Privacy information pursuant to article 13 of EU Regulation no. 2016/679 (hereinafter, “GDPR”)

EU Regulation no. 2016/679 protects the confidentiality of personal data to protect the freedom and rights of interested parties and therefore imposes a series of obligations on those who "process" personal information relating to other subjects. Among the most important

obligations that the law requires to be respected, there is that of informing the interested parties and acquiring their consent to the processing in the prescribed cases, especially for the processing activities in relation to which the data must be communicated to other subjects.

In light of the above, therefore, we would like to inform you, pursuant to article 13 of the GDPR in question, that the undersigned company collects and processes data concerning your company without your express consent (art. 24 letter a) , b), c) Privacy Code and art. 6 lett. b), e) GDPR for purposes related to the management of ordinary commercial relationships and, precisely, for the compilation of personal data lists, the keeping of customer/supplier accounts, invoicing, the management of the creditor for the satisfaction of all the obligations established by the regulations in force.

The processing of your personal data is carried out by means of the operations indicated in the art. 4 Privacy Code and art. 4 no. 2) GDPR and precisely: collection, recording, organisation, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subjected to both paper and electronic and/or automated processing.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no longer than 10 years from the termination of the relationship for administrative/accounting purposes.

The processing may be carried out using both IT and manual tools, in compliance with all the precautions necessary to guarantee the security and confidentiality of the information.

Furthermore, your data may be communicated to third parties, exclusively for technical and operational needs strictly connected to the purposes set out above and in particular to the following categories of subjects:

1. bodies, professionals, companies or other structures entrusted by us with processing related to the fulfillment of administrative, accounting and management obligations linked to the ordinary performance of our economic activity, also for credit recovery purposes;
2. to public authorities and administrations for purposes related to the fulfillment of legal obligations;
3. banks, financial institutions or other subjects to whom the transfer of the aforementioned data is necessary for the performance

of our company's activity in relation to the fulfillment, on our part, of the contractual obligations assumed towards you.

In your capacity as an interested party, you have the rights referred to in the art. 7 Privacy Code and art. 15 GDPR and precisely the rights of:

1. obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
2. obtain indication of: a) the origin of the personal data; b) the purposes and methods of processing; c) of the logic applied in case of processing carried out with the aid of electronic instruments; d) the identification details of the owner, managers and representative designated pursuant to art. 5, paragraph 2 Privacy Code and art. 3, paragraph 1, GDPR; e) of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representatives in the territory of the State, managers or agents;

• obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed; c) certification that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which this requirement is proves impossible or involves a manifestly disproportionate use of means compared to the protected right;

Methods of exercising rights

You can exercise your rights at any time by sending:

• an e-mail to the address: AMMINISTRAZIONE@WALCOR.IT

The data controller is Mr. Walter Bucceroni domiciled at the company's registered office.

The appointed DPO is Dr. Paolo Franco, who can be contacted at PFRANCO@ARUBAPEC.IT

The updated list of data controllers and persons in charge of processing is kept at the registered office of the Data Controller.

Rome 02/01/2022

CUSTOMER'S AND PROVIDER'S DATA PROTECTION POLICY

General Data Protection Regulation 2016/679 EU (GDPR) articles 13 and 14

1. Definitions

Where mentioned in the Information, the terms below have the meanings indicated below.

- Data Controller - Data Controller.

The subject (the natural or legal person, public authority, service or other body) who, individually or together with others (Joint Controller - Joint data controller), determines the purposes and means of the processing of personal data.

- Data Subject - Interested

The identified or identifiable natural person to whom the data refers.

- Personal Data - Personal data.

Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more elements characteristic of his or her physical identity, physiological, genetic, psychological, economic, cultural or social.

- Identifiable Data - Common/identifying data

E.g. personal data (name, surname, date of birth, citizenship, marital status, address, professional qualification); identity documents (CdI, driving licence, passport); tax identification codes (CF, VAT number for natural persons); contact data (phone number, email address, physical address); worker identification codes (serial number, access credentials to IT systems); bank details (CC number, IBAN code); license plate; multimedia data (video, audio); Internet browsing data (cookies, logs, IP address); geolocation data; profiling data.

- Special Data - Special data

E.g. data suitable for revealing ethnic or racial origin, membership of parties, trade unions, religious or philosophical organisations; genetic data; biometric data; data relating to health (e.g. pregnancy, illness, belonging to protected categories). Judicial data, such as. data relating to criminal convictions, crimes and related security measures (criminal records, register of administrative sanctions dependent on crime and related pending charges).

2. Data Controller (Data Controller)

Data Controller WALCOR SRL - ROME

3. Categories of interested parties and personal data collected

Walcor Srl collects personal data from its Customers and Suppliers, existing and potential, consisting of commercial and contact data of their directors, employees and collaborators, specifically belonging to the category of so-called "Identifying" Data, such as surname and name , email address, telephone/mobile number, etc. Any collection of personal data not listed in this Policy will be preceded (where applicable) by adequate communication regarding their type, as well as the purposes and methods of their processing.

With the exception of some information required by law, the interested party's decision to provide us with his/her personal data is voluntary, but is necessary and indispensable for the execution of contracts and supplies requested/provided by Walcor Srl.

Generally, so-called data is collected. special or judicial data: in the limited cases where this becomes necessary, the collection takes place in compliance with the current regulatory requirements regarding data protection in force and with the express consent of the interested party.

The interested party who provides us with personal data of another person (for example a contact person in your organization) is required to guarantee that this person is informed of the contents of this Information and that he or she has given, even if only verbally, consent to the sharing of the data. your personal data with Walcor

The personal data referred to in this Policy are provided directly by the interested party (for example to receive information on our services or sign a supply contract) or obtained indirectly through third parties such as public administration, websites, other third-party companies.

4. Purpose of the processing

The personal data provided by the interested party are processed by Walcor Srl . for the execution of contracts; the supply/request for supply of Walcor products and services; the sending of commercial information relating to the quality of the services provided/received or to their cancellation or termination; requests to receive/send newsletters or other commercial and business content; improving Walcor 's interaction with Customers and Suppliers; compliance with accounting, administrative and tax obligations, and all other obligations required by current laws or requested by competent authorities.

5. Personal data collected for marketing purposes

The collection and processing of personal data for marketing purposes is based on Walcor's legitimate interests or balancing of interests.

Most of the personal data collected for marketing purposes refers to individual administrators, employees/collaborators of Walcor Customers and Suppliers.

The purposes of collecting this data are: sending e-mails about the Company's services; carrying out market research; creation of first contacts, customer and supplier loyalty; statistical and analytical purposes; maintaining and managing relationships with customers and suppliers.

6. Transfer to Third Parties

Walcor Srl may transfer the personal data processed to public and governmental authorities in fulfillment of the obligations established by law or regulations and upon request by the competent authorities.

In such cases Walcor Srl adopts all necessary measures to ensure that personal data are adequately protected, in compliance with the requirements of EU Reg. 679/2016 and the internal procedures regarding Data Protection adopted by the Company , even if the recipients of the data reside in foreign countries, within the EU or outside the EU.

7. Storage and deletion of data

Walcor Srl retains personal data for the time strictly necessary to achieve the purposes referred to in point 4. of this Information, in compliance with legal and contractual obligations.

After this time, the data is deleted from all IT media. For paper documents they will be safely shredded by the designated person. Waste will be periodically collected only by authorized personnel for disposal.

During the entire time of storage, personal data are protected through suitable technical and organizational measures and procedures for the safe management and storage of Walcor Srl databases

8. Rights of interested parties

In the circumstances and under the conditions established by EU Reg. 679/2016 and subsequent amendments, the interested parties referred to in point 3 of this Information have the right to:

• obtain confirmation of the existence or otherwise of personal data concerning them;
• request rectification of their personal data if it is inaccurate or incomplete;
• request the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
• request certification that the operations referred to in the two previous points have been brought to the attention, also with regard to their content, of those to whom the data were communicated and transmitted, except in the case in which this fulfillment proves impossible or involves a use of means that is manifestly disproportionate to the protected right;
• object to the processing of personal data;
• request the deletion of personal data even if they are no longer suitable for processing;
• request the limitation of the processing of personal data so that they are processed only in limited circumstances, including with the consent of the interested party;
• request the portability of personal data or exercise the right to receive a copy in an intelligible form or request its transmission to another Data

To the extent that the processing of personal data is based on implicit or explicit consent, the interested party has the right to revoke such consent at any time by contacting the certified email address PFRANCO@ARUBAPEC.IT

This will not affect Walcor Srl 's right to process personal data obtained before the withdrawal of consent or the right to continue parts of the processing for compliance with legal or contractual obligations.

Walcor Srl informs the recipients of this information of the possibility of contacting the Guarantor for the protection of personal data or other competent authorities for any complaint arising from the processing of their personal data by our Company.

PRIVACY POLICY FOR USERS OF SOCIAL NETWORKS EX ART. 14, REGULATION (EU) 2016/679 (“GDPR”)

This information concerns the processing of personal data of users of social networks such as Facebook, Instagram, and other similar networks or portals (hereinafter "Social Networks") who, through their social accounts, interact with the accounts, pages social network of WALCOR SRL with registered office in Via Tor Sapienza- 00155 Rome (hereinafter "WALCOR"), or browse the Walcor website.

The information refers exclusively to the processing operations carried out by WALCOR: in fact, the data is collected and processed primarily by the Social Network where the users are registered (which acts as Data Controller of its users' data); however, when the user interacts with WALCOR's social profile, social pages or website, WALCOR may receive a small fraction of such data from the Social Network, with respect to which Angelini assumes the status of "independent data controller": this means that the Social Network and WALCOR independently decide the purposes and methods with which they process the data of the users to which they have access respectively.

The treatments carried out by WALCOR will be described below. If, however, you wish to have information about the processing carried out by the Social Network to which you are registered, you are invited to read the relevant Privacy Policy, accessible via your profile.

The Social Network may also make information available to WALCOR on activities and preferences expressed while browsing the internet, to the extent that the user has permitted this via the settings of their profile and browser. The collection of such data can also take place with tools such as cookies, web beacons and pixel tags: we therefore invite you to check the settings of your browser, your profile on Social Networks or the privacy/cookie information on the sites visited for more information. It should be noted that when these tools are present on WALCOR sites, the relevant information is contained in the respective privacy and cookie policies.

The processing that WALCOR carries out with respect to these data is limited to navigation data and therefore the Company collects these and other data (such as, for example, the number of visits and the time spent on the Site) only for statistical purposes and in anonymous form at order to check the functioning of the Site.

The data will be processed for the purpose of:

- respond to posts, requests and questions from users, and allow users to participate in activities carried out through the Page and interact with it; manage and optimize the contents of the Page, carry out statistical and market analyzes on the users who interact with the Page or with our Sites. The legal basis of the processing is Angelini's legitimate interest in promoting its activities and its corporate image (art. 6.1.f GDPR);

- fulfill regulatory obligations, pursuant to art. 6.1.c of the Regulations. The legal basis of the processing is the legitimate interest of the Company to prevent abuses committed by users through the page, including behavior contrary to the codes mentioned above, violations of applicable regulations and to protect their rights (art.6.1.f and 9.2.f GDPR) .

- send personalized messages ("profiling") relating to the activities carried out, products and services specified in the previous point. The legal basis of the processing is the user's consent, expressed to the Social Network, also in combination with cookies, etc (art. 6.1.a of the GDPR);

- with regards to the data collected in relation to job position advertisements published via Social Networks, evaluate and possibly establish a collaboration or work relationship: the legal basis of the processing is the execution of a contract or pre-contractual measures aimed at conclusion of a contract with the user (art. 6.1.b of the GDPR).

With regards to the publication of any third party data, it is the user's responsibility to obtain the necessary consent and fulfill any information duties required by the applicable privacy legislation.

Regarding the consent to the processing of user data deduced from the accounts on the Social Networks, it is specified that: (i) these are given by the user at the time of registration on the Social Network, who can modify/personalize them at any time.

The user's data will be processed with mainly electronic tools, and may be entered into the WALCOR information system in compliance with the applicable legislation, including security and confidentiality profiles and inspired by the principles of correctness and lawfulness of processing. The data will be kept for the period strictly necessary to achieve the purposes for which they were collected; in any case, the criterion used to determine this period is based on compliance with the terms permitted by applicable laws and the principles of minimization of processing and rational management of archives.

The data may be processed by WALCOR staff assigned to IT, HR, administrative functions and other duly authorized subjects who need to process them due to their duties.

The user may exercise the rights recognized by the articles. 15-22 of the GDPR, including: obtaining confirmation of the existence or otherwise of data concerning him, accessing such data, verifying its content, origin, accuracy, location, requesting a copy, integration, updating, rectification and, in the cases provided for by current law, limitation, cancellation, transformation into anonymous form, opposition to direct contact activities (even limited to some means of communication), opposition to processing for legitimate reasons.

To exercise your rights, the user can contact the data controller WALCOR by contacting its DPO, in the person of Dr. Paolo Franco, at pfranco@aruba.pec.

Finally, the user can lodge a complaint with the Guarantor for the Protection of Personal Data, following the procedures and instructions published on the Authority's official website at www.garanteprivacy.it ;

The exercise of rights is not subject to any formal constraints and is free.

To revoke consent to the processing provided to Social Networks, it is necessary to interface directly with the Social Networks themselves.

 

Information provided pursuant to articles 13-14 of the GDPR (General Data Protection Regulation) 2016/679

 

Dear user,

in compliance with the provisions of the European Regulation 2016/679 (GDPR), WALCOR SRL wishes to inform you that the personal data provided by you or acquired by us as part of our activity, necessary to carry out the services offered to you, will be processed in compliance with the legislation on privacy and the principles of correctness , lawfulness , transparency and protection of your privacy and your rights.

We would also like to provide you with the following information:

 

1. DATA CONTROLLER is the undersigned WALCOR SRL, a company based in Rome (00155, Italy), in Via di Tor Sapienza n. 64, contactable at the following numbers: telephone 06-2284544, e-mail privacy@walcor.it, pec walcor@pec.it
The DPO (Data Protection Officer) Dr. Paolo Franco is responsible for data protection and can be contacted at the following numbers: telephone 347.3999696, e-mail pfranco@arubapec.it.

 

2. DATA PROCESSED, PURPOSE AND LEGAL BASIS OF THE PROCESSING

2.1.The legal basis that legitimizes the processing of such data is the need to make the functions of the company website usable as a result of the User's access.

2.2. The data provided voluntarily by the User are those necessary for the Owner to provide the available services and are processed in a lawful and correct manner, furthermore they are collected and recorded for the specific, explicit and legitimate purposes indicated below and are used in operations of processing that are not incompatible with these purposes.

Personal data (personal identification data such as, for example: name and surname, company name, tax code and VAT number, address, telephone / fax, e-mail, bank and payment details) are collected and processed:

  in the presence of specific distinct consent of the User , for the following marketing purposes: to send (via e-mail, post, text message or telephone contact) newsletters, updates, advertising material or commercial communications.

 

3. METHODS OF TREATMENT

The processing of the User's personal data is carried out by means of the following operations: collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.

The User's personal data is collected following direct sending to the Data Controller, by filling in forms or modules generally prepared for this purpose, also included in contractual documents, or collected by telephone by the operator as part of pre-contractual activities. The data is processed both through manual processing in paper format and with electronic or automated, IT and telematic tools. The data collected are recorded and stored by the Data Controller in computer and paper archives, as well as kept and controlled in such a way as to minimize the risks of destruction or loss, even accidental, of unauthorized access and of processing that is not permitted or does not comply with the purposes. of the collection.

The data is processed by employees or collaborators of the Data Controller, duly trained in this regard.

 

4. NATURE OF DATA COMMUNICATION

The provision of personal data relating to processing is optional. However, failure to provide the data, partially or totally, may result in the partial or total impossibility of establishing or continuing the relationship with the User, to the extent that such data is necessary for the execution of the same.

The provision of data for marketing purposes is also optional. The User can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case he will not be able to receive newsletters, commercial communications and advertising material in general relating to the services offered by the Owner.

 

5. RECIPIENTS OR ANY CATEGORIES OF RECIPIENTS OF PERSONAL DATA

The processing of the User's data is carried out by internal staff of the Owner (employees, collaborators, System Administrators), identified and authorized for processing according to instructions given in compliance with current legislation on privacy and data security.

If this is necessary for the purposes listed in article 2, the User's personal data may be processed by third parties appointed as Data Controllers (pursuant to Article 28 of the GDPR) or "independent" Data Controllers, namely:

1. by the SEAC Group Companies for the purposes referred to in article 2.2. letter “d”;

2. by professionals, companies, associations or professional firms that provide the Data Controller with assistance or consultancy for administrative, accounting, tax purposes, or legal protection or personnel selection;

3. by all the public institutions established by law and more generally by all the bodies envisaged by current legislation on accounting and tax matters as recipients of mandatory communications;

4. from banking institutions for collections and payments as well as from any professionals - in single, associated or corporate form - for analysis and market research services, for the management of payments via credit cards or electronic payment instruments in general, couriers postal mail, for any debt collection or for certification activities of the Owner's balance sheet.

The updated list of data processors and persons in charge of processing is kept at the registered office of the Data Controller.

In any case, the User's personal data are not subject to disclosure.

 

6. TRANSFER OF DATA TO A THIRD COUNTRY OR INTERNATIONAL ORGANIZATIONS

As part of the management of the contractual relationship, no transfer of the User's data to third countries outside the EU or to international organizations is envisaged.

 

7. PERIOD OF CONSERVATION OF PERSONAL DATA OR CRITERIA USED TO DETERMINE THIS PERIOD

For marketing purposes, the User's personal data will be processed and stored by the Owner until the User revokes consent or until the User exercises the right to object to processing or the right to cancellation. of personal data.

8. USER RIGHTS

In your capacity as interested party and in relation to the processing described in this Information, the User has the rights referred to in articles 7, 15 to 21 and 77 of the GDPR and, in particular, the:

• right of access – article 15 GDPR: right to obtain confirmation as to whether or not personal data concerning the User is being processed and, if so, obtain access to such personal data, including a copy of the same;

• right of rectification – article 16 GDPR: right to obtain, without unjustified delay, the rectification of inaccurate personal data concerning the User and/or the integration of incomplete personal data;

• right to cancellation (right to be forgotten) – article 17 GDPR: right to obtain, without unjustified delay, the deletion of personal data concerning the User;

• right to limit processing – article 18 GDPR: right to obtain the limitation of processing, when: the interested party disputes the accuracy of the personal data, for the period necessary for the Data Controller to verify the accuracy of such data; the processing is unlawful and the interested party opposes the deletion of the personal data and requests instead that their use be limited; the personal data are necessary for the interested party to ascertain, exercise or defend a right in court; the interested party has objected to the processing pursuant to art. 21 GDPR, in the period of waiting for verification regarding the possible prevalence of legitimate reasons of the Data Controller with respect to those of the interested party;

• right to data portability – article 20 GDPR: right to receive, in a structured format, commonly used and readable by an automatic device, the personal data concerning the User provided to the Data Controller and the right to transmit them to another Data Controller without impediments, if the processing is based on consent and is carried out by automated means. Furthermore, the right to have the User's personal data transmitted directly to another Data Controller if this is technically feasible;

• right to object – article 21 GDPR: right to object, at any time for reasons related to your particular situation, to the processing of personal data concerning you based on the condition of lawfulness of legitimate interest or the execution of a security task. public interest or the exercise of public powers, including profiling, unless there are legitimate reasons for the Data Controller to continue processing which prevail over the interests, rights and freedoms of the interested party or for the assessment, exercise or defense of a right in court. Furthermore, the right to object at any time to processing if personal data is processed for direct marketing purposes, including profiling, to the extent it is connected to such direct marketing;

• right of revocation – article 7 GDPR: the User has the right to withdraw his consent at any time. The revocation of consent does not affect the lawfulness of the processing based on consent before the revocation;

• right to complain – article 77 GDPR: the User has the right to lodge a complaint with the Guarantor Authority for the protection of personal data, Piazza di Montecitorio 121, 00186, Rome (RM).

 

9. HOW TO EXERCISE RIGHTS

The User may exercise their rights at any time by sending a registered letter to:

WALCOR SRL, a company based in Rome (00155, Italy), in Via di Tor Sapienza n. 64. To exercise the rights as indicated in this Policy as well as to receive any information relating to them, the User may contact the Owner or the DPO who, also through the designated structures, will take charge of the request and provide the The User, without unjustified delay and in any case, at the latest, within one month of receipt of the same, information relating to the action taken regarding the request.

The exercise of rights by the User is free pursuant to Article 12 GDPR. However, in the case of manifestly unfounded or excessive requests, also due to their repetitiveness, the Owner may charge the User a reasonable fee, in light of the administrative costs incurred to manage his request, or deny satisfaction of his request.

 

The last modification to this Privacy Policy was made on 07.26.2018.

Cookie Policy

Cookies consist of portions of code installed within the browser that assist the Owner in providing the Service based on the purposes described. Some of the purposes of installing Cookies may also require the User's consent.

When the installation of Cookies is based on consent, this consent can be freely revoked at any time by following the instructions contained in this document.

Technical and aggregate statistics cookies

• Activities strictly necessary for operation
• Preference saving, optimization and statistics activities

Other types of Cookies or third-party tools that may install them

Some of the services listed below collect statistics in aggregate and anonymous form and may not require the User's consent or may be managed directly by the Owner - depending on what is described - without the help of third parties.

How can I express consent to the installation of Cookies?

In addition to what is indicated in this document, the User can manage preferences relating to Cookies directly within their browser and prevent - for example - third parties from installing them. Through the browser preferences it is also possible to delete Cookies installed in the past, including the Cookie in which the consent to the installation of Cookies by this site is possibly saved. The User can find information on how to manage Cookies with some of the most popular browsers, for example at the following addresses: Google Chrome , Mozilla Firefox , Apple Safari and Microsoft Internet Explorer .

Data Controller

The data controller is WALCOR SRL, in the person of its legal representative pro tempore, electively domiciled at the Walcor headquarters at the aforementioned address.

Owner's email address: privacy@walcor.it

Since the installation of Cookies and other tracking systems operated by third parties through the services used within www.walcor.it cannot be technically controlled by the Owner, any specific reference to Cookies and tracking systems installed by third parties is to be considered indicative. To obtain complete information, the User is invited to consult the privacy policy of any third party services listed in this document.

Given the objective complexity of identifying the technologies based on Cookies, the User is invited to contact the Owner should he wish to receive any further information relating to the use of the Cookies themselves via www.walcor.it