Updated on 07/01/2022
This privacy policy statement is drafted and customised for visitors to the following websites
hereinafter “Gruppo Romani websites”
This document abrogates and completely replaces the previously published document
WEBSITE PRIVACY POLICY PURSUANT TO ARTICLES 13 AND 14 OF EUROPEAN REGULATION 2016/679 (GDPR) – PRIVACY POLICY
Specific short privacy notices will be progressively included or displayed on the pages of the site provided to manage special optional services that require the use of data collection forms. We also inform you that, in order to supply a comprehensive service, our site may contain links to other websites not managed by GRUPPO ROMANI S.P.A..
GRUPPO ROMANI S.P.A. is not responsible for errors, contents, cookies, publications of illegal moral contents, advertising, banners, or files that are not in conformity with statutory legal requirements and compliance with data protection regulations by sites not managed by the controller.
GRUPPO ROMANI S.P.A. in its role of controller of your personal data, pursuant to articles 13 and 14 of Regulation (EU) 2016/679, hereby informs you that the Regulation protects data subjects in relation to processing of their personal data and that said data processing must be based on principles of fairness, lawfulness, transparency and protection of your confidentiality and your rights. The information and personal data you have supplied or that has been otherwise acquired in the context of use of the site will be processed in compliance with the legislative provisions of the aforementioned regulation and the confidentiality obligations set down therein
DATA SUBJECTS AND RETENTION TIME
A) users (navigators) of the following websites
hereinafter “Gruppo Romani websites”
Types of data processed
• Navigation data: the IP addresses or domain names of computers and other devices used by users connecting to the site; addresses in Uniform Resource Identifier notation (URI) of the resources requested and any temporal indications of the same; parameters concerning the user’s operating system and IT environment; departure and arrival pages; navigation index and identifying behaviours while viewing the site pages.
• Personal data supplied voluntarily by the user: the optional, explicit and voluntary transmission of emails to the addresses given in this site and filling in of the forms on the site result in the subsequent acquisition of the sender’s personal data (e.g. name, surname, email address). Specific short privacy notices are provided on pages containing forms.
Data processing aims: your data collected during navigation will be processed for the following aims.
1) execution of operations strictly connected with and instrumental to the management of relations with site users and visitors;
2) collection, retention and processing of your data for statistical analysis also in anonymous and/or aggregated form; statistical analysis aimed at checking the quality of the services offered by the site;
3) sharing with the operators of social networks and third parties of interactions carried out and the utilisation data related to pages containing cookies integrating products or software functions.
Data processing for the execution of the aims as at points 1 and 2 is required in order to fulfil a request you have made and if you refuse to provide your consent this could limit and/or prevent full use of the functions and services provided by the site. The legal grounds for processing of your data for the aims as at points 1, 2 are the fulfilment of a request you have made, pursuant to article 6.1.b.) of the GDPR; your refusal to communicate said data would make it impossible to consult the site. Communication of the data indicated in aim 3 is optional on the legal grounds of consent, and any refusal to provide consent for processing will not affect the functionality of the site and the services it provides. The legal grounds for processing of your data for the aim as at point 3 are optional, pursuant to article 6.1.a). Your consent is given via the short privacy notice by clicking on the words “ACCEPT ALL COOKIES” given in the short privacy notice. In relation the optional communication of personal data, more information is given concerning the cookies present on the site in the cookie policy document, which can be accessed also from the short privacy notice.
The navigation data are retained for the times shown in the cookie policy available on the site.
COOKIES AND OTHER TRACKING SYSTEMS
Your data are collected also by means of tools and services supplied by third parties and retained by said third parties. For more information we invite you to refer to the cookie policy of each site, available at the following links
GRUPPO ROMANI S.P.A. operates merely as an intermediary for the links given in the cookie policy and assumes no liability in the event of possible changes.
B) contact us section users
When you fill in the forms accessible from the “Contact us” section on the “GRUPPO ROMANI Websites” your “common” personal data will be used to reply to your request for information. The communication of data for these aims is based on fulfilment of a request you have made. The legal grounds for processing are given in article 6.1.b) of the GDPR. Once you have provided your consent by selecting the checkbox “I give my consent for marketing aims as indicated in point B) of the privacy notice and confirm that I am over 16 years of age”, your data will be used to send adverts and promotional information concerning information messages and sales communications concerning the activities and products of GRUPPO ROMANI S.P.A. by means of conventional methods (e.g. telephone contacts, traditional mail, personal emails, etc.) or automated contact methods (e.g. automated email transmission campaigns, instant messaging) and software systems managed by third parties in full compliance with the principles of lawfulness and fairness and legal provisions. Communication of your data for these aims is optional and does not affect our reply to your request for information. The legal grounds for processing are given in article 6.1.a.) of the GDPR. You can object to processing at any time by means of the “UNSUBSCRIBE” link at the foot of the email or by sending a request to the controller using the contact details provided in this privacy policy. Your data will be retained for the necessary time to provide the service you have requested and for marketing aims until you decide to cancel your subscription, object to data processing, or withdraw your consent.
C) subscribers to the newsletter
When you fill in the form accessible from the “Newsletter” site, your “common” personal data will be used to meet your request to receive the newsletter and associated subscription to the mailing list for the transmission of adverts and promotional information and sales communications concerning the activities and products of GRUPPO ROMANI S.P.A. via emails and software systems managed by third parties, in full compliance with the principles of lawfulness and fairness and legal provisions.
Communication of your personal data is optional, however your refusal to communicate your data will make it impossible for GRUPPO ROMANI to fulfil your request for subscription to the newsletter and to keep you informed of GRUPPO ROMANI news. The legal grounds for processing are given in article 6.1.a.) of the GDPR. You can object to data processing at any time using the “UNSUBSCRIBE” link at the foot of the mail or by sending a request to the controller using the contact details shown in this privacy policy statement. Your data will be retained until you decide to cancel your subscription
METHOD OF PROCESSING PERSONAL DATA
Your personal data will be processed using manual, electronic, and/or computer methods though the use of cookies (as indicated in the cookie policy published on the site), by means of computers with the use of third party software and using automated contact methods (e.g. automated mailing campaigns, instant messaging, etc.) in compliance with the methods pursuant to articles 6, 32 of the GDPR and by adopting the adequate security measures provided for.
In order to compare and potentially improve the results of communications, the controller uses systems for sending newsletters and promotional communications with reports. Through the reports GRUPPO ROMANI can access the following information for example: the number of readers, page views, unique clickers, and clicks; the devices (iPhone, Blackberry, Nokia…) and operating systems (Windows, Apple, Linux, Android…) used to read the communication; details on the activity of individual users; the number of pending users who have not yet confirmed their subscription; details of emails sent by date/hour/minute; details of emails delivered or not delivered, of those sent; a list of persons who have unsubscribed from the newsletter; the persons who opened an email or clicked a single link; users experiencing problems viewing the message; link tracking (i.e. the number of clicks on the message links); click tracking (which links were clicked and by whom). All these data are used in order to compare and potentially improve communication results
USE OF SOCIAL MEDIA PLATFORMS
GRUPPO ROMANI S.P.A. can also supply links to other social media platforms that point to servers installed by persons or organisations over which it has no control. GRUPPO ROMANI S.P.A. does not provide any form of representation or assume any responsibility concerning the accuracy or any other aspect of the information available on said sites. The link to a third party site cannot be construed as an endorsement, either by GRUPPO ROMANI S.P.A. or by said third party, of the products and services of others or of said third party. GRUPPO ROMANI S.P.A. does not provide declarations or guarantees concerning the use or filing of the user’s data on third party sites. Users are invited to read the privacy policy regulating the third party sites linked to our website carefully, in order to achieve a comprehensive understanding of the possible uses of their personal data
RECIPIENTS OF PERSONAL DATA AND DATA DISSEMINATION
Your data will be processed by duly appointed personnel and will be disclosed externally to companies that act in the role of independent controllers or data processing officers:
• external parties supplying services in cloud form;
• technical assistance service suppliers;
• platform used for the transmission of sales information.
The complete list can be requested by writing to the controller at the contact details provided
Your data will not be disseminated.
TRANSFER OF PERSONAL DATA
Your personal data may be transferred to other countries in the European Union
CONTROLLER
In accordance with the law the controller is Gruppo Romani S.p.A. Via A. Volta 9-23/25 42013 Casalgrande (Re) Italy Tel. +39-0522-998411/911 e-mail: privacy@grupporomanispa.com in the person of its pro tempora legal representative. The controller has appointed the data protection officer (DPO) pursuant to art. 37, available by writing to dpo@grupporomanispa.it.
The data subject shall have the right to obtain from the controller erasure (right to be forgotten), restriction of processing, updating, rectification, portability, and the right to object to processing of the personal data concerning him or her, and in general to exercise all the rights provided by articles 15 and following of European Regulation 2016/679 by writing to privacy@grupporomanispa.com or to dpo@grupporomanispa.it. The data subject has the right to lodge a complaint with the Supervisory authority
APPLICATION OF THIS PRIVACY POLICY NOTICE
If you need clarification concerning this Privacy Policy, first contact GRUPPO ROMANI S.P.A. by email at privacy@grupporomanispa.com or contact the controller at the company addresses given in this document.
AMENDMENTS TO THIS PRIVACY POLICY NOTICE
GRUPPO ROMANI S.P.A. reserves the right to update this privacy policy notice to reflect changes in the law, and taking in due consideration feedback from employees, customers, collaborators and users. If GRUPPO ROMANI S.P.A. makes any changes, the Privacy Policy available on the “GRUPPO ROMANI websites” will be promptly updated
DATA SUBJECT RIGHTS
Regulation (EU) 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22 – Data Subject rights
1. The data subject has the right to obtain confirmation as to whether or not personal data concerning him or her are being processed, even if not yet subscribed, and to receive a copy of the data in intelligible form and can lodge a complaint with the Supervisory authority.
2. The data subject has the right to be informed of:
a) the source from which the personal data originate;
b) the aims and methods of processing;
c) the logic applied in the case of data processing performed with the aid of electronic equipment;
d) the name and contact details of the controller, of the processors, and of the controller’s representative pursuant to article 5, subsection 2;
e) the recipients or categories of recipients to whom the personal data may be disclosed or who may become informed of the personal data in their role of designated representative in the Member State, of processors or persons authorised to process personal data.
3. The data subject has the right to obtain:
a) updating, rectification and, taking into account the purposes of processing, completion of incomplete personal data concerning him or her;
b) erasure, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not required for the aims for which the data were collected or subsequently processed;
c) an attestation that the operations at letters a) and b) have been brought to the attention, also with regard to their contents, of the parties to whom the data were disclosed or diffused, except for cases in which compliance with this requirement is not possible or would require the use of manifestly disproportionate resources with respect to the protected right;
d) data portability.
4. The data subject has the right to object, entirely or partly:
a) for legitimate grounds, to the processing of personal data concerning him or her, even if relevant to the aim of data collection;
b) to the processing of personal data concerning him or her for the transmission of advertising or direct sales material, for market surveys or for commercial communications