PRIVACY POLICY

INFORMATION ON THE PROCESSING OF PERSONAL DATA PURSUANT TO ART. 13 – 14 OF EU REGULATION 2016/679 AND CONSENT

Pursuant to the EU Regulation 2016/679 (hereinafter Regulation or “RGPD”) and the applicable national legislation on the protection of personal data this information is provided: to individuals acting on behalf of and for Clients, to the Client-themselves if a natural person (e.g. sole proprietor or professional), utents of the site (cavarzan.it), potential Customers, later also Interested Parties:

1. Data controller: CAVARZAN srl VIA TONIOLO 11 31030 ALTIVOLE (TREVISO), C.F. and P.IVA 03418190280 , Tel. +39 0423 915606, email: info@cavarzan.it, website cavarzan.it.
2. Type of data processed – The personal data processed are collected directly from the Data Subjects or from the company they work for, during the pre-contractual activities, the conclusion and execution of the contract. Such common data are biographical data (surname and first name, …), contact details (phone number, e-mail address, …). The Contractors do not process any “sensitive” or “special” data (see Article 9 of the RGPD). The processing of personal data is carried out, in compliance with the provisions of the RGPD and the Privacy Regulations in force, using manual, paper, computer and telematic tools, including automated tools and in accordance with the principles of correctness, lawfulness and transparency so as to ensure the security and confidentiality of the data. In particular, processing may be done through automated systems (such as electronic mail, SMS Short Message Service or other type of electronic communication) and traditional systems.
3. Purposes, legal basis for processing, and obligatory nature of providing data – The Co-Processors process personal data:
   1. for purposes strictly related and instrumental to the management and execution of contracts with Customers (e.g. acquisition of information prior to the conclusion of a contract, provision of services, management of evolutionary requests, assistance, …). The provision of personal data for this purpose and its processing are necessary to the extent that Data Subjects deem it necessary to disclose it in order to ensure the effectiveness of the pre-contractual, disbursement and assistance activities carried out by the Contractors. Such processing operations do not require the consent of the Data Subjects. The legal basis for processing is identified in the need to enter into or perform a contract;
   2. in the case of sole proprietorships or professionals, for purposes of protecting the assets and rights of the Joint Owners, such as acquiring information pertaining to the solvency of the same or such as debt collection. The data are necessary for the conclusion of the contract. The legal basis for the processing is identified in the legitimate interest of the Joint Holders and consent is not required;
   3. for direct/indirect marketing purposes (illustrative and non-exhaustive list): sending of commercial information and newsletters, communication of promotional initiatives and events of the Contractors and technology partners. The provision of personal data for these purposes is not obligatory and its processing requires the consent of the data subjects. Failure to provide consent will not affect the service provided but will result in the inability of the Contractors to send you commercial communications. The legal basis for processing is identified in express consent.
4. Categories of recipients of personal data: personal data, to the extent and for the purposes indicated, may be communicated to or come to the attention of and thus be processed by:
   1. Expressly authorized employees and contractors of the Joint Owners;
   2. consultants of the Contractors, marketing agencies, agents, companies that provide IT services (site management, internet services, …), possibly in their capacity as external data controllers;
   3. technology partners of the Joint Owners;
   4. forwarders or carriers for the goods to be delivered/received;
   5. companies specializing in Customer creditworthiness information systems, companies and/or professionals for debt collection;
   6. Subjects who can access the data by virtue of legal provision, or EU regulations, within the limits provided by law.
   7. The full list of recipients is available at the office of the Joint Holders.
5. Data Retention Period: the personal data in question are processed for the duration of the business relationship and also thereafter for a maximum of 10 years; for marketing purposes, the data are processed and retained until consent is revoked.
6. Transfer of data abroad: processing is carried out within the European Economic Area (EEA) and data may be transferred to the U.S.; in the latter case, the guarantee of data protection is the signing of appropriate contractual clauses suitable to ensure an adequate level of protection.
7. Automated decision-making processes: any automated decision-making process including profiling is excluded.
8. Rights of the Data Subject: the Data Holders inform that, with reference to the data provided, you as the Data Subject have the following rights:
   1. to access the data and obtain a copy: to obtain confirmation as to whether or not your Personal Data is being processed and, if so, to obtain access to the Personal Data and information provided for in Art. 15 of the RGPD, including but not limited to: the purposes of the processing, the categories of Personal Data processed, etc;
   2. of rectification: to obtain the rectification of your Personal Data that are inaccurate as well as, taking into account the purposes of the processing, the integration of the same, if they are incomplete, by providing adequate documentation;
   3. of deletion of personal data: to request the deletion of your Personal Data, if any of the grounds provided for in Art. 17 of the GDPR, including, but not limited to, if the Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed or if the consent on which the processing of your Personal Data is based has been withdrawn by you and there is no other legitimate reason for the processing. The Data Controllers may not proceed to the deletion of your Personal Data: if their processing is necessary, for example, for the fulfillment of a legal obligation or for the establishment, exercise or defense of a right in a court of law;
   4. of restriction of processing: to obtain the restriction of the processing of your Personal Data if one of the cases provided for in Art. 18 of the Regulations, including, for example: contesting the accuracy of your Personal Data, for the period necessary for the Data Controllers to make the appropriate verifications; objecting to the processing, pending the appropriate verifications by the Data Controllers as to whether the reasons for the processing itself prevail;
   5. to the portability of electronic data that are subject to automated processing: to obtain a copy of the Personal Data you have provided in a structured, commonly used, machine-readable format (example: computer and/or tablet); to transmit your Personal Data received to another entity, the Data Controller, without hindrance from the Data Controllers and based on your precise authorizations and indications;
   6. to object to processing: to block processing if it is carried out in pursuit of a legitimate interest of the Data Controller, unless there are legitimate grounds for processing (grounds overriding the interests, rights and freedoms of the data subject), or processing is necessary for the establishment, exercise or defense in court of a right;
   7. of revocation of consent to processing, without prejudice to the lawfulness of processing based on consent acquired prior to revocation;
   8. to file a complaint with the competent supervisory authority: the Data Protection Authority.
9. Contact details: for any clarification and to exercise their rights, data subjects may contact the Joint Owners by writing to the Centralized Privacy Function:

CAVARZAN Ltd.
VIA TONIOLO 11
31030 ALTIVOLE (TREVISO)
C.F. and VAT no. 03418190280
Tel. +39 0423 915606
or by writing an e-mail message to
email: info@cavarzan.it