IMEAS S.P.A., with its registered offices in Villa Cortese (20020 — MI), Via Antonio Pacinotti, 36, registered in the Business Register of Milano Monza Brianza Lodi, Taxpayer ID No. 00215070129 and VAT No. 13480470155, in person of its legal representative and Chairman of the Board of Directors Mr. Franco Zenere (Taxpayer ID No. ZNRFNC42S29B286Q), born in Bruscate (MI) on November 29, 1942, as Controller of the treatment of personal data (hereinafter, «IMEAS» or «Controller») pursuant to articles 4 and 28 of Legislative Decree no. 196 of 30 June 2003 — Privacy Code (hereinafter «Privacy Code») and articles 4, n. 7) and 24 of the EU Regulation 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data (hereinafter, «Privacy Regulation») informs you, pursuant to the art. 13 of the Privacy Code and Privacy Policy, that your personal data is collected and processed by IMEAS for purposes directly connected and essential to the provision and management of services offered by the present website (hereinafter «website»). The supply of your personal data is necessary for the provision of services by IMEAS, therefore the failure to provide, even partially, such data will create obstacle or even impossibility for IMEAS to proceed with the provision of services. By the procedure of processing of personal data, we mean any operation or set of operations, whether or not performed by automated means and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, communication by transmission, dissemination or any other form of provision, comparison or interconnection, limitation, cancellation or disclosure of personal data.
Therefore, we inform you that the data will be processed manually and/or with the support of computer or telematic tools for the following purposes.
- Primary purposes of the processing of personal data.
- First of all, the processing of personal data requested that you are required to indicate when registering for the website is aimed at making it possible for the provision of the services for the part of IMEAS allowing you to access and browse within the website pages. The processing of your personal data could be also aimed at providing you with pre-contractual information or services, including but not limited to providing replies to data subject’s queries.
- The above-mentioned personal data will be processed only for granting your access, the browse and the registration within the website in light of requesting information or clarification about IMEAS and its products.
- Your personal data (excluding sensitive data) processed by IMEAS are only those requested to perform the above-mentioned purposes and, in particular, common personal data could be processed, such as name, surname and e-mail of the data subject. The process does not in any case include personal data which might be classified as “sensitive” or “particular data”.
- Purpose of fulfilling obligations under the law, regulations or EU regulations.
2.1 Secondly, your personal data (general and sensitive data) will also be processed in order to fulfil legal, regulatory or Community law obligations.
- Mandatory or optional consent for the processing of personal data for the primary purposes.
3.1 On the basis of the applicable provision of the Privacy Code and Privacy Regulation, for the purposes described above in paragraphs 1 and 2 of the present privacy policy, the Controller is not requested to obtain specific consent for the processing of general data of users who registered for the website. The above-mentioned processes of data for the primary purposes, as mentioned in Article 24 of the Privacy Code and Article 6 of the Privacy Regulation, exclude the need to obtain a specific consent of the user. That is for the following reasons: either because the processing is necessary to comply with an obligation provided by law, regulation or EU legislation, or the processing of data derives from a contract (in the case at hand: general terms and condition regarding the access and the browse of IMEAS website) to which the data subject is a party or in order to fulfil, prior to the conclusion of the contract, specific requests of the data party or — finally — because the processing of data pursues administrative-accounting objectives within the meaning of art. 34 iter of the Privacy Code.
3.2. Whether the subject data does not intend to authorize the data process which are necessary to perform the activities of the Controller for the purposes listed above, as a consequence no access to the website should be granted.
- Communication and dissemination of personal data for the primary purposes.
4.1 The data processed for the purposes lay down in previous Paragraph 1 may be communicated to any other third party when the disclosure is required by law, including the purpose of prevention/repression of any illegal activity connected with access to the website.
4.2 With reference to art. 13, Paragraph 1, letter (d) of the Privacy Code and Art. 13, paragraph 1, letter (e) of the Privacy Policy, the persons or categories of persons who may become aware of the user’s personal data in their capacity as managers or agents are set out below together with a list of categories:
- IMEAS staff, appointed as data processor;
- third parties involved by IMEAS in the management of the website and appointed as responsible for the treatment.
4.3. Personal data will not be the subject of disclosure.
- Data retention times and other information.
5.1 The personal data of users who register on the website will be kept for the time strictly necessary to carry out the primary purposes illustrated in Paragraph 1. Following the access to the website, the personal data will be stored in IMEAS datacenter in order to answer to possible queries by the data subject and to perform law provisions. If a user of the website, after being disconnected from the website requests the cancellation of his/her personal data, exercising the rights provided in Paragraph 7, . it will be impossible for IMEAS to respond to any requests made by the interested party.
5.2. The five year or ten-year retention periods for documents and related data of a civil, accounting and fiscal nature remain unaffected, as provided for by the laws in force.
5.3. The collected data is processed within the registered office and operating offices of the Processors of the treatment.
5.4. Pursuant to art. 13, Paragraph 1, letter (f) of the Privacy Policy, we inform you that all data collected will not be transferred to a third country or an international organization either inside or outside the European Union.
- Data Controller and Data Processors
The identification details of the Controller are the following:
IMEAS S.P.A.,
Villa Cortese (20020 — MI), Via Antonio Pacinotti, 36,
- +39 0331 4630 11 and telefax +39 0331 4323 11
email address for the exercise of data subject’s rights pursuant to the art.7 of the Privacy Code: email: privacy@imeas.it
The updated list of the persons in charge — if appointed — of the treatment is available at the indicated office.
- Exercise of rights by the data subject
7.1 Pursuant to article 7 of the Privacy Code and pursuant to articles 13, paragraph 2, letters (b) and (d), 15,18,19 and 21 of the Privacy Policy, we inform you that:
- a) you have the right to request the Controller of the treatment the access to personal data, rectification or cancellation of the same or the limitation of the processing that concerns you or to refuse their treatment, in addition to the right of data transfer;
- b) you have the right to lodge a complaint before the Data Protection Authority, following the procedures and instructions published on the official website of the Authority on garanteprivacy.it.
- c) any rectification, cancellation or restriction of the processing carried out at your request — unless this proves impossible or involves a disproportionate effort — will be communicated by the Controller to each of the recipients to whom the personal data have been transmitted. The Controller may inform you of such recipients at your request.
7.2 The exercise of the rights is not subject to any formal requirement and is free of charge.
7.3 For practical purposes, article 7 of the Privacy Code is provided below, while articles 15 to 23 of the Regulations can be accessed following this link:
http://eur-lex.europa.eu/legal-content/IT/TXT/HTML/?uri=CELEX:32016R0679&from=IT
ARTICLE 7 OF THE PRIVACY CODE
Art.7
(Right of access to personal data and other rights)
- The data subject has the right to obtain confirmation of the existence or otherwise of personal data concerning him/her, even if not the party is not yet registered, and their communication is in an intelligible form.
- The data subject has the right to obtain the information on:
- a) the origin of personal data;
- b) the purposes and methods of processing;
- c) the logic applied in the case of processing carried out using electronic tools;
- d) the identification details of owner, managers and representative appointed pursuant to article 5, paragraph 2;
- e) the subjects or categories of subjects to whom personal data may be communicated or who may become aware of it thought their position: representative in the territory of the State, managers or persons in charge.
- The data subject has the right to obtain:
- a) the update, correction or, where relevant, integration of data;
- b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including the data the retention of which is not necessary for the purposes the data was collected or processed further;
- c) certification that the operations referred to in letters a) and b) have been notified, also with regard to its content and to whom the data have been communicated or disseminated, unless this requirement proves to be impossible or involves the use of means manifestly disproportionate with respect to the right protected.
- The data subject has the right to oppose, in whole or in part:
- a) for legitimate reasons to the processing of personal data concerning him/her, although pertinent for the purpose of collection;
- b) the processing of personal data concerning him/her for the purpose of provision of advertising material, direct selling, carrying out market research or any commercial communication.
To exercise your rights you can download, complete and send the appropriate form (download here) to the address indicated in point 6.