Regulation (EU) 2016/679

of the European Parliament and of the Council

Neri Bruno wishes to inform you that, pursuant to art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data (hereafter, the “European Regulation”), may process some personal data collected automatically or provided by you through the surfing or use of the website www.turbosplashpac.com (hereinafter, the “Website”).

Therefore, this Privacy Policy exclusively refers to the present Website and does not concern other websites, pages or online services accessible via links published within the Website.

  1. DATA CONTROLLER

Neri Bruno, in the person of the legal representative, domiciled at the registered office of Via Vincenzo Monti 32, 20127 – Milano (MI), (hereinafter, “Neri Bruno – Turbosplashpac” or “Data Controller”) is the Data Controller.

  1. TYPES OF PROCESSED DATA

To allow you to use the Website and its services, including getting in touch with Neri Bruno – Turbosplashpac for specific requests or to receive materials about our activities and events, the Data Controller may know and process some of your personal data.

Surfing data

The computer systems and software implemented on the Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of communication protocols of the Internet.

This category of data includes IP addresses or domain names of the computers used by users connecting to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the user’s computer environment.

These data, necessary for the use of the Website, are processed for the sole purpose of obtaining statistical information on the services use (most visited pages, number of visitors per hour or day, geographical areas of origin, etc.) and to ensure the proper functioning of the services offered.

The navigation data are not stored for more than seven days and are deleted immediately after their aggregation, without prejudice to the possible requests of judicial authorities to ascertain criminal offenses.

Data provided voluntarily by the user

The optional, explicit and voluntary submission of e-mail messages, as well as the filling-in and submission of Website forms entail the acquisition of the sender’s email address, which is required to respond to your requests, as well as any other personal data included in the email, or in every attached file.

If necessary, dedicated privacy policies may be published on the Website pages dedicated to specific services.

Cookies policy

The Website uses the following types of cookies.

Technical Cookies

Technical and session cookies are implemented on the Website, i.e. small text files containing a certain amount of information exchanged between your terminal or your browser and the Website, which allow the correct operation and use of the latter. On the opposite, cookies are neither used to transmit information of a personal nature nor the so-called persistent cookies have been implemented.

Analytical Cookies

Analytical cookies are used and made available by a third party, Google Analytics. The latter activity is carried out for mere internal statistical analysis of access, to improve the website and simplify its use, as well as to monitor its correct functioning. In any case, the Data Controller has adopted the most suitable tools to reduce the identification capabilities of this type of cookie. Google Analytics publishes its cookie policy here. The user may selectively disable the functionalities of Google Analytics by installing on the browser the opt-out component provided by Google. To disable the action of Google Analytics, please refer to the following link.

Profiling Cookies

Cookies for profiling users are not used, nor are other tracking methods used.

The present Website does not implement either so-called “profiling cookies” nor tracking methods.

Third-party Cookies

This Website uses analytical cookies installed and made available by Google Analytics, as previously mentioned.

Lastly, for the playback of multimedia files, such as videos, the Website may use external tools, which may install cookies. For instance, the YouTube cookie policy may be consulted here.

Browser settings options on the use of cookies by the Website

The installation of all types of cookies may, nevertheless, be disabled in settings of your browser. It should be noted, however, that any changes on these settings could make the site unusable where the cookies that are essential for the provision of our services were to be blocked.

However, each browser has different settings for deactivating cookies. Below are the links to the instructions for the most common browsers: Apple Safari, Google Chrome, Microsoft Internet Explorer, Mozilla Firefox.

  1. PURPOSE OF THE DATA PROCESSING AND LEGAL BASIS

The Data Controller exclusively holds those personal data provided by you during surfing of the Website and the use of its services, including forwarding of your spontaneous application. Data will be used exclusively to allow use of contents and services on the Website as well as, upon request, to receive your inquiries and/or spontaneous application.

In consideration of your choice to use the Website and its services, the legal basis on which the processing of your personal data is based upon is:

  • the consent to the processing you provide by spontaneously sending to our email addresses inquiries and/or your application;
  • the legitimate interest in processing your personal data to offer you the best services; allow us to respond to your email requests; prevent fraud; maintain the Website, our services and the IT systems secure; ensure that our processes, procedures and systems are as efficient as possible.
  • the need to fulfill a legal obligation, if this becomes necessary, and to communicate your personal data wherever required by the authorities;

Your personal data may be processed either through IT tools or paper-based means.

  1. PERIOD OF RETENTION OF PERSONAL DATA

The Data Controller plans to keep your personal data for a period of time no longer than it is necessary to achieve the purposes for which they were collected and processed.

Therefore, personal navigation data and those acquired through the use of the Website will not be stored for longer than 30 days or for the time needed to exploit the service that you requested.

With regard to other personal data, since the Data Controller cannot accurately determine the period of storage of your personal data, the Data Controller commits to inspire the processing of your personal data to the principles of adequacy, relevance and data minimization, so as required by the European Regulation, annually assessing the need of continued storage. Therefore, once the purposes for which they were collected and processed are achieved, we will remove them from our systems and records and/or take any appropriate measures to render them anonymous, preventing your identification.

The abovementioned paragraphs are without prejudice to the case in which such data will be stored to comply with regulatory obligations, or to ascertain, exercise or defend our right in court.

  1. CATEGORIES DATA SUBJECTS ADDRESSEES

The processed data will not be disclosed to third parties. The following may, however, come to know your personal data, in relation to the above mentioned processing purposes:

  • individuals who may access the data pursuant to European Union law or Member State legislation to which the Data Controller is subject;
  • subjects who perform, within the borders of the European Union, in complete autonomy, as separate Data Controllers, or as Data Processors specifically appointed by Neri Bruno – Turbosplashpac, purposes auxiliary to the activities and services referred to in para. 4., e. the professionals of Neri Bruno – Turbosplashpac, the companies that offer IT infrastructures and IT assistance and consultancy services as well as the design and implementation of software and websites, the companies that offer services useful for customizing and optimizing our services, companies that offer data analysis and development services (including those relating to user interactions with our services), service centers, companies or consultants responsible for providing additional services to the Data Controller, within the limits of the purposes for which they were collected.

Furthermore, our employees may also become aware of your personal data, provided that they are previously designated as individuals acting under the authority of the Data Controller pursuant to art. 29 of the European Regulation or as System Administrators.

Any communication of your personal data will take place in full compliance with the provisions of the law set by the European Regulation as well as technical and organizational measures put forth by the Data Controller to ensure an adequate level of security.

  1. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

The Data Controller does not intend to transfer your personal data to third countries. Accordingly, the entire processing of personal data takes place within the borders of the European Union.

  1. POTENTIAL AUTOMATED DECISION MAKING PROCESSES

The Data Controller does not use automated decision-making processes, including the profiling referred to in Art. 22, paras. 1 and 4, of the European Regulation.

  1. NATURE OF THE PERSONAL DATA PROVISION

The provision of your personal data for the purposes referred to in paragraph 4 is mandatory, as the refusal would make it impossible for Neri Bruno – Turbosplashpac to display the Website contents or to process the data contained in your requests and emails sent by the form in the website.

  1. RIGHTS OF DATA SUBJECTS

In relation to the processing of your personal data, in accordance with the European Regulation, you as a data subject have the rights to:

  • At any time, withdraw your consent to the processing. It should be noted, however, that the withdrawal of consent does not affect the lawfulness of any previous processing, as provided for under art. 7, para. 3 of the European Regulation;
  • Ask to the Data Controller for access to your personal data, as provided for by art. 15 of the European Regulation;
  • Obtain from the Data Controller the amendment and integration of your personal data deemed inaccurate, also by providing a simple supplementary statement, as provided for by art. 16 of the European Regulation;
  • Obtain from the Data Controller the cancellation of your personal data under any of the reasons at art. 17 of the European Regulation;
  • Obtain from the Data Controller the limitation of the processing of your personal data if one of the cases under art. 18 of the European Regulation;
  • Receive from the Data Controller your personal data in a structured format, commonly used and readable by automatic device, as well as the right to transmit such data to another data controller without impediments, as provided for by art. 20 of the European Regulation;
  • At any time and for reasons connected to your particular situation, oppose the processing of your personal data carried out pursuant to art. 6, para. 1, letters e) or f), including profiling on the basis of these provisions, pursuant to art. 21 of the European Regulation;
  • Not to be subjected to decisions based solely on automated processing, including profiling, which produce legal effects that affect you or that significantly affect your person, if you have not previously and explicitly consented, as required by art. 22 of the European Regulation. By way of example and not exhaustive, this category includes any form of automated processing of personal data aimed at analyzing or predicting aspects concerning consumption and purchase choices, the economic situation, interests, reliability and behavior;
  • File a complaint to a supervisory authority (art. 77) or take appropriate judicial offices (art. 79), if you deem the data processing to be in violation of the European Regulation. The complaint may be lodged in the Member State in which you usually reside or work, or in the place where the alleged violation has occurred.

In exercising your rights, you may contact the Data Protection Officer, addressing a communication at the registered office of Via Vincenzo Monti 32, 20127 – Milano (MI), or by sending an email to [email protected]