On this page, COMASTRI DISTRIBUTION S.r.l. describes the management methods of this site (the "COMASTRI DISTRIBUTION Site") with reference to the processing of personal data of users who consult it or send email messages to the addresses available on the Site COMASTRI DISTRIBUTION S.r.l.
If you have any queries, please contact us at firstname.lastname@example.org
As of 25 May 2018, new privacy regulations came into force, which apply to all EU countries, under EU Regulation no. 2016/679 (General Data Protection Regulation, hereinafter referred to as GDPR), as well as by national laws, such as Legislative Decree101/18. The GDPR provides for greater user protection and requires new obligations and responsibilities for those who process personal data, including through websites. To learn more about the GDPR you can consult the useful in-depth section by the Italian Data Protection Commissioner (Garante), which will help you to better understand the new rules and to know your rights. One fundamental principle is that of transparency – users must know in advance, in a clear and complete manner, what personal information will be collected, who will handle it, for what reasons and for how long it will be held, whether it will be used for commercial purposes or for profiling purposes, whether it will be shared with third parties, etc., and be able to effectively control the management of their data. This information is provided in accordance with Article 13 of the GDPR as well as Legislative Decree 101/18 and also takes into consideration the Guidelines of the Working Party under Article 29 on Transparency.
The information is addressed to all those who interact with the COMASTRI DISTRIBUTION S.r.l. Site, accessible by electronic means from the address https//www.comastridistribution.com corresponding to the home page of the COMASTRI DISTRIBUTION S.r.l. Site. On consulting the COMASTRI DISTRIBUTION S.r.l. Site as well as submitting communications to the contacts present on the COMASTRI DISTRIBUTION S.r.l. Site, data can be processed that allow users to be identified – directly or indirectly.
The information is provided only for the COMASTRI DISTRIBUTION S.r.l. Site and not for other websites that may be consulted by the user via the links (hypertext links) on the COMASTRI DISTRIBUTION S.r.l. Site. The existence of one or more links to a site not belonging to COMASTRI DISTRIBUTION S.r.l. does not imply the approval or acceptance of responsibility by COMASTRI DISTRIBUTION S.r.l. regarding the content or use of such third-party sites. We recommend that users who wish to send data to or via third-party websites carefully read their privacy statements before providing personal data.
DATA CONTROLLER AND CONTACTS
The Data Controller of your personal data referred to in this Statement is COMASTRI DISTRIBUTION S.r.l., with REGISTERED OFFICE at:
Via Risorgimento n.35/E - 40069 Zola Predosa (BO), Italy,
available for any communication or request regarding its data, also at the email address email@example.com or the certified email address (PEC): firstname.lastname@example.org under the provisions of Regulation 2016/679 and Legislative Decree 101/18
TYPES OF DATA PROCESSED
Access to and consultation of the COMASTRI DISTRIBUTION S.r.l. Site does not involve the collection of personal data by COMASTRI DISTRIBUTION S.r.l., except for the "Contact Us" page where there is a contact form for which a specific privacy notice will be provided, in addition to to email contacts to send requests for information, CVs and applications. However, the computer system – as part of its normal operation – may need to store some of your browsing data. These data are sent automatic and are necessary for the operation of the COMASTRI DISTRIBUTION S.r.l. Site, being linked to the use of Internet communication protocols. These data are not collected in order to be associated with your identity; however, they could indirectly – through processing and association with data held by third parties – allow you to be identified. For this reason, they could be considered "personal data" according to the GDPR. These data include IP addresses or domain names of computers used by persons who connect to the COMASTRI DISTRIBUTION S.r.l. Site, the URI (Uniform Resource Identifier) of the resources requested, 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 operating system and computer environment.
Data protection provisions about the application and use of Google Analytics (with anonymization function)
On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
Data protection provisions about the application and use of Google Remarketing
On this website, the controller has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise's Internet site. The integration of Google Remarketing therefore allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.
The operating company of the Google Remarketing services is the Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users.
Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our website if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During the course of this technical procedure, Google receives personal information, such as the IP address or the surfing behaviour of the user, which Google uses, inter alia, for the insertion of interest relevant advertising.
The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser used by the data subject.
Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
Data protection provisions about the application and use of Google-AdWords
On this website, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google's search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.
The operating company of Google AdWords is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.
If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.
The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.
The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
Data Provided Voluntarily by Users
The optional, explicit and voluntary sending of email messages to the addresses indicated on the COMASTRI DISTRIBUTION S.r.l. Site implies the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the message. On all the pages of the COMASTRI DISTRIBUTION S.r.l. Site where there are features or forms that allow users to voluntarily provide personal data, specific privacy information is provided, directly and easily accessible from each page so that users can be fully aware of what, on a case by case basis, their personal data will be used for. COMASTRI DISTRIBUTION S.r.l. as Data Controller specifies that, if the User voluntarily and willingly provides personal data belonging to particular categories, pursuant to article 9 of the GDPR, (i.e.information that may reveal the racial origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions or organisations of a religious, philosophical, political or industrial nature, as well as personal data that may reveal a person's state of health or sexual orientation), COMASTRI DISTRIBUTION S.r.l. will treat them with the utmost confidentiality, in compliance with current legislation and for the exclusive purposes indicated in the specific policy notice. This data will be disclosed only to the recipients indicated in each specific policy notice and will not be used for commercial purposes, unless you provide us with your express consent, as specified below.
COMASTRI DISTRIBUTION S.r.l. may send commercial notifications exclusively to those users who have provided specific informed consent by accessing specific pages on the Site www.comastridavide.com. Before giving their consent, users are duly informed of the fact that COMASTRI DISTRIBUTION S.r.l., in accordance with the provisions of articles 13 GDPR and articles 8 and 9 of Legislative Decree 70/03, may send commercial and/or promotional messages to Users' email address and/or home address relating to its services or organised activities. Users who have consented to the sending of commercial notifications may, at any time, decide to withdraw their consent. In this case, COMASTRI DISTRIBUTION S.r.l. will refrain from sending future notifications. Withdrawing your consent will be possible with the same simple methods with which it was provided. Withdrawal of consent, as foreseen by the GDPR, does not prejudice the legality of the processing based on the consent previously given.
PURPOSE AND LEGAL BASIS OF THE PROCESSING
The data collected automatically by the system are used:
- in order to allow the User to use the features of the COMASTRI DISTRIBUTION S.r.l. Site;
- in order to obtain anonymous statistical information on the use of the COMASTRI DISTRIBUTION S.r.l Site and to check its correct functioning and are destroyed immediately after being processed;
- to ascertain liability in the event of possible computer crimes against the COMASTRI DISTRIBUTION S.r.l.
Site Data provided voluntarily by the user The data acquired by COMASTRI DISTRIBUTION S.r.l. with the optional, explicit and voluntary sending of email to the addresses indicated on the COMASTRI DISTRIBUTION S.r.l. Site, as well as through the forms present on specific pages of the COMASTRI DISTRIBUTION S.r.l. Site will be processed only as necessary in order to respond to any user requests. The data acquired by COMASTRI DISTRIBUTION S.r.l. with the optional, explicit and voluntary sending of curriculum vitae by candidate collaborators will be processed only for the purpose of evaluating applications for possible hiring and collaboration. Specific summary information is reported or displayed on the pages of the COMASTRI DISTRIBUTION S.r.l. Site from which personal data is collected by means of forms, with details of the purposes of the processing. The legal basis for processing the aforementioned data is the user's express consent, acquired in accordance with the GDPR.
RECIPIENTS OF PERSONAL DATA
The recipients of the navigation data are: • employees and collaborators of COMASTRI DISTRIBUTION S.r.l., service providers related to the management and operation of the COMASTRI DISTRIBUTION S.r.l. Site: Data provided voluntarily by the user Recipients of data voluntarily provided by the user – as specifically detailed also in the individual information notices – will be the following subjects, indicated individually or by categories:
- • employees and collaborators of COMASTRI DISTRIBUTION S.r.l.,
- • email service providers
- • service providers related to the management and operation of the COMASTRI DISTRIBUTION S.r.l. Site, any employees involved in occasional maintenance and repair operations
- • cloud service providers
- • hosting and virtual server service providers
- • providers of connectivity and telephony services
- • providers of chat and communication services
- • mailing list service providers
- • file transfer service providers
- • remote assistance service providers
- • shipping service providers
- • payment service providers
- • social networks
Data will not be disclosed to other categories of subjects, nor will they be shared or made public in any way. They may be shared with the competent authorities if required by current legislation or at the request of legitimate parties.
INTENTION TO TRANSFER DATA TO A THIRD COUNTRY OR AN INTERNATIONAL ORGANISATION
The navigation data and data sent voluntarily by users through the various channels made available by the COMASTRI DISTRIBUTION S.r.l. Site may be transferred to servers located in non-EU countries, if the IT service providers and programs used by COMASTRI DISTRIBUTION S.r.l., listed previously as recipients, foresee it or use cloud computing technology that cannot locate with certainty where your data is located. In accordance with the law, it should be noted that at present the European Commission has provided for an adequacy decision only for a limited number of States (Andorra, Argentina, Australia, PNR, Canada, Faer Oer, Guernsey, Isle of Man, Israel, Jersey, New Zealand, Switzerland, Uruguay) and therefore your personal data could be transferred from the services used (e.g. Skype, Gmail) also to countries for which such an adequacy decision has not been published, nor is COMASTRI DISTRIBUTION S.r.l. able independently to provide appropriate guarantees at present. However, we remind you that COMASTRI DISTRIBUTION S.r.l. has carefully selected only service providers able to offer a high level of security and protection of personal data.
DURATION OF DATA RETENTION
This data could be used to ascertain liability in case of hypothetical computer crimes against the site; except for this eventuality, the data is deleted immediately after processing. Cookies are stored for 12 (twelve) months, but only in aggregate form and do not identify users.
Data Provided Voluntarily by Users
The data voluntarily provided by users by sending information request emails to the contacts on the COMASTRI DISTRIBUTION S.r.l. Site and/or by completing the form on the contact page will be stored only for the time necessary to give feedback to parties concerned and will be subsequently destroyed. The data provided voluntarily by users by sending emails to contacts on the COMASTRI DISTRIBUTION Site Individual enterprises by sending CVs aimed at applying as collaborators will be stored only for the time necessary to give feedback to parties concerned and they will then be stored for 3 year, in order to be able to consult them should the need arise to hire a new professional or start a new collaboration.
YOUR RIGHTS AS A PARTY CONCERNED
We inform you that, as a party concerned, you have all the rights pertaining to you provided for by the GDPR: the Right of Access (article 15), Right to Rectification (article 16), Right to Erasure ("Right to be forgotten") (article 17), Right of Restriction of Processing (article 18), the Right for addressees to be notified by the Data Controller of rectification or erasure (article 19), the Right to Data Portability (article 20), and the Right to Object (article 21). You also have the right to withdraw consent given for the processing of data at any time; the withdrawal takes effect from the moment in which COMASTRI DISTRIBUTION S.r.l. becomes aware of it. We remind you that withdrawal, under the GDPR, shall not affect the lawfulness of the processing based on consent given beforehand. Finally, you have the right to file a complaint with a control authority, as specified below. The Italian Authority is the Data Protection Comissioner (Garante per la Protezione dei Dati Personali), whose contact details are accessible at the link http://www.garanteprivacy.it/web/guest/home/footer/contatti.
In all the cases described, the exercising of your rights is brought to the attention of those to whom your data have been communicated, except for the cases of exemption provided for by the GDPR, referring to the reading of all content at the link http://www.garanteprivacy.it/regolamentoue/diritti-degli-interessati In some cases (cancellation, limitation, objection) the exercising of your rights may no longer make it possible, in whole or in part, to follow up your requests formulated by email or through the web form, nor the provision of any services in your favour. All the rights described are exercised with a request made without a formal procedure, or via email to the address email@example.com to COMASTRI DISTRIBUTION S.r.l., or through a designated person, to whom an appropriate response is provided without delay.
RIGHT TO WITHDRAW CONSENT
Parties concerned always have the right to withdraw their previously given consent, in the same way in which they expressed it or in any case by email, by sending the withdrawal notification to the following address firstname.lastname@example.org . The email shall become effective when received and therefore will allow upon receipt thereof to proceed with the interruption of all processing and to the instruction to each manager or person responsible to adapt in this regard. We remind you that any withdrawal of consent does not affect the lawfulness of the processing based on consent before withdrawal.
THE RIGHT TO FILE A COMPLAINT WITH A SUPERVISORY AUTHORITY
Any party concerned has the right in the event of a violation committed to the detriment of their rights and their liberties to proceed with making a complaint to the Italian Data Protection Commissioner via the web by filling out the appropriate form, available on the website www.garanteprivacy.it.
OBLIGATION AND NEED TO PROVIDE YOUR DATA
Except for what is specified for browsing data, users are free to provide us with their personal data or not. Failure to provide the data requested on each page of the COMASTRI DISTRIBUTION S.r.l. website, such as by way of example, name, surname or email address, will make it impossible to obtain the information requested by the user.
PROFILING AND AUTOMATED DECISION-MAKING PROCESSES
Your browsing data will not be used for profiling purposes, nor for activating automated decision-making processes. Data provided voluntarily by the user: The data you voluntarily and willingly provide through the email addresses on the COMASTRI DISTRIBUTION S.r.l. website and/or by filling in forms on specific pages of the COMASTRI DISTRIBUTION S.r.l. website will not be used for profiling purposes, nor to activate automated decision-making processes.
Data processing will be carried out in compliance with the provisions of Article 32 of the GDPR, and will take place with the aid of computer and telematic means, as well as with manuals and paper. Using periodic checks, the Data Controller will verify that the data gathered is strictly relevant and does not exceed the obligations and purposes of processing.
RULES OF CONDUCT – COMMUNICATION AND DISCLOSURE OF DATA
In order to comply with the provisions of current legislation, should the User make inappropriate use of the COMASTRI DISTRIBUTION S.r.l. Site in order to commit offences and/or engage in any criminal conduct, the Data Controller reserves the right to inform the public authorities, in full compliance with the law.