Data Controller

FeDI srl – Registered Office: Via Francesco Vela 35, Turin (Italy)
Owner’s email address: info@fedisrl.com

Types of Data Collected

Among the Personal Data collected by fedisrl.com, either independently or through third parties, are: Tracking Tools; Usage Data; Data disclosed during use of the service; name; phone number; company name; email; answers to questions; clicks; keypress events; motion sensor events; mouse movements; position relative to scrolling; touch events; number of Users; city; device information; session statistics; latitude (of the city); longitude (of the city); browser information. Full details on each type of Personal Data collected are provided in the relevant sections of this privacy policy or by means of specific information texts displayed prior to the collection of such Data. Personal Data may be freely provided by the User or, in the case of User Data, automatically collected during the use of fedisrl.com.

Further information for users

LEGAL BASIS FOR PROCESSING

The Controller processes Personal Data relating to the User if one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Controller may be allowed to process Personal Data without the User’s consent or any of the other legal bases specified below, until the User objects (“opts-out”) to such processing. However, this does not apply where the processing of Personal Data is governed by European legislation on the protection of Personal Data;
• the processing is necessary for the performance of a contract with the User and/or the execution of precontractual measures;
• processing is necessary to comply with a legal obligation to which the Controller is subject;
• the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
• processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.

However, it is always possible to ask the Controller to clarify the concrete legal basis of each processing operation and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.

ULTERIORI ADDITIONAL INFORMATION ON RETENTION TIME

Unless otherwise stated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligation or on the basis of Users’ consent.

Consequently:

• Personal Data collected for purposes related to the performance of a contract between the Controller and the User will be retained until the performance of that contract is completed.
• Personal Data collected for purposes related to the legitimate interest of the Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When the processing is based on the User’s consent, the Controller may keep the Personal Data for a longer period until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this period, the right of access, cancellation, rectification, and the right to Data portability can no longer be exercised.

USER RIGHTS

Users may exercise certain rights with reference to the Data processed by the Data Controller.

Within the limits provided for by law, the User has the right to:

• withdraw consent at any time. The User may revoke his or her previously expressed consent to the processing of his or her Personal Data. 
• oppose the processing of their Data. The User may object to the processing of his or her Data when it is done on a legal basis other than consent.
• access to their Data. The User has the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the Data processed.
• verify and request rectification. The User may verify the correctness of its Data and request that it beupdated or corrected.
• obtain restriction of processing. The User may request the restriction of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
• obtain the deletion or removal of their Personal Data. The User may request the deletion of its Data by the Controller.
• receive their Data or have them transferred to another data controller. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller.
• Propose a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.

Users have the right to obtain information on the legal basis for the transfer of Data abroad, including to any international organisation governed by international law or consisting of two or more countries, such as the UN, as well as on the security measures taken by the Data Controller to protect their Data.

Details of the right to object

Where Personal Data are processed in the public interest, in the exercise of official authority vested in the Controller or in pursuit of a legitimate interest of the Controller, Users have the right to object to the processing on grounds relating to their particular situation.
Users are informed that, should their Data be processed for direct marketing purposes, they may object to such processing at any time, free of charge and without giving any reasons. Should Users object to the processing for direct marketing purposes, the Personal Data shall no longer be processed for such purposes. To find out whether the Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise rights

To exercise their rights, Users may address a request to the Controller’s contact details indicated in this document. The request may be filed free of charge and the Controller will reply as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectification,
cancellation or restriction of processing shall be communicated by the Controller to each of the recipients, if any, to whom the Personal Data have been transmitted, unless this proves impossible or involves a disproportionate effort. The Controller shall notify the User of such recipients if he so requests.

Further information on treatment

DEFENCE IN COURT

The User’s Personal Data may be used by the Owner in legal proceedings or in the preparatory phases to its possible establishment for the defence against abuses in the use of fedisrl.com or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

SPECIFIC INFORMATION

Upon the User’s request, in addition to the information contained in this privacy policy, fedisrl.com may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

SYSTEM LOGS AND MAINTENANCE

For operational and maintenance purposes, fedisrl.com and any third-party services it uses may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User’s IP address.

INFORMATION NOT CONTAINED IN THIS POLICY

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

CHANGES TO THIS PRIVACY POLICY

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying the Users on this page and, if possible, on fedisrl.com as well as, when technically and legally feasible, by sending a notification to the Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.
If the changes affect processing whose legal basis is consent, the Controller will collect the User’s consent again, if necessary.

DEFINITIONS AND LEGAL REFERENCES

Personal Data (or Data)

Personal data is any information that, directly or indirectly, even in conjunction with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

This is the information automatically collected through fedisrl.com (also by third party applications integrated in fedisrl.com), including: IP addresses or domain names of the computers used by the User who connects with fedisrl.com, URI (Uniform Resource Identifier) notation addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server response (successful, error, etc.. ) the country of origin, the characteristics of the browser and the operating system  used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s computer environment.

User

The individual who uses fedisrl.com which, unless otherwise specified, coincides with the Interested Party.

Data subject

The natural person to whom the Personal Data refer.

Data Controller (or Processor)

The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Controller, as set out in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of fedisrl.com. The Data Controller, unless otherwise specified, is the owner of fedisrl.com.

fedisrl.com (or this Application)

The hardware or software tool through which Users’ Personal Data are collected and processed.

Service

The Service provided by fedisrl.com as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document shall be deemed to
extend to all current member states of the European Union and the European Economic Area.

Cookies

Cookies are tracking tools that consist of small pieces of data stored within the User’s browser.

Tracking Instrument

Tracking Tool means any technology – e.g. cookies, unique identifiers, web beacons, embedded scripts, etags and fingerprinting – that allows Users to be tracked, for example by collecting or storing information on the User’s device.

Legal references

Unless otherwise specified, this privacy policy relates exclusively to fedisrl.com

Unless otherwise specified, all Data requested by fedisrl.com are mandatory. If the User refuses to communicate them, it may be impossible for fedisrl.com to provide the Service. In cases where fedisrl.com indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users in doubt as to which Data are mandatory are encouraged to contact the Controller.
The possible use of Cookies – or other tracking tools – by fedisrl.com or the owners of third party services used by fedisrl.com has the purpose of providing the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy.
The User assumes responsibility for Personal Data of third parties obtained, published or shared through fedisrl.com.

Method and place of processing of collected Data

METHODS OF PROCESSING

The Controller takes appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.

The processing is carried out using computer and/or telematic instruments, with organisational methods and logics strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of fedisrl.com (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller, may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

LOCATION

The Data are processed at the premises of the Controller and at any other place where the parties involved in the processing are located. For further information, please contact the Controller.

Your Personal Data may be transferred to a country other than the country where You are located. To obtain further information on the processing location You may refer to the section on Personal Data processing details.

RETENTION PERIOD

Unless otherwise stated in this document, Personal Data are processed and kept for the time required by the purpose for which they were collected and may be kept for a longer period due to any legal obligation or on the basis of Users’ consent.

Purposes of the Data collected.

The User’s Data are collected to enable the Data Controller to provide the Service, to comply with legal obligations, to respond to requests or enforcement actions, to protect its rights and interests (or those of Users or third parties), to detect any malicious or fraudulent activities, and for the following purposes: Statistics, Contacting the User, Tag Management and SPAM Protection.

In order to obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the section ‘Personal Data Processing Details’.

Details of Personal Data Processing

Personal Data are collected for the following purposes and using the following services:

CONTACT THE USER

Contact form (fedisrl.com)

The User, by filling in the contact form with his/her Data, consents to the use of such Data to respond to requests for information, quotes, or of any other nature indicated in the header of the form.

Dati Personali trattati: e-mail; nome; numero di telefono; ragione sociale.

TAG MANAGEMENT

This type of service is functional for the centralised management of tags or scripts used on fedisrl.com.

The use of these services involves the flow of User Data through them and, where appropriate, their retention.

Google Tag Manager (Google LLC)

Google Tag Manager è un servizio di gestione dei tag fornito

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data Processed: Tracking Tools.

Place of processing: United States – Privacy Policy.

PROTECTION FROM SPAM

This type of services analyses fedisrl.com traffic, potentially containing Users’ Personal Data, in order to filter it from traffic, messages and content recognised as SPAM.

Google reCAPTCHA (Google Ireland Limited)

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.

Use of reCAPTCHA is subject to Google’s privacy policy and terms of use.

Personal Data Processed: clicks; Usage Data; keypress events; motion sensor events; touch events; mouse movements; scrolling position; answers to questions; Tracking Tools.

Place of processing: Ireland – Privacy Policy.

STATISTICS

The services contained in this section allow the Data Controller to monitor and analyse traffic data and serve to track User behaviour.

Google Analytics 4 (Google Ireland Limited)

Google Analytics is a statistics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of fedisrl.com compile reports and share them with other services developed by Google.

Google may use Personal Data to contextualise and personalise ads in its advertising network.

In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data are recorded in any data centre or server. To learn more, you can consult Google’s official documentation.

Personal Data Processed: city; Usage Data; browser information; device information; latitude (of city); longitude (of city); number of Users; session statistics; Tracking Tools.

Place of processing: Ireland – Privacy Policy – Opt Out.

Information on how to deactivate interest-based advertisements

In addition to any opt-out functionality provided by any of the services listed in this document, Users can read more about how to disable interest-based advertisements in the appropriate section of the Cookie Policy.

Cookie Policy

Fedisrl.com makes use of Tracking Tools. To learn more, Users may consult the Cookie Policy.

More informations for users

LEGAL BASIS FOR PROCESSING

The Controller processes Personal Data relating to the User if one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Controller may be authorised to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opts-out”) to such processing. This does not apply, however, where the processing of Personal Data is governed by European legislation on the protection of Personal Data;

• the processing is necessary for the performance of a contract with the User and/or the performance of pre-contractual measures;

• the processing is necessary to comply with a legal obligation to which the Controller is subject;

• the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;

• processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.

However, it is always possible to ask the Controller to clarify the concrete legal basis of each processing operation and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.

ADDITIONAL INFORMATION ON RETENTION TIME

Unless otherwise stated in this document, Personal Data are processed and kept for the time required by the purpose for which they were collected and may be kept for a longer period due to any legal obligation or on the basis of Users’ consent.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Controller and the User will be retained until the performance of that contract is completed.

Personal Data collected for purposes related to the legitimate interest of the Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When the processing is based on the User’s consent, the Controller may keep the Personal Data for a longer period until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this period, the right of access, cancellation, rectification and the right to Data portability can no longer be exercised.

USER RIGHTS

Users may exercise certain rights with respect to the Data processed by the Data Controller.

Within the limits of the law, the User has the right to:

• withdraw consent at any time. The User may revoke the consent previously given to the processing of his or her Personal Data.

• oppose the processing of their Data. The User may object to the processing of its Data when it is carried out on a legal basis other than consent.
• access to their Data. The User has the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the Data processed.
• verify and request rectification. The User may verify the correctness of its Data and request that it be updated or corrected.
• obtain restriction of processing. The User may request the restriction of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
• obtain the deletion or removal of their Personal Data. The User may request the deletion of its Data by the Data Controller.
• receive their Data or have them transferred to another data controller. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another data controller.
• Propose a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.

Users have the right to obtain information on the legal basis for the transfer of Data abroad, including to any international organisation governed by international law or consisting of two or more countries, such as the UN, as well as on the security measures taken by the Controller to protect their Data.

Details of the right to object

Where Personal Data are processed in the public interest, in the exercise of official authority vested in the Controller or in pursuit of a legitimate interest of the Controller, Users have the right to object to the processing on grounds relating to their particular situation.

Users are informed that, should their Data be processed for direct marketing purposes, they may object to such processing at any time, free of charge and without giving any reasons. Should Users object to the processing for direct marketing purposes, the Personal Data shall no longer be processed for such purposes. To find out whether the Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise rights

To exercise their rights, Users may address a request to the Controller’s contact details indicated in this document. The request may be filed free of charge and the Controller will reply as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectification, cancellation or restriction of processing shall be communicated by the Controller to each of the recipients, if any, to whom the Personal Data have been transmitted, unless this proves impossible or involves a disproportionate effort. The Controller shall notify the User of such recipients if he so requests.

Further information on treatment

DEFENCE IN COURT

The User’s Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages to its possible establishment for the defence against abuses in the use of fedisrl.com or related Services by the User.

The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

SPECIFIC INFORMATION

Upon the User’s request, in addition to the information contained in this privacy policy, fedisrl.com may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

SYSTEM LOGS AND MAINTENANCE

For purposes of operation and maintenance, fedisrl.com and any third-party services it uses may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User’s IP address.

INFORMATION NOT CONTAINED IN THIS POLICY

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

CHANGES TO THIS PRIVACY POLICY

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying the Users on this page and, if possible, on fedisrl.com as well as, when technically and legally feasible, by sending a notification to the Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Controller will collect the User’s consent again, if necessary.

DEFINITIONS AND LEGAL REFERENCES

Personal Data (or Data)

Personal data is any information which, directly or indirectly, even in conjunction with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

This is the information collected automatically through fedisrl.com (including by third party applications integrated into fedisrl.com, including: IP addresses or domain names of computers used by the User who connects with fedisrl.com, URI (Uniform Resource Identifier) notation addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.. ) the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User

The individual who uses fedisrl.com which, unless otherwise specified, coincides with the Interested Party.

Data subject

The natural person to whom the Personal Data refer.

Data Controller (or Processor)

The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Controller, as set out in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of fedisrl.com. The Data Controller, unless otherwise specified, is the owner of fedisrl.com.

fedisrl.com (or this Application)

The hardware or software tool by which Users’ Personal Data are collected and processed.

Service

The Service provided by fedisrl.com as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.

Cookies

Cookies are tracking tools that consist of small pieces of data stored within the User’s browser.

Tracking Instrument

Tracking Tool means any technology – e.g. cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that allows Users to be tracked, for example by collecting or storing information on the User’s device.

Legal references

Unless otherwise specified, this privacy policy relates exclusively to fedisrl.com.