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EXTENDED INFORMATION PURSUANT TO ARTICLES 12, 13 AND, IF APPLICABLE, 14 OF THE GDPR – REGULATION (EU) 2016/679 ON THE PROTECTION OF NATURAL PERSONS WITH REGARD TO THE PROCESSING OF PERSONAL DATA (HEREINAFTER THE GDPR)

The data controller reports, below, the Information pursuant to articles 12, 13 and, if applicable, 14 of the GDPR relating to the processing of personal data provided by the Customer/interested party by completing and signing the Contract to purchase the products/services offered for sale by the data controller himself, spontaneously uploading personal data to this website (in particular by filling in forms) or simply by browsing it.

1. Data controller and contact details

The data controller is Calzificio figli di G. Vitrano snc, with registered office in Palermo, Via Giuseppe Ingegneros 52, P.I. 03084610827, tel. 091 6884551, e-mail This email address is being protected from spambots. You need JavaScript enabled to view it., web http://www.calzevitrano.it// (hereinafter the Site).

2. Principles applicable to processing

In accordance with the provisions of the GDPR, the data controller constantly works to ensure that personal data are:

  1. processed lawfully, fairly and transparently;
  2. collected for specific, explicit and legitimate purposes, and subsequently processed in a manner that is not incompatible with those purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. exact and, if necessary, updated;
  5. kept for a period of time not exceeding the achievement of the purposes for which they are processed;
  6. processed, using appropriate technical and organizational measures, in a manner that ensures their security;
  7. processed, if by consent, by decision freely taken by the Customer/data subject, on the basis of a request presented in a manner that is clearly distinguishable from the rest, in an intelligible and easily accessible form, using clear and simple language.

This Policy may undergo changes, in line with the evolution of the reference legislation and the technical and organizational measures gradually adopted by the data controller; the Customer/interested party is therefore requested to periodically visit this section of the Site, to view the updates and the Information in the text in force from time to time.

3. Method of processing personal data

The processing of personal data is carried out manually and with electronic tools, with logic strictly related to the purposes indicated below and, in any case, in such a way as to guarantee the security and confidentiality of the data itself.

4. Purpose of the processing of personal data

(4a) Purpose for which the processing of data is necessary
The personal data provided by the Customer/interested party are mainly processed for the execution of the Contract and the management of credit and, more generally, of the relationship arising from the Contract itself.
The provision of data in the Contract or subsequently, during the contractual relationship, for the processing purposes in question is mandatory; therefore, the failure to provide such data, or partial or incorrect provision of such data, makes it impossible to stipulate and/or execute the Contract and, for the Customer/interested party, to use the products/services offered by the data controller, potentially exposing the Customer/interested party to liability for breach of contract.
The personal data provided by the Customer/interested party may also be processed if this is necessary to fulfill a legal obligation to which the data controller is subject, to safeguard the vital interests of the Customer/interested party or another natural person, to perform a task of public interest or connected to the exercise of public powers vested in the data controller, or to pursue the legitimate interest of the data controller or third parties, provided that the interests or fundamental rights and freedoms of the Customer/interested party do not prevail; even in these cases, the provision of data is mandatory and, therefore, failure to communicate, partial communication or incorrect communication of data may expose the Customer/interested party to possible liabilities and sanctions provided for by the legal system.

(4b) Further purposes of processing following specific and express consent of the Customer/interested party
In addition to the processing purposes set out above, the personal data provided/acquired may be processed, subject to the consent of the Customer/interested party, to be expressed by selecting the box <<Give consent>> on the Contract or on the Site (or by using other social or web applications of the data controller), also for carrying out market research and for making commercial and promotional communications, by telephone (also using the mobile number provided) and automated contact systems (e-mail, sms, mms, fax, etc.), on products/services of the data controller or of companies of the Group to which the data controller may belong.
Consent for the processing purposes set out in this point (4b) is optional; therefore, following any refusal, the data will be processed only for the purposes indicated in the previous point (4a), except as specified below with reference to the legitimate interests of the data controller or third parties.

5. Categories of personal data processed

The data controller mainly processes identification/contact data (name, surname, addresses, type and number of identification documents, telephone numbers, e-mail addresses, tax/invoicing data, except for others) and, if commercial transactions are envisaged, financial data (of a banking nature, in particular current account identifiers, credit card numbers, except for others connected to the aforementioned commercial transactions).

The processing that the data controller carries out, both for the execution of the Contract and by virtue of the express consent of the Customer/interested party, does not generally concern particular categories of personal data, known as sensitive (which reveal racial or ethnic origin, political opinions, religious beliefs, state of health or sexual orientation, etc.), nor genetic and biometric data or so-called judicial data (relating to criminal convictions and offences).
However, it cannot be excluded that the data controller, in order to perform the obligations arising from the Contract, must retain and/or need to process sensitive, genetic and biometric or judicial data, of the Customer/interested party or third parties, of which the Customer/interested party has access in the capacity of data controller; in the case in question, the processing by the data controller takes place under the conditions and within the limits of the appointment of the same data controller as data processor, by the Customer/interested party.
The data controller processes, in the capacity of data controller with reference to the Site, and, potentially, as data processor appointed to do so (in the terms above) by the Customer/interested party, also the so-called navigation data. The computer systems and software procedures used to operate the websites acquire, during their normal operation, some personal data, the transmission of which is implicit in the use of internet communication protocols. This is information that is not collected to be associated with identified subjects, but which, by its very nature, could allow the identification of the interested party. This category of information includes geolocation data, IP addresses, browser type, operating system, domain name and website addresses from which access or exit was made, information on the pages visited by users within the site, access time, time spent on a single page, internal path analysis and other parameters relating to the operating system and the user's IT environment. Therefore, this is information that, by its very nature, allows, through processing and associations also with data held by third parties, to identify users.
The Site may also use cookies, both session cookies (which are not stored on the interested party's computer and disappear when the browser is closed) and persistent cookies, for the transmission of personal information, or in any case systems for tracking the interested parties.

6. Source of personal data

The personal data that the data controller processes are collected directly by the data controller from the Customer/interested party at the time of, and during, the navigation of the latter on the Site (or using other social or web applications of the data controller), or, also through its own sales representatives, at the time of, or after, the signing of the Contract, during the execution of the same, or from public sources.

As specified above, the data controller, as the data controller responsible for the processing in charge, in order to perform the obligations arising from the Contract, may store and/or process data, in particular navigation data, potentially also sensitive, genetic and biometric or judicial, of third parties, of which the Customer/interested party has access in the capacity of data controller, acquired, with the prior consent of said third parties, at the time of, and during, the navigation of the same third parties on the Site (or using other social or web applications referable to the data controller).

7. Legitimate interests

The legitimate interests of the data controller or third parties may constitute a valid legal basis for processing, provided that the interests or fundamental rights and freedoms of the data subject do not prevail. In general, such legitimate interests may exist when there is a relevant and appropriate relationship between the data controller and the data subject, for example when the data subject is a customer of the data controller. In particular, it constitutes a legitimate interest of the data controller to process personal data of the Customer/data subject: for fraud prevention purposes, for direct marketing purposes, to ensure the free circulation of the same data within the business group to which the data controller may belong, or relating to traffic, in order to guarantee network and information security, i.e. the ability of a network or system to resist unforeseen events or unlawful acts that may compromise the availability, authenticity, integrity and confidentiality of the data.

8. Circulation of personal data

(8a) Communication of personal data – categories of recipients
In addition to the employees and collaborators of the data controller in various capacities (who are authorised by the data controller to process data by virtue of adequate written operating instructions, in order to guarantee the confidentiality and security of the data), some processing operations may also be carried out by third parties, to whom the data controller entrusts certain activities, or part of them, functional to the purposes referred to in point (4a), therefore both in execution of contractual and legal obligations, among which the following deserve mention, by way of a non-exhaustive title: commercial and/or technical partners; companies that provide banking and financial services; companies that perform document archiving services; debt collection companies; accounting and balance sheet certification companies; rating companies; subjects that perform, for the data controller, professional assistance and consultancy activities; companies that carry out customer care activities; factoring companies, credit securitisation companies or other credit transferees; companies of the Group to which the data controller may belong; subjects that provide commercial information; IT service companies. The subjects belonging to the aforementioned categories process the personal data as independent data controllers, or as data processors, with reference to specific processing operations that fall within the contractual services that the subjects themselves perform in favor/in the interest of the data controller; the data controller provides the data processors with adequate written operating instructions, with particular reference to the adoption of minimum security measures, in order to guarantee the confidentiality and security of the data.
Some processing operations may be carried out by third parties, to whom the data controller entrusts certain activities, or part of them, also functionally to the purposes referred to in point (4b), among which the following deserve mention, by way of a non-exhaustive title: commercial and/or technical partners; companies that institutionally provide marketing services; advertising agencies; subjects that provide assistance and consultancy with reference to competitions and prize operations. The subjects belonging to the aforementioned categories process personal data as independent data controllers, or as data processors, with reference to specific processing operations that fall within the contractual services that the subjects themselves perform in favor/in the interest of the data controller; the data controller provides the data processors with adequate written operating instructions, with particular reference to the adoption of minimum security measures, in order to guarantee the confidentiality and security of the data.
The list, subject to periodic updating, of the data processors with whom the data controller maintains relationships is available, upon written request to be sent to the headquarters of the data controller.
Furthermore, personal data may be communicated, upon request, to the competent authorities, in compliance with obligations arising from mandatory provisions of law.

(8b) Transfer of personal data to third countries
The personal data of the Customer/data subject may also be transferred abroad, both to countries of the European Union and to countries outside the European Union and, in the latter case, either on the basis of an adequacy decision, or within the scope and with the appropriate guarantees provided for by the GDPR (therefore, in particular, in the presence of standard contractual clauses for data protection approved by the European Commission), or, outside the hypotheses mentioned above, using one or more of the derogations provided for by the GDPR (in particular, by virtue of the explicit consent of the Customer/data subject, or for the execution of the Contract concluded by the Customer/data subject, or for the execution of a contract stipulated between the data controller and another natural or legal person in favor of the Customer/data subject, in particular for the execution of activities delegated to the latter by the data controller for the execution of the Contract concluded with the Customer/data subject). In the event of data transfers to countries outside the European Union, the Customer/interested party is allowed, upon written request to be sent to the headquarters of the data controller, to know the adequate guarantees, or the derogations, that legitimise cross-border processing. It is understood, in the event of data transfer to countries outside the European Union, that for any request relating to the data, including for the exercise of the rights recognised by the GDPR to the Customer/interested party, the latter may always validly contact the data controller.

9. Criteria for determining the period of retention of personal data

For the purposes referred to in point (4a) above, the period of retention of personal data released by the Customer/interested party, and their consequent potential processing, coincides with the period of prescription of the rights/duties (legal, fiscal, etc.) arising from the Contract: generally 10 years, therefore, unless there are events interrupting the prescription that could, in fact, extend said period.
For the purposes referred to in point (4b) above, the retention period of the data released by the Customer/interested party, and their consequent potential processing, ends with the revocation of the consent previously released by the Customer/interested party himself or, in the absence of this, in any case after one year from the cessation of any relationship between the data controller and the Customer/interested party.

10. Rights of the Customer/interested party

The data controller recognizes - and facilitates the exercise, by the Customer/interested party, of - all the rights provided for by the GDPR, in particular the right to request access to their personal data and to extract a copy thereof (art. 15 GDPR), to rectification (art. 16 GDPR) and to the erasure of the same (art. 17 GDPR), to the limitation of the processing that concerns them (art. 18 GDPR), to the portability of the data (art. 20 GDPR, where the conditions are met) and to object to the processing that concerns them (arts. 21 and 22 GDPR, for the hypotheses mentioned therein and, in particular, to the processing for marketing purposes or that results in an automated decision-making process, including profiling, which produces legal effects that concern them, where the conditions are met).
The data controller also recognizes the Customer/interested party, if the processing is based on consent, the right to withdraw said consent at any time, without prejudice to the lawfulness of the processing based on the consent given before the withdrawal. To do so, the Customer/interested party can unsubscribe at any time on the Site (or on other social or web applications of the data controller) or by using the appropriate link at the bottom of each commercial communication received, or by contacting the data controller at the contact details above.
The data controller also informs the Customer/interested party of the right to lodge a complaint with the Personal Data Protection Authority, as the supervisory authority operating in Italy, and to lodge a judicial appeal, both against a decision of the Guarantor Authority and against the data controller and/or a data processor.

11. Security of systems and personal data

Taking into account the state of the art, the costs of implementation, as well as the nature, scope, context and purposes of processing as well as the risk, in terms of likelihood and severity, for the rights and freedoms of natural persons, the data controller shall adopt technical and organisational measures deemed appropriate to ensure a level of security appropriate to the risk, in particular by ensuring, on an ongoing basis, the confidentiality, integrity, availability and resilience of processing systems and services (including through encryption of personal data, where necessary) and the ability to restore the availability of data in a timely manner in the event of a physical or technical incident, and by adopting internal procedures to regularly test, verify and evaluate the effectiveness of the technical and organisational measures employed.
In assessing the appropriate level of security, account shall be taken of the risks presented by the processing which arise, in particular, from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
The data controller shall ensure that anyone acting under his/her authority and having access to personal data does not process such data unless instructed to do so by the data controller.
That said, the Customer/interested party acknowledges and accepts that no security system guarantees, in terms of certainty, absolute protection; therefore, the data controller is not liable for acts or deeds of third parties who abusively, despite the adequate precautions adopted, should access the systems without the necessary authorizations.

12. Automated decision-making processes, including profiling

The data controller may carry out automated processing, including profiling, in relation to the purposes referred to in point (4b) above, to optimize the navigability of the Site (or the usability of other social or web applications of the data controller) and to improve the purchasing experience, except as specified above with regard to the rights of opposition and withdrawal of consent by the Customer/interested party.
Profiling means any form of automated processing of personal data aimed at evaluating certain aspects relating to a natural person, in particular to analyze or predict aspects concerning, for example, the personal preferences, interests or location of that person, also for the purpose of creating profiles, or homogeneous groups of subjects by characteristics, interests or behaviors.

The data controller does not carry out any automated processing that produces legal effects concerning the Customer/interested party or that significantly affects his/her person, unless this is necessary for the conclusion or execution of the Contract, is authorised by law or is based on the explicit consent of the Customer/interested party, in any case always recognising the latter's right to obtain human intervention, to express his/her opinion and to contest the decision.