Policy privacy
Simta S.p.A. located in Corso Svizzera, 185 – 10149 Turin (TO), (hereinafter “SIMTA”), acting as Data Controller under the terms of d. lgs. 196/2003 and subsequent amendments – “Codice in materia di protezione dei dati personali” (“Privacy Code”) – and the EU Regulation 679/2016 applicable since 25th May 2018 – General Data Protection Regulation (“GDPR”) (Privacy Code and GDPR shall be hereinafter collectively indicated as “Applicable Law”) acknowledges the importance of personal data protection and considers its protection one of the objectives of its activity.
Before communicating any personal data, Simta invites you to read carefully this privacy policy (“Privacy Policy”) as it contains important information on the protection of personal data and on the safety measures adopted in order to guarantee their confidentiality in full compliance with the Applicable Law.
Furthermore, this Privacy Policy is intended applied to the website https://www.simtaspa.com/ and it is not applied to any other website visited through external links; this Privacy Policy is to be intended as aimed towards those who interact with the Website in compliance with art. 13 of the Applicable Law.
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Simta informs you that your personal data processing will be carried out in accordance with the principles of lawfulness, fairness, transparency, accuracy, purpose and storage limitations, data minimization, integrity, and confidentiality. Your personal data will be treated in compliance with the Applicable Law’s legislative dispositions and with the confidentiality obligations referred to therein.
INDEX
The index of this Privacy Policy will follow, so you will be able to easily find information about your personal data processing.
1. DATA CONTROLLER
2. PERSONAL DATA SUBJECT TO PROCESSING
a. Navigation Data
b. Data provided voluntarily
c. Cookies and related technologies
3. PURPOSE, LEGAL BASIS AND COMPULSORY OR OPTIONAL NATURE OF PROCESSING
4. MODALITIES
5. RECIPIENTS
6. TRANSFERS
7. DATA STORAGE
8. YOUR RIGHTS
9. AMENDMENTS
1. DATA CONTROLLER
With reference to the Applicable Law, we inform you that the Data Controller is Simta, whose data is reported on the website’s Home Page and/or on other web pages of the same.
2. PERSONAL DATA SUBJECT TO PROCESSING
“Personal Data” means information about a physical person identified or identifiable with particular reference to an identification such as the name, identification number, location, online identification, or one or more elements characteristic of their physical, physiological, psychological, economic, cultural, or social identity.
The Personal Data collected by the Website are the following:
a. Navigation Data
The Website’s computing systems collect some Personal Data whose transmission is implicit in the usage of communication protocols on the Internet. This is information which is not collected to be linked to you, but which, for its inherent nature and by elaboration and association with data held by third parties, could allow your identification. Among these, the IP addresses or domain names of the devices used to access the Website, URI addresses of the requested resources, time of the request, the method used to submit your request to the server, the size of the file received in response, the number code which indicates the outcome of the response from the server (successful, error, etc.) and other parameters linked to your operative system and computing environment are included.
These data are used in order to obtain anonymous statistic information on the use of the Website and to check its proper functioning; in order to allow – given the architecture of the systems used – the proper delivery of the functionalities you have requested, for security reasons and to ascertain responsibility in case of hypothetical cyber-crimes to the detriment of the Website or third parties, and cancelled after 7 days and, in any case, these data are kept by the Data Controller of the Website for the period strictly necessary and always in conformity with the current legal provisions in the matter.
b. Data provided voluntarily
On the Website, you can voluntarily provide Personal Data in the sections “Work with us” or contact Simta through the “Contacts” form or other similar services. The users are free to provide their information but failure to provide it may result in an impossibility to obtain the requested service. Simta will treat this data in compliance with the Applicable Law, assuming that they are referring to you or to third parties who gave you their explicit consent to provide them based on a legal basis which legitimates the treatment of the data in question. With respect to this last case, you are your own data controller, undertaking all the legal obligations and responsibilities. In this sense, you give maximum indemnification concerning any dispute, demand, request of compensation from data processing damage, etc. that shall be received by Simta from third parties whose Personal Data has been processed through your usage of this Website in violation of the Applicable Law.
c. Cookies and similar technologies
Simta gathers Personal Data through cookies. More information on the use of cookies and similar technologies can be found here.
3. PURPOSE, LEGAL BASIS AND COMPULSORY OR OPTIONAL NATURE OF PROCESSING
The Personal Data you are providing through this Website will be processed by Simta for the following purposes:
a) Purposes regarding the application of a contract of which you are part of or the application of pre-contractual measures adopted upon your request (ex: request to be contacted through the Contact form or by e-mail, etc.);
b) Statistical research/analysis purposes based on aggregated or anonymous data, therefore without the possibility of identifying the user, aimed to measure the performance of the Website, measure data traffic and evaluate usability and interest;
c) Purposes regarding the fulfilment of a legal obligation to which Simta is subject;
d) Purposes aimed to ascertain, exert, or defend a right in a court of Law or any time the jurisdictional authorities exert their jurisdictional functions.
The legal basis of the processing of Personal Data as per point a) is the provision of a service or the response to a request that does not require your prior consent to the Applicable Law.
The purpose per point b) does not entail any Personal Data processing, while the purposes per points c) and d) represent a legitimate treatment of Personal Data as per the Applicable Law as, once the Personal Data have been submitted, their processing is indeed necessary to fulfil a legal obligation to which Simta is subject.
The transmission of your Personal Data for the purposes listed above is optional, however failure to provide consent may render impossible to respond to your request or to fulfil a legal obligation to which Simta is subject.
4. MODALITIES
1. Tools and methods. In relation with the purposes mentioned above, the processing of the user’s personal data takes place through manual, computerized and telematic tools using methods that are strictly related to the purposes outlined above and, in any case, aiming to guarantee adequate security and confidentiality to the data and with commitment on your part to promptly communicate any correction, modification or updates. Said data processing shall be executed on behalf of the Data Controller for the purposes and with the modalities outlined above in accordance with adequate criteria that will guarantee security and confidentiality from societies, studies, entities, and external collaborators appointed Responsible and only for what concerns the processing operations carried out by them.
2. Special categories of data. None of the Personal Data gathered by the Data Controller are attributable to the definition of “Special categories of personal data” as per art.9 of EU Regulation 2016/679. In case such data have been transmitted by you, in the absence of your explicit written consent, it will be our care to immediately cancel them.
5. RECIPIENTS
As per the purposes outlined in point 3, your Personal Data can be shared with: a. Necessary subjects for the provision of a service offered by this Website, such as sending e-mails and the analysis of the Website performance, who acts solely as Simta’s data controllers; b. People authorized by Simta to Personal Data processing who have undertaken to keep the data confidential or who are subject to an adequate legal obligation of confidentiality; (ex. Simta’s employees and collaborators); (a. and b. are collectively “Recipients”); c. Jurisdictional authorities in carrying out their duties when requested by the Applicable Law.
6. TRANSFERS
Some of your Personal Data are transferred to Recipients which may reside outside of the European Economic Area. Simta guarantees that the electronic and paper processing of your Personal Data by the Recipients is carried out in accordance with the Applicable Law. In fact, the data transfers are alternatively based on an adequacy decision or on the Standard Model Clauses approved by the European Commission. More information and a copy of these agreements are available at the Data Controller headquarters.
7. DATA STORAGE
Simta will only keep your data for the time strictly necessary to reach the purposes in point 3. Notwithstanding the above, Simta will keep your Personal Data up to the time allowed by the Italian Law to protect its interests (Art. 2947(1)(3) c.c.). More information on the Personal Data storage time and the criteria adopted to determine this period can be requested by writing an e-mail to info@simtaspa.com.
8. YOUR RIGHTS
Within the limits of the Applicable Law, you have the right to request to Simta, at any time, access to your Personal Data, their correction, or their cancellation or to oppose to their processing operations, to limit the processing operations and to obtain your data in a structured, commonly used and machine-readable format. The requests must be forwarded via e-mail to info@simtaspa.com. According to the Applicable Law, you can also lodge a complaint with the supervisory authority (Garante per la Protezione dei Dati Personali) in case you consider that the way in which your Personal Data have been processed is contrary to existing legislation.
9. AMENDMENTS
Simta reserves the right to modify or simply update, partially or totally, the content of this Privacy Policy, also in response to variations in the Applicable Law. Simta will inform you of these amendments as soon as they are introduced and they shall be binding as soon as they are published on this Website. Simta invites you to regularly check this section so that you are aware of the most recent and updated version of the Privacy Policy in order to always remain up-to-date on the data collected and Simta’s use of them.