Franco Curletto srl (hereinafter “Franco Curletto“), as Data Controller, pays particular attention to the protection of personal data of its visitors users to the site www.francocurletto.com
- is intended for the website www.francocurletto.com, including the dedicated areas where the user can freely and expressly provide a series of data concerning him/her to contact the Franco Curletto (or send requests);
- is made pursuant to and by art. 13 of the EU General Data Protection Regulation (hereafter “GDPR”) and illustrates how to use, share, access, modify or delete personal information provided by the user. The Regulation is also inspired by the Recommendation n. 2/2001 concerning the minimum requirements for online data collection in the European Union, adopted on 17 May 2001 by the Article 29 Working Group.
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The security measures applicable to this Site have been defined and developed to ensure that the processing of users’ personal data takes place in compliance with the principles of lawfulness, correctness, transparency, purpose limitation and retention, data minimization, accuracy, integrity and confidentiality, in compliance with current national and European regulations.
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2.2 Data provided voluntarily by the user. 2
4 Legal basis and purpose of processing. 3
5 Recipients of personal data. 4
6 Transfer of personal data. 4
8 Rights of the interested party. 5
1 Owner of data processing
The data controller is Franco Curletto srl, with registered office in Viale Pasubio, 12, 20154 Milan (MI) – Italy C.F. and VAT number 08632090018.
The updated list of data processors and persons authorized to process the data is at the registered office of the Data Controller. For any further information or clarification, Franco Curletto can be contacted at the address indicated, or at the e-mail address e-mail email@example.com
2 Personal data processed
2.1 Navigation data
The processing of personal data of users who visit and consult the Site is limited to the so-called navigation data the transmission of which is necessary for the functioning of the computer systems and the programs necessary for the operation of the Site but which by their very nature could, in association with other data, allow the identification of users.
These include the IP addresses or the names of the computers used by the users connecting to the Site, the Uniform Resource Identifier (URI) addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained the answer, the numerical code indicating the status of the answer given by the server (good order, error, etc.) and other parameters related to the operating system and to the IT platform used by the user.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning. These data may also be used to ascertain responsibility in the case of commission of computer crimes against the Site in accordance with the procedures in force at the competent Authorities.
With the exception of this possibility, navigation data are only temporarily stored in compliance with applicable regulations.
2.2 Data provided voluntarily by the user
To access the contents of the site it is not necessary to register. However, within the Site there are services for which it is necessary to provide data.
If Franco Curletto acquires personal information and data, it will inform users in advance about the purposes for which such data are requested and how they will be used.
By way of example, if the User decides to contact the Franco Curletto through the contact forms, personal data such as name and surname, telephone number, e-mail address and any other information that the user agrees to provide may be requested. In this case, the User consents to their use to respond to requests for information, quotes, or any other kind indicated by the form header.
Where necessary, Franco Curletto will acquire the specific consent of the user to the relative use of the data.
3 Data of minor users
The Website is not aimed at minors and Franco Curletto does not intentionally collect personal data from them. In case of accidental registration of any information on minors, Franco Curletto will delete them in a timely manner at the request of users.
4 Legal basis and purpose of processing
The following table shows the legal basis and the reasons why User data may be processed by Franco Curletto
In some cases it is necessary to process the personal data of the User to execute our contract with reference to the use of the site
|§ Allow access to the Website and allow its correct use to the User
We collect and process personal data to improve and monitor the efficiency of the Site and to offer updated services
· Improve the efficiency of the site
· Perform statistical analysis on the efficiency and functioning of the Site
· To guarantee the best possible experience for the User in navigating the Website
· Manage and respond to requests for applications submitted through the Site and for which we invite you to read the appropriate Regulation
|Compliance with legal obligations
We may use the data provided to satisfy requests from the authorities and for the fulfilment of the obligations related to security
· In some cases we may need to use your information to manage and resolve legal disputes and ensure the security of the Site and users
With the consent of the user we will be able to perform profiling on site activity
With the consent of the user we will be able to perform profiling on site activity
· With the consent of the user we will be able to send you commercial communications to update you on our products and services and to take part in our latest news
5 Recipients of personal data
- subjects acting as Data Processors such as, by way of example: people, companies or professional firms that provide assistance and advice to Franco Curletto in accounting, administrative, legal, tax and financial matters; subjects delegated to perform technical services; credit institutions and insurance companies;
- persons authorized by the Franco Curletto to the processing of personal data for activities strictly related to the provision of services, which have an adequate legal obligation of confidentiality;
- police forces, armed forces and other public administrations in order to fulfil their obligations under applicable laws, regulations and national or European legislation as well as agencies or professionals for debt collection (e.g. debts owed to us) or to allow the defense in the judgment of the Franco Curletto, for example in the case of violations of the network by the users;
- only with the specific consent of the user, personal data may be communicated to business partners of Franco Curletto or to third parties (without prejudice to the adoption of security and data protection criteria in line with current legislation) for marketing and profiling purposes as described above.
6 Transfer of personal data
Franco Curletto does not transfer personal data to third countries or international organizations. However, it reserves the right to use cloud services. In this case, the service providers will be selected from those who provide adequate guarantees, as provided for by art. 46 GDPR 679/16. Therefore, the processing will be carried out according to one of the modalities permitted by the current law, such as the adoption of Standard Clauses approved by the European Commission, the selection of subjects adhering to international programs for free circulation of data (e.g. EU-US Privacy Shield) or operating in countries considered safe by the European Commission.
7 Storage of personal data
The information systems and computer programs used by Franco Curletto are configured in such a way to minimize the use of personal and identifying data; these data are processed only for the achievement of the specific purposes from time to time pursued; in any case, the criterion used to determine the retention period is based on compliance with the terms permitted by applicable laws and the principles of minimization of processing and rational management of archives.
8 Rights of the interested party
Pursuant to articles 15 and ss. of the Rules, the user has the right to ask the Franco Curletto at any time, access to their personal data, rectification or cancellation of the same, or to oppose their treatment pursuant to art. 21 of the GDPR. It also has the right to request the limitation of processing in the cases provided for by art. 18 of the GDPR, as well as obtaining, in a structured format, in common use and readable by automatic device, the data concerning it, in the cases provided for by art. 20 of the GDPR.
In any case, the user is always entitled to lodge a complaint with the competent Supervisory Authority (Guarantor for the protection of personal data), pursuant to art. 77 of the Regulations, if it considers that the processing of its data is contrary to the law in force.
Franco Curletto therefore invites its users to regularly visit this section in order to be always updated on the data collected and on the use made of it by the Data Controller.