Dear Customers and Suppliers,
as you know, our Company attaches the utmost importance to the protection of personal data and ensures strict compliance with the provisions regarding privacy and data protection and processing.
For this reason, we inform you that our Company, starting from 25 May 2018, will process your personal data also in full compliance with the regulations introduced by the European Regulation no. 679/2016 (hereafter: the Regulation), adhering to the principles of correctness, lawfulness and transparency issued by the latter.
We inform you that under the new privacy legislation, without prejudice to the provisions of Legislative Decree no. 196/2003 where compatible with the new legislation, you have the right to request access, rectification, cancellation, portability of your personal data (within the limits of the provisions of articles 15, 16, 17 and 20 of the Regulation) and the limitation of processing (Article 18). You also have the right to oppose the processing for reasons connected with your particular situation, in full compliance with art. 21 of the Regulations, and where the processing also concerns "particular categories of personal data" (ie data revealing "racial or ethnic origin, political opinions, religious or philosophical convictions, or union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or sexual life or sexual orientation of the person "), the right to request the withdrawal of consent previously granted at any time, without prejudice to this only the lawfulness of the processing occurred before this revocation.
To apply these rights, we ask you to send us a motivated and documented request to our e-mail
firstname.lastname@example.org or via PEC to the
email@example.com to which we will respond in accordance with the law and however within 15 days of actual receipt.
We also inform you that if you believe that your rights are infringed by our Company, you can lodge a complaint with the competent guarantor.
We would like to point out to you that the purposes for which our Company had collected your data - as well as the legal basis and methods of processing - have not changed and will not change due to the entry into force of the Regulation. If, therefore, we will need to process your data for further and different purposes, we will proceed immediately to ask your consent in accordance with the law.
Lastly, we inform you that your data will be kept for 10 years, in order to allow our Company to act in accordance to the scopes they were collected. In any case, our Company reserves the right to store your data for a longer period strictly necessary for the pursuit and / or attainment of the aforementioned purposes, as well as to fulfill any legal and / or contractual obligations.
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.
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).
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.
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
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
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 23/05/2018.