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PRIVACY POLICY

INFORMATION PURSUANT TO ART. 13 OF LEGISLATIVE DECREE N. 196/2003

Dear User,

The Company PROGOLD S.p.a. places great emphasis on the protection of data of all those with whom it comes into contact (the ”User” or “Users”).
Following consultation of our website (www.progold.com, hereafter, the “Website”) data relating to identified or identifiable persons may be processed.
In reference to that data processing and also in accordance with Art. 13 of Italian Legislative Decree no. 196/2003 - Personal Data Protection Code, we therefore provide this privacy policy, the validity of which does not extend to any other external websites consulted by the user via the links present on the website.


Personal Data Processing Controller (Art. 28 of Italian Legislative Decree no. 196/2003).

The “Controller” of the data processing is PROGOLD S.p.a. based in Via Postale Vecchia no. 26/A 36070 Trissino (VI).
In accordance with Art. 29 of Italian Legislative Decree no. 196/2003, the complete list of processing managers may be obtained by anyone making a written request for the same.

Types of Data processed.

This Website processes personal data to be understood in accordance with Art. 4 Letter b) of Italian Legislative Decree no. 196/2003 as “any information relating to an individual, identified or identifiable, even indirectly, by way of reference to any other information, therein including a personal identification number” (the Data).
There is no processing of sensitive data, to be understood in accordance with Art. 4 Letter d) of Italian Legislative Decree no. 196/2003 “personal data that may reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organisations of religious, philosophical, political or trade union nature, as well as personal data that may reveal the state of health and sex life”
If the foreign User indicates his/her name or other data which may infer his/her nationality, this does not constitute sensitive data as it is not data likely to reveal the racial or ethnic origin in the proper sense.

The Data subject to processing includes:

1) Browsing Data: the IT systems and software procedures in charge of the functioning of this Website acquire, during their normal exercise, some personal data whose transmission is implicit in the use of internet communication products. This is information not collected to be associated with identified persons, but which, by its very nature, may allow for the User to be identified through processing and association with data held by third parties.
2) Cookies: the Website makes use of cookies as specified in the cookies policy found on the Website and consultable here
3) Data provided voluntarily by the User: this is Data communicated freely by the User, to request information, to access certain services, to send an e-mail and, in general, Data requested upon registration where provided.

The optional transmission, explicit and voluntary, of Data by the user, even beyond the registration procedure, and the sending of e-mail messages to the addresses indicated on this Website involves the subsequent acquisition of the sender's address, required to respond to requests, to send newsletters, etc. and also the acquisition of other data included in that transmission.

Optional nature of provision of Data

Without prejudice to what is indicated in the cookies policy, consultable here with reference to technical and browser cookies, the User is free to provide personal data for the request for information, sending of newsletters, informative material, or any other communications or for registration to the Website.
Any failure to provide the Data, however, may involve the impossibility of obtaining what is requested. On the Website pages where there is the possibility of obtaining services at the request of the User, specific information is provided or displayed, subject, where necessary, to the consent of the User (for example, to register to the website, to receive newsletters, etc.).
In particular, any refusal to provide Data during the request for registration will prevent the correct registration to the Website and will make it impossible to use the services provided and reserved to registered Users.
If the User indicates Data of third parties, this implies processing of the Data with respect to which the User himself/herself acts as autonomous processing controller, assuming all obligations and responsibilities provided by Italian Legislative Decree no. 196/2003.
The User therefore guarantees to the Data Processing Controller of this Website that any third party data has been acquired by him/her in respect of the regulations contained in Italian Legislative Decree no. 196/2003, as well as undertaking to indemnify the Controller for any claim for compensation for damages, indemnity or dispute or claim that the third party may make against the Processing Controller of Data indicated by the User in violation of the applicable rules on personal data protection.

Purposes of processing

Specific purposes of personal data processing (“Purposes”) are communicated to the user in detail in the relevant sections of the website.
However, the general processing purposes can be summarised as follows:
a) purposes provided as mandatory by law
b) for administrative, accounting, tax and management fulfilments
c) to fulfil pre-contractual, contractual and post-contractual obligations
d) for purposes of statistical analysis or production of non-identifying statistical results, also by way of statistical information systems
e) to send newsletters
f) to send information on products and services of the company and/or associated companies and/or commercial partners
g) in the case of registration, to allow for access to the services provided by way of registration and reserved to registered users (including management of the request itself and communication of updates on the status of the request).

Processing methods

The Data is processed for the time strictly necessary to achieve the purposes for which it was collected using automated, IT and/or paper tools, complying with specific and adequate security measures so as to avoid unlawful, incorrect and unauthorised uses or loss of data. The Data is managed by personnel authorised by the processing Controller and in particular by staff in the commercial and marketing area, the administrative and information technology area.
The Data provided will not be disseminated.
It may, however, be communicated to entities appointed from time to time by the Company as external processing managers or officers such as: subsidiary/parent companies or associates, assignees of businesses and business branches, companies resulting from mergers or demergers of the Company, commercial partners involved in specific projects or initiatives, suppliers of hosting services, external consultants for technical, procedural or accounting or legal purposes within the limits of relevance and necessity.
The User's Data may be provided to the authorities when this is required by a rule of law.
During browsing on this Website, you may be redirected via hypertext link to other websites in relation to which the collection of personal data is done outside the control of the Controller, which does not, therefore, accept any liability.
The methods of processing personal data of those websites will be regulated by the privacy policies of the latter to which reference is made.

Processing Location

The processing connected to the web services of this Website takes place at the Controller and the company Progold S.p.A. and at the servers and IT structures used directly by this company or managed by way of commercial partners assigned or appointed as managers.

Rights of the User
The Data Subjects are entitled at any time to obtain confirmation of the existence or otherwise of that data and to know of its content and origin, to verify its accuracy, or request its supplementation, update, or rectification (Art. 7 Italian Legislative Decree no. 196/2003)
In accordance with that article, the data subjects are entitled to request the deletion, transformation into anonymous form or block on data processed in violation of the law, also to object for legitimate reasons to its processing.
Requests should be sent to paolo.priante@progold.com

For transparency, we set out below the text of Art. 7 of the Privacy Code, already cited:
Art. 7 Italian Legislative Decree no. 196/2003. Right of access to personal data and other rights

1. The data subject is entitled to obtain confirmation of the existence or otherwise of personal data relating to him/her, even if not yet registered, and its communication in intelligible form.

2. The data subject is entitled to obtain an indication:
a) of the origin of the personal data;
b) of the purposes and methods of processing;
c) of the logic applied in the case of processing done using electronic tools;
d) of the identification details of the controller, managers and appointed representative in accordance with Article 5, Paragraph 2;
e) of the entities or categories of entities to which the personal data may be communicated or which may come to know of it in the capacity of appointed representative in the State territory, managers or officers.

3. The data subject is entitled to obtain:
a) the update, rectification or, where appropriate, supplementation of the data;
b) the deletion, transformation into anonymous form or block of data processed in violation of the law, including that whose storage is not necessary in relation to the purposes for which the data was collected or subsequently processed;
c) certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data was communicated or disseminated, except where that fulfilment is found to be impossible or involves a use of means manifestly disproportionate to the protected right.

4. The data subject is entitled to object, in whole or in part:
a) for legitimate reasons to the processing of personal data relating to him/her, even if pertinent to the purpose of its collection;
b) to the processing of personal data relating to him/her for the purposes of sending advertising material or direct sales or for the completion of market research or commercial communication

Changes to Privacy Policy

The Personal Data Processing Controller reserves the right to change this Privacy Policy.
The updated version of the Privacy Policy will be published on this page.
The Data Subject undertakes to read the updated version, regularly checking the respective web page, which, to that end, sets out the latest update date.
This version is updated to 01/10/2016.

Progold S.p.a.

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