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Privacy Policy

pursuant to Article 13 of Regulation (EU) 2016/679

With this document ("Information"), the Data Controller, as defined below, wishes to inform you about the purposes and methods of processing your personal data and about the rights that Regulation (EU) 2016/679, relating to the protection of persons with regard to the processing of personal data, as well as the free circulation of such data ("GDPR"), recognizes them. This Notice relates exclusively to the processing of personal data relating to the website (the "Site").

1. Who is the Data Controller

The data controller is Cappello Group SpA industrial zone IV phase viale 3, n 5, 97100 Ragusa (RG).

2. What personal data we process
2.1. Common personal data

In response to your specific request, and for the purposes indicated in Article 3 of this Notice, the Data Controller processes the following personal data:
- common and contact data, such as name, surname, address, telephone number, e-mail address and any additional data that you will provide from time to time through the forms on the Site.

2.2. Navigation data

The computer systems and computer programs used to operate the Site collect some personal data whose transmission is implicit in the use of Internet communication protocols (eg IP addresses or domain names of the computers used by users who connect to the Site, the URI - Uniform Resource Identifier - addresses of the requested resources, time of the request, method used in submitting the request to the server, size of the file obtained in response, numerical code about the status of the response made by the server - successful, error, etc. - and other parameters relating to the operating system and the IT environment of the User). Although this is information that is not collected to be associated with identified data subjects, by their nature they could, through processing and association with data held by third parties, allow the data subjects to be identified. 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 and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site: except for this possibility, the data on web contacts do not currently persist for more than seven days.

2.3. Cookies

In some cases, personal data is collected by Cappello Group with the use of various technologies, including that of "cookies". Cookies are small text files created by some websites and sent to the user's browser when they access the site. This information can then be stored on your computer via a tag that identifies the device but not the user.

Some pages of the Site use cookies, sent by Cappello Group or third parties, and other technologies in order to allow the technical functioning of the Site itself, for a better use of the Site and to carry out statistical analysis on the use of the Site.

3. What are the purposes and legal bases of the processing

3.1. Execution of the contract and fulfillment of legal obligations

Your personal data will be processed by the Data Controller for purposes strictly connected and instrumental to the execution of the contract you have signed with Cappello Group, as well as for the fulfillment of obligations established by laws, regulations and / or community regulations, or by supervisory bodies. and control or by other authorities entitled to do so.

For the processing of your personal data for the purposes referred to in this paragraph it is not necessary to obtain your consent, as the legal basis of the processing consists, in accordance with current legislation, in the execution of a contract and in the fulfillment of a legal obligation. Your personal data will be processed for the time necessary to pursue the indicated purpose and, subsequently, kept exclusively for the period of time necessary to comply with the legal requirements.

3.2. Management of your request

Your personal data will be processed to respond to the requests you make from time to time through the Site such as, by way of example and not limited to, the request for information through the "contact" forms, registration to specific areas of the Site.
The legal basis for the processing of your data, in accordance with current legislation, is the satisfaction of your request. Therefore, the Data Controller does not need your consent to carry out the processing.

For the management of your request, your personal data will be processed for the time strictly necessary and, in any case, will not be kept for a period exceeding [6] months. However, in the event that you request to be registered on the Site, your personal data will be kept until you decide to remain registered. For the fulfillment of legal obligations, your personal data will be processed for the time strictly necessary for this and will subsequently be kept exclusively for the period from time to time required by current legislation (including the provisions for the prescription of rights).

3.3. Marketing

Upon your request, Cappello Group may also process your personal data to send you communications of a commercial or editorial nature via the newsletter.
For this treatment, your consent is required which constitutes the legal basis of the treatment in accordance with current legislation.

The data collected will be processed by the Data Controller until your decision to revoke the consent and / or to obtain the termination of the processing.
Even if you have given us your consent, you have the right to withdraw your consent and / or to oppose direct marketing activities at any time by contacting the Data Controller at the following address:

4. Nature of the processing of personal data and consequences of a refusal

For the purposes referred to in Article 3.1 above, the provision of your personal data is mandatory. Therefore, your refusal will make it impossible for the Owner to follow up on you.
Otherwise, for the pursuit of the purposes referred to in the previous article 3.2., The provision of your personal data is optional. Therefore, your refusal will not make it impossible for Cappello Group to follow up on the requests you have made, but only to inform you about any offers and / or new products and / or initiatives.

5. Methods for processing your personal data

The processing of your personal data will take place, in compliance with the provisions of the GDPR, by means of paper, IT and telematic tools, for the purposes indicated and, in any case, with suitable methods to guarantee their security and confidentiality in accordance with the provisions of the Article 32 of the GDPR.

6. To which subjects your personal data may be disclosed and who can learn about them

For the pursuit of the purposes described in the previous article 3, your personal data will be disclosed to employees, external consultants and, in general, to the staff of Cappello Group, who will operate as persons authorized to process personal data.

Furthermore, Cappello Group may need to communicate your personal data to third parties belonging, in particular to the following categories:
- subjects that provide services for the management of the Data Controller's IT systems;

- subjects that provide technical assistance services;
- subjects that provide logistic or transport services;
- subjects who provide professional services of tax, legal and judicial consultancy and assistance;
- supervisory and control authorities and bodies and, in general, public or private entities with publicistic functions.
The subjects belonging to the above categories will operate, in some cases, as separate data controllers, in other cases, as data processors specifically appointed by the Data Controller pursuant to Article 28 of the GDPR. At any time you can request the list of data processors by contacting the Data Controller at the addresses indicated in the previous one

article 1.
Your personal data will not be disclosed to the public.

7. Your rights as an interested party
In relation to the treatments described in this Notice, you may exercise the rights listed in this section, enshrined in Articles 15 to 21 of the GDPR. In particular:

right of access: right to obtain confirmation as to whether or not personal data concerning you are being processed and, in this case, to obtain access to your personal data - including a copy of the same - and communication, among others , of the following information:
a) purpose of the processing;
b) categories of personal data processed;
c) recipients to whom these have been or will be communicated;
d) data retention period or criteria used;
e) rights of the interested party (rectification, cancellation of personal data, limitation of processing and right to object to processing;
f) right to lodge a complaint;
g) the right to receive information on the origin of my personal data if they have not been collected from the interested party;
h) the existence of an automated decision-making process, including profiling;

right of rectification: right to obtain the rectification of inaccurate personal data concerning you and / or the integration of incomplete personal data;

right to cancellation (right to be forgotten) : right to obtain the cancellation of personal data concerning you, when:
a) the data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;
b) You have withdrawn your consent and there is no other legal basis for the processing;
c) You have successfully opposed the processing of your personal data;
d) the data have been unlawfully processed, ì;
e) the data must be deleted to fulfill a legal obligation;
f) the personal data have been collected in relation to the offer of information society services referred to in Article 8, paragraph 1, GDPR.
The right to erasure does not apply to the extent that the processing is necessary for the fulfillment of a legal obligation or for the performance of a task carried out in the public interest or for the ascertainment, exercise or defense of a right. in court;

right to limitation of treatment : right to obtain limitation of treatment, when:
a) the data subject disputes the accuracy of the personal data;
b) the processing is unlawful and the interested party opposes the cancellation of personal data and requests instead that its use be limited;
c) personal data are necessary for the interested party to ascertain, exercise or defend a right in court;

right to object : right to object to the processing of personal data concerning you, unless there are legitimate reasons for the Data Controller to continue processing;

right to data portability: right to receive, in a structured format, commonly used and readable by an automatic device, the personal data concerning you provided to the Data Controller and the right to transmit them to another data controller without impediments, if the processing is based on consent and is carried out by automated means. Furthermore, the right to obtain that your personal data be transmitted directly by Cappello Group to another owner if this is technically feasible;
propose a complaint to the Guarantor Authority for the protection of personal data, Piazza di Montecitorio n. 121, 00186, Rome (RM).
The above rights may be exercised against the Data Controller by contacting the references indicated in point 1 above.

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