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Website privacy policy

According to Regulation (EU) 2016/679 (General Data Protection Regulation) we provide you the due information concerning the processing of collected personal data. This notice is not to be considered valid for other websites attainable trough links and data processor shall not be held responsible for third parties web pages. 

This notice is provided pursuant to art. 13 of the Regulation (EU) 2016/679 (General Data Protection Regulation) and according to the provisions of the Directive 2002/58/CE, as amended by Directive 2009/136/CE on Cookies, as well as  according to the Provision of the Data Protection Authority dated 08.05.2014 on cookies.

Personal data we may collect and process

Personal data: any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can directly or indirectly be identified, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier or to one or more specific factors to the physical, physiological, genetic, mental, economic, cultural or social identity (C26, C27, C30).

Users’ data

Navigation data: IP addresses, domain name, URI/URL addresses, time and method of the request, response code from server and a few information regarding the useragent (OS version, resolution, devise type).

Voluntarily provided data: The optional, explicit and voluntary transmission of messages to contact addresses or forms, entails the subsequent acquisition of sender's address; the latter, along with any other personal information provided, will be necessary for us to reply.

Social media: For more information regarding the processing of personal data carried out by any Social Media platforms deployed on this website, please refer to their respective privacy policies. The Data Controller processes the personal data through the pages of the dedicated Social Media platforms, to manage interactions with users (comments, public posts, etc.) and in compliance with current legislation.

Specific privacy statement may be furnished with regards to specific processing or services  offered by the website.

Cookies: More information available in the specific statement; please click here

Data Controller

pursuant to art. 4 and 24 of the Reg. (EU) 2016/679, is PAMAR SRL – with registered office in via Sirtori 41, 20838 Renate (MB), represented by the legal representative pro tempore.

 

PURPOSES AND LAWFULNESS OF PROCESSING

A) Website browsing.

Activities strictly related to site operations and to platform browsing service provision. The data required to avail yourself of this website, will be processed as well in order to:

  • Gather statistical information (most viewed pages, number of visitors, timeline visits, geographical source of visit)

  • Monitor the status of services

Legal Basis: Legitimate interest | Data subject rights

Art. 6 lett. f) and recital 47 GDPR: the processing is necessary for pursuing the legitimate interest of data controller or third parties.

Data collected: technical cookies

Data Retention: Single browsing session and up to 7 days after (except from any requests by the Judicial Authority for crime prevention needs).

B) Website Analytics.

By means of cookies and similar technologies

Legal Basis: Cookies other than technical (or similar) require users’ consent in order to be deployed (art. 6.a GDPR) Whether required, the consent will be requested by means of our cookie policy and its banner

Please visit our cookie policy to know about Data Retention and Data Conferral.

C) Contact or information request.

Legal Basis: Legitimate interest | Data subject rights

Art. 6 lett. f) and recital 47 GDPR:

the processing is necessary for pursuing the legitimate interest of data controller or third parties.

Data collected: name, e-mail address

Data Retention: 1 year

D) Newsletter subscription.

Mailing list for promotional communication and related activities.

Legal Basis: Consent

Art 6.1.a) GDPR: the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

Data collected: e-mail address

Data Retention: Until opposition / Unsubscription

E) Download online content (Catalogues)

Legal Basis: Legitimate interest.

Art. 6 lett. f) and recital 47 GDPR:;

Data collected: e-mail address

Data Retention: 1 year

F) Registration to website (member)

Legal Basis: Consent.

Art 6.1.a) GDPR: the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

Data collected: name and surname, e-mail address

Data Retention: until unsubscription.

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA

Personal data provided by you may be communicated to recipients who will act as Processors  (art. 28 of the Reg. EU 2016/679) and/or persons acting under the authority of the Controller and the Processor (art.29 of the Reg. UE 2016/679) for the purposes pointed ahead. Precisely, your data may be communicated to recipients part of the following categories:

  • subjects providing services for the management of the information system used by PAMAR SRL and telecommunications networks:

  • Freelancers,

  • studies or companies in the context of assistance and consultancy relationships;

  • subjects providing services related to the management of the above mentioned purposes (communication, brochure printing, fliers, websites, videos);

  • platform operators for the abovementioned services (websites hosting, etc);

  • Commercial partners, upon consent; 

  • Competent authorities for compliance with legal obligations and / or provisions of public bodies, upon request;

You can request a complete listing of processors writing to the abovementioned addresses.

DATA TRANSFER TO A THIRD COUNTRY AND/OR INTERNATIONAL ORGANISATION

Personal data provided will be transferred to a third Country outside the SEE, within limits and conditions set forth in art. 44 and ff. of the Reg. (EU) 2016/679:

  • Art. 45: towards third countries the Commission has declared to offer an adequate level of protection. Such a transfer shall not require any specific authorisation.

  • Art 46.b: towards subjects the controller or processor provide appropriate safeguards: eg. BCR Binding Corporate Rules within an entrepreneurial group or group of companies;

  • Art 46.c&d: to subjects providing adequate safeguards by means of Commission’s SCC Standard Contractual Clauses;

  • Art 49: the transfer takes place on specific derogations.

Data subject can request a copy of the processing conditions sending an e-mail at privacy@pamar.it

 

AUTOMATED-MEAN PROCESSINGS

Personal data will be manually and electronically processed, as well as by automated-mean activity. It is specified that fully automated decision-making processes are not carried out.

With reference to profiling activity carried out with prior and express consent, it will be carried out through the intervention of operators who will elaborate the profile of the interested party and analyze his habits and consumption choices, in order to improve the commercial offer and data controller’s services (non-automated profiling).

 

DATA SUBJECT’S RIGHTS

You may freely exercise your rights at any time under Reg. EU 2016/679 –GDPR, Sections15, 16, 17, 18, 19, 20, 21 by contacting the Data Controller - PAMAR SRL in person of its legal representative sending an email to privacy@pamar.it.

You have the right, at any time, to obtain confirmation from the Data Controller as to whether or not personal data concerning you are being processed, request their rectification or erasure, to oppose to personal data processing (also to profiling) without prejudice to the lawfulness of processing, to obtain the restriction of processing.

Without prejudice to any other administrative or judicial remedy, in case you consider your data processing in contrast with Reg. UE 2016/679, pursuant to article 15 lett. f) of Reg. UE 2016/679, you have the right to lodge a complaint with a supervisory authority (www.garanteprivacy.it) and, pursuant to article 6 paragraph no. 1, lett. a) and article 9, paragraph no. 2, lett. a), you have the right to revoke your expressed consent at any time.

Exercising your right to data portability, the Data Controller may provide your personal data in a structured, commonly used and machine-readable format subject to the provisions set forth in paragraphs 3 and 4 of art. 20 of Regulation EU 2016/679.

 

Informative amendments: Data processor retains the right to modify, update, add or remove some parts of this informative at any time.

Date of review: September 2023

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