Information on the processing of personal data pursuant to and for the effects of articles 13 and 14 of EU Regulation n. 2016/679 and Legislative Decree 196/03 s.m.i
La Torrente Srl is committed to respecting and protecting the privacy of its users and wants you to feel safe, both during the simple consultation of the application, which in case you decide to register us by providing your personal data to use our services. We therefore invite you to read this information carefully to know how we process and protect the personal data entrusted.
Please note that this information is provided only for the website www.latorrente.it and not for other web spaces accessible through any other links on the website, with its own policies of protection of personal data that the user can consult by accessing the respective websites.
La Torrente Srl, with registered office in Sant’Antonio Abate, Via Paludicella n. 23 – 80057- (NA) as Data Controller, informs, pursuant to and for the purposes of Legislative Decree 196/2003 Privacy Code , as amended by Legislative Decree 101/ 2018 laying down Provisions for the adaptation of national legislation to the provisions of Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data, as well as the free movement of such data and repealing Directive 95/46/EC (hereinafter referred to as “GDPR” for the sake of brevity), that the data provided by the user or collected through our website will be processed in accordance with the provisions of this policy.
This statement also fully respects and complies with Recommendation No. 2/2001, which the European Data Protection Authorities adopted on 17 May 2001 to identify certain minimum requirements for the collection of personal data online and, in particular, the manner, timing and nature of the information that data controllers must provide to users when they connect to web pages, regardless of the purpose of the link.
It is specified that the consent mechanisms will be clear, short and easily understandable; if the original conditions for which consent has been requested are subject to changes, for example if the purpose of data processing changes, We will seek further consent.
The services offered through the site, are aimed at companies and/ or exclusively to individuals who have reached the eighteenth year of age. The data controller does not intentionally collect information and personal data relating to minors and does not knowingly use the service to process personal data relating to minors for profiling purposes. Should such an event occur, the Data Controller will immediately delete all personal data involuntarily collected in relation to minors.
The site also allows interaction with social networks or other external platforms (Facebook, Twitter, Google +, Linkedin, Flickr, Vimeo, and Google Map) each of which, if used through the site, could collect and process data on user traffic, even from places outside the European Union. The interactions and information acquired, are in any case subject to the User’s privacy settings related to each social network. Therefore, before interacting with these web platforms, the user is encouraged to consult the information on the processing of data on each of them and only subsequently decide whether to use them through the site.
1) Type of Data Processed
Our website www.latorrente.it offers informative and interactive content. During the navigation you can then acquire information about the user. Among the Personal Data collected by this website, independently or through third parties, there are: Usage data, Cookies, Data provided voluntarily by the user.
1.1 Navigation data and cookies
The computer systems and software procedures responsible for the operation of this website, acquire automatically during their normal operation, some data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified users, but by their very nature could allow the identification of the user, through processing and association with other data held by third parties. This category of data includes: IP addresses or domain names of computers used to connect to this Application, addresses in URI notation, the time of the request, the method used to forward the request to the server, the numerical code indicating the status of the response from the server (successful, error, etc.), the browser and operating system characteristics used the various temporal connotations of the visit (for example, the time spent on each page, etc.) and other parameters related to the user’s operating system and computer environment. These data are automatically acquired by the technological systems of the site , being indispensable for navigation purposes , and are processed for the sole purpose of obtaining anonymous statistical information on the use of the site, check its correct functioning, and ascertain liability, in the case of hypothetical computer crimes against the owner (legitimate interests of the owner ) .
1.2 Data provided voluntarily
The optional, explicit and voluntary sending of personal data within the various forms on our site , subject to express acceptance of the consents provided in the appropriate sections , involves the subsequent acquisition of the personal data entered, in order to satisfy the requests of the user and offer the services and products made available on our site.
The personal data provided by users when completing the information request form, belong to the category of common personal data, and do not include sensitive data, health, genetic, biometric, judicial, or data referred to in Article. 9 and 10 of EU Regulation no. 2016/679,the processing of the latter categories of data is not necessary for the purposes of the processing. The data that the user will enter for the completion of the electronic form of information request, and that will be acquired by the Owner, are: name, surname, e-mail address, telephone number. Sending the request, subject to acceptance of specific, free and informed consent, will allow the Data Controller to process the data voluntarily entered by the user in the “message” section of the information request form, as well as any other data that will be communicated spontaneously by e-mail, including the e-mail address of the sender. In any case, only personal data strictly necessary for the pursuit of specific and legitimate purposes, in respect of which the processing will always be relevant and never excessive, will be processed.
The registration on our website, allows us to guarantee the user to proceed with the purchase of our products, to manage his account and to comply with legal obligations ( accounting and tax) to which the owner is subject. The personal data provided by users at registration, belong to the category of common personal data, and do not include sensitive data, health, genetic, biometric, judicial, or data referred to in Art. 9 and 10 of GDPR 2016/679, as the processing of these latter categories of data is not necessary for the pursuit of the purposes of processing. The data that the user will enter voluntarily and that will be acquired by the owner, are the e-mail address and all the data provided to allow the execution of a purchase order, the compilation and use of the account on the site and the delivery of products with the communication of data relating to numbers or contact addresses (e.g. telephone, email, addresses) as well as any names of the recipients of orders, if different from the buyer. All information and financial information regarding your credit card and/or paypal account, will not be handled in any way by www.latorrente.it , as at the time of payment the user will be redirected directly to the portal of the bank and/ or paypal that will guide him , in total security, to enter the data to proceed with the payment. Therefore, the torrent does not deal with any information regarding credit cards and other. In any case, only personal data strictly necessary for the pursuit of specific and legitimate purposes, in respect of which the processing will always be relevant and never excessive, will be processed.
2) Source of personal data
The c.d. “navigation” data referred to in point 1.1 above are automatically acquired by the software procedures used to operate the site.
The personal data referred to in point 1.2 above are provided by users by filling in special electronic forms on the pages of the site, or by sending spontaneous communications.
3) Purpose of the processing
Except as specified in point 1.1 above with regard to the c.d. “navigation” data, the personal data provided by users may be processed for the following purposes:
a) for service purposes and in particular
- to satisfy requests submitted and perform specific pre-contractual activities that the user may wish to perform (for example, the preparation of an estimate);
- to manage orders and carry out related activities (e.g.: order status reports, billing, assistance and technical support, etc.);
- to manage the user account in case of registration to the Site to use the related services;
- improve technical assistance, customer care, illustration of our products and services;
- carry out any aggregated statistical analysis on an anonymous basis.
b) The Data Controller will use the data provided by the user to protect its legitimate interests in the following cases:
- handling complaints and litigation, preventing fraud and illegal activities;
- exercise rights and protect his legitimate interests, such as the right to a fair hearing;
c) For the fulfillment of legal obligations the data will be used for:
- omply with and comply with the obligations laid down in laws, regulations, Community regulations, orders and requirements of the competent authorities.
d) Only in the presence of a separate express consent, for other non-service purposes, or for commercial, advertising, promotional and marketing purposes in the broad sense, which involve processing:
d.1) for the sending of communications of information relating to new product offers, of a commercial nature and/or of commercial solicitation (Newsletter) by the Data Controller.
d.2) for profiling activities, that is to analyze preferences and interests (for example, preferred contents, purchases, etc.), and propose initiatives and commercial offers customized on the basis of the same (with email and newsletter)
If the user wishes to object to the processing of your data for marketing and profiling purposes, as well as revoke the consent given, may do so at any time, by sending, without formalities, an e-mail to the addresses specified below, without prejudice to the lawfulness of the processing based on the consent given before the revocation. We also point out that if you are already our customer, you may receive commercial or marketing communications relating exclusively to services and products similar to those of which you have already benefited, subject to your objection, to practice by sending an email to the addresses specified below.
Unless explicit consent is given, no processing of personal data is provided for purposes other than those mentioned above.
We point out that they are not in ns. possession data defined by the aforementioned Dlgs. 196/03 s.m.i come ” details “that is, suitable to reveal the state of health, membership in trade unions, religious and philosophical beliefs, sex life, membership in political parties etc.
4) Expression of consent
The consent to the processing of personal data, where required, is given by the interested party through the selection of the appropriate fields on the data collection forms.
5) Consequences of non- disclosure of personal data
The communication of data other than those required in the electronic forms , is left to the discretion of the user; consequently, the failure to communicate these data, which are defined as optional data, will not produce any consequence.
Similarly, consent to the processing of personal data for the marketing and profiling purposes referred to in point 3 letter d) of the information, is purely optional. Therefore, the lack of consent to the related processing, will not result in any consequence for the user, except that the same may not be subjected to profiling nor receive communications of a promotional and commercial nature indicated in point 3 letter d)
6) Legal basis for processing
The legal basis for the processing of data for the purposes referred to in point 3 a) is the need to execute the contract and/or manage specific pre-contractual and post-contractual measures. With reference to these purposes, although not mandatory, the Owner also requires the consent of the user.
In the event that the user decides to contact the Owner by sending e-mail messages or other means of communication other than the completion of the appropriate form, the legal basis for processing will be the sole need to implement the specific pre-contractual and/or contractual measures requested by the user. The legal basis of the processing of personal data relating to the purposes referred to in Article 3 letter b) is substantiated in the pursuit of the legitimate interest of the holder such as: management of disputes, defence, prevention of fraud and illegal activities always provided that fundamental rights and freedoms, dignity or a legitimate interest of the data subject do not prevail. in the performance of legal obligations.
The legal basis of the processing of personal data relating to the purposes referred to in Article 3 letter c) consists in the fulfilment of obligations provided by law, regulation, Community legislation or an order of the Authority. The legal basis of the processing of personal data relating to the purposes referred to in Article 3 letters d) consists exclusively in the prior, free, specific, optional and informed consent to the processing by the user for the aforementioned purposes.
The legal basis of the processing of navigation data consists exclusively in the need to ensure the operation of the site.
7) Methods of processing
The processing of personal data provided by the users of the site, for the purposes set out, takes place either by automated means, on electronic or magnetic, or not automated on paper, with logic strictly related to the purposes and, in any event, in such a way as to ensure the security and confidentiality of the data, in addition to compliance with the specific obligations laid down in the legislation in force. The processing consists of operations of collection, registration, organization, storage, consultation, matching, processing, modification, selection, extraction, comparison of databases, use, interconnection, crossing, blocking, communication, cancellation and destruction of data, and will be carried out by personnel formally appointed and adequately trained by the Data Controller.
8) Place of treatment
The treatments connected to the web services on the site, are carried out at the headquarters of the Data Controller, and in any other place where the parties involved in the treatment are located, for the time strictly necessary to achieve the purposes for which they were collected and in any case not exceeding the limits indicated in point 13 of this information, in full compliance with the purposes pursued by the Owner and in accordance with current regulations on privacy. They are also treated, on behalf of the Owner, by professionals and/ or companies charged with carrying out technical, management and administrative activities – accounting.
9) Security measures
La Torrente Srl and third parties that work for us, take appropriate and appropriate technical and organizational measures, suitable to ensure a level of security appropriate to the risk, in order to prevent unauthorized access, the unauthorised disclosure, modification or destruction of the processed data, in accordance with applicable national law and the GDPR. In particular, access control systems to the network, servers and programs are used, to prevent the disclosure of data to unauthorized third parties, firewall and antivirus systems are adopted to protect against viruses and malware that could erase, disclose or render unusable the same data, physical and logistic measures are implemented to protect the IT infrastructure and premises used for archive use, as well as procedures for disaster recovery and data breach in the event of breaches.
In compliance with current privacy legislation, the user’s personal data may be accessible only if strictly necessary for the pursuit of the purposes referred to in point 3:
- members directors and our employees and collaborators in the administrative, commercial and technical sector and system administrators, formally appointed, as authorized or internal data processors;
- service providers that perform outsourcing activities on our behalf – appointed, if necessary, external data processors- carrying out related, instrumental or support activities, such as: hosting providers, developers and website managers.
11) Communication of data
La Torrente may communicate the data provided by the user or collected through the website, for the purposes indicated in point 3 a) b) c) without the need to acquire separate consent : to the judicial and/or control authorities at their request, and to all persons to whom it is necessary to communicate them, by law or contract, to allow the fulfilment of the purposes described above as an example and not exhaustive: Ente Poste or other mail delivery companies, Institutions and Public Administrations, Couriers/Logistics Service Providers, Companies and Professional Firms for legal, tax and tax assistance purposes. These subjects will process the personal data of users, in their capacity as independent owners or external managers in charge of processing.
The Data Controller will not communicate your data to third parties for the promotional or marketing purposes referred to in point 3 letter d). In any case, it should be noted that the data will not be disseminated in any way (meaning to disseminate the knowledge of indeterminate subjects in any way, including through their making available or consultation).
The updated and complete list of data processors appointed for the processing, can be requested by sending an e-mail to the Data Controller to the details specified below.
12) Dissemination and transfer of personal data to countries outside the EU or to international organisations.
For the pursuit of the processing purposes described above, the personal data of the user can be transferred to the recipients indicated above in Italy and within the EU. Currently there is no transfer of user data outside the European Union or to International Organizations. Should the data be subject to these transfers in the future, the Data Controller hereby ensures that appropriate safeguards are adopted, including adequacy decisions and standard contractual clauses approved by the European Commission. The list of countries deemed by the European Commission to offer an adequate level of protection, are available here: https://ec.europa.eu/info/law/law-topic/data-protection_en.
13) Retention period of personal data
The personal data voluntarily provided by the interested party to request information or other pre-contractual activities will be kept for the time strictly necessary to fulfill the request made by the user and in any case not exceeding 12 months from their collection, subject to prior cancellation at the request of the data subject.
Where the request of the user follows the conclusion of a contract for the provision of the services offered by the Owner, personal data will be processed for the duration of the contract and subsequently stored for five and ten years for the purpose of fulfilling the civil, accounting and tax obligations required by current legislation , except for further extension due to litigation.
The personal data processed for promotional, commercial and marketing purposes in the broad sense referred to in point 3, letters d), will be stored for a period not exceeding 12 months from collection, unless withdrawal of consent by the interested party. Navigation data shall remain for a period not exceeding one month.
At the end of the retention period, the Personal Data will be deleted and/or destroyed by the personnel formally appointed and adequately trained. Upon expiry of this period, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
14) Rights of the data subject
The user in his capacity as interested party, can exercise the rights provided by art. 7 Privacy Code and art. 15 ss GDPR and precisely:
- Right of access, or may have confirmation of the existence or otherwise of your personal data, even if not yet registered and require that such data are made available to you.
- Right to rectification, you can obtain, update, change, rectification of your incorrect data or integration of your incomplete data, if you have an interest.
- Right of cancellation, to obtain the cancellation or blocking of your data or, where possible, the transformation into anonymous form: if your data are processed unlawfully; if they are no longer necessary in relation to the purposes for which they were collected or subsequently processed ; in case of withdrawal of consent on which the processing is based and in case there is no other legal basis; in case he opposed the processing and there are no other legitimate reasons to continue to use your data; in case we are required by law; in case they are related to minors. The Data Controller may refuse to delete your data in the case of: exercise of the right to freedom of expression and information; fulfilment of a legal obligation, performance of a task carried out in the public interest or exercise of public authority; reasons of public health interest; filing in the public interest, scientific or historical research or for statistical purposes; assessment, exercise or defense of a right in court;
- Right to limitation,or, obtain limitation of processing in the case of contestation of the accuracy of personal data, if you did not prefer to ask for modification, updating or rectification unlawful processing of the Data Controller in order to prevent its cancellation; exercise of your right in court;
- Right to portability where applicable- or, the right to request from the Data Controller, that personal data concerning you be transferred to another Data Controller, if the processing is carried out by automated means and is based on your consent or on a contract to which you are a party.
- Right to withdraw consent to the processing if the processing is based on their consent, without affecting the processing already carried out;
- Right to object, a) if the processing is necessary for the pursuit of a legitimate interest of the Data Controller or Third Party recipients of the data, has the right to object at any time to the processing of the data, even if they are relevant to the purpose of the collection, if there are legitimate and overriding reasons related to its particular situation that must be specified in the request; b) the processing of personal data for marketing purposes in the broad sense (for instance has the right to object to the sending of advertising, information, commercial communications, by e-mail and/or telephone and/or paper mail. ) In case of opposition to the processing of data pursuant to Article 21 of the Regulation, the owner, reserves the right to assess the request, which will not be accepted in case there are compelling legitimate reasons to proceed with the processing, which prevail over its interests,rights and freedoms or in the event of the establishment, exercise or defence of a right in the courts. For all the cases mentioned above, if necessary, the Data Controller, will inform the third parties to whom your data are communicated, of the possible exercise of your rights, with the exception of specific cases (e.g. where such fulfilment proves impossible or involves the use of means which are manifestly disproportionate to the protected right).
15) Procedures for exercising rights
The user can at any time exercise his rights by sending an e-mail to p.e.c: email@example.com
The deadline for reply is 1 month from the day of the request, for the exercise of all rights. This period may be extended to 3 months in cases of particular complexity; in this case, the data controller will still proceed to notify the applicant within 1 month. Any impossibility or delay by the owner in meeting the requests will be justified. For the processing referred to in this statement, the user has the right to lodge a complaint with the Supervisory Authority pursuant to Article 77 of the Regulation, if he considers that the processing of his data is contrary to the legislation in force. This authority is represented in Italy,by the Guarantor for Privacy, based in Rome, Piazza Monte Citorio n. 121, c.a.p. 00186.. (www.garanteprivacy.it).
16) Data controller and contact details
Pursuant to Article 4 of the Regulation, La Torrente Srl , Registered office in Via Paludicella n.23, – 80057- S.Antonio Abate (NA) in the person of the Legal Representative, is the Data Controller of the personal data of users. For communications or requests, the Company can be reached at the following addresses: : Tel. 081.8738410 – address p.e.c. : firstname.lastname@example.org. The updated list of our data processors is available from our office.
Please therefore consult this page regularly, referring to the date of last modification indicated at the bottom. If the changes affect processing whose legal basis is the consent of the interested party, the Data Controller will collect the consent of the User again, if necessary.
Last update: August 2020