorized access.

8) WHAT ARE THE RIGHTS OF THE INTERESTED?

Subjects to whom personal data refer have the right, at any time, to obtain confirmation of whether or not the same data exist and to know its content and source, to verify its accuracy or to request its integration or updating, or rectification (Article 7 of the Code on the Protection of Personal Data).
Pursuant to the same article, users have the right to request the cancellation, transformation into anonymous form, or the blocking of the information processed in violation of law, and, in any case, to object to the processing of data for legitimate reasons.
Requests should be sent to SPOTTI Srl, to the attention of Mr. MAURO SPOTTI, by filling out the attached FORM (Personal data form):

– via e-mail, all’indirizzo: privacy@spotti.com
– via fax: 039 484973
– oppure via posta, all’indirizzo MILANO, IT- 20129 , Viale Piave, n.27, alla C.A. del Sig. MAURO SPOTTI

The “Privacy Policy” of the WWW.SPOTTI.COM website will be subject to constant adjustments by virtue of legislative updates that will be monitored on the site of the Authority for the protection of personal data, to which reference should be made to review the legislation.