Privacy Policy

Siroflex s.r.l

PRIVACY POLICY PROVIDED PURSUANT TO ART. 13 OF THE EUROPEAN GENERAL DATA PROTECTION REGULATION 2016/679 (GDPR)

Siroflex has updated its Privacy Policy.

We will continue to keep you informed about our activities, news and promotions so that, in full compliance with the law, you can take advantage of the best opportunities offered to our contacts.

Some of the security measures we use to protect your information are firewalls, antivirus and access control to information.

Pursuant to and in accordance with the provisions of Article 13 of EU Regulation n. 679/2016, Siroflex Srl Via Valverde 35R 16014 Campomorone (Ge) – VAT No. 00264480104 provides the following information on the processing of personal data carried out by the company, as Data Controller.

This Application collects some Personal Data from its Users.

Users may be subject to different levels of protection. Some Users therefore enjoy superior protection. Further information on the protection criteria can be found in the applicability section.

DATA CONTROLLER

The Data Controller is

Siroflex Srl, Registered Office: Via Valverde 35R 16014 Campomorone (Genova) – VAT No. 00264480104

e-mail: info@siroflex.it  Tel. 010780307, 010781955 – Fax 0107856810.

For all information and requests, the Data Processor can be contacted: e-mail: privacy@siroflex.it

DATA COLLECTION METHODS AND TYPES

The processed data may include common data collected for the purpose of concluding the contract with the customer as well as personal data included in the following categories:

– Economic and commercial activities;

– Bank account details;

– Tax code and other personal identification numbers;

– Visitor data, customers of the siroflex.it corporate website;

– Email address;

– Name, address or other identification elements

Among the Personal Data collected by this Application, either independently or through third parties, there are: Cookies, Usage data, email, name, surname and username.

Full details of each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
The Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.
Unless otherwise specified, all the Data required by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application 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 on its operation.
Users who have doubts about which data are mandatory, are encouraged to contact the owner.
Any use of Cookies – or other tracking tools – by this Application or third party service providers used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes the responsibility of the Personal Data of third parties obtained, published or shared through this Application and guarantees to have the right to communicate or disseminate them, freeing the Owner from any responsibility towards third parties.

Mode and place of processing of the collected Data

Data processing

In relation to the aforementioned purposes, the processing of data takes place through manual, computerized and telematic tools with logics strictly related to the same purposes and, in any case, in such a way as to guarantee the security and confidentiality of the data, as well as compliance with the obligations established by the legislation.
The data will be processed in accordance with the principle of lawfulness, correctness, relevance and not excess, in accordance with the provisions of the legislation on the protection of personal data.
The treatment will be carried out by formally appointed and adequately trained personnel.
If the data controller intends to further process personal data for a purpose other than that for which they were collected, prior to such further processing, they will provide the interested party with information regarding such different purposes and any other relevant information.

The Data Controller uses appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
Processing is carried out using IT and / or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Owner. The updated list of Data Processors may always be requested from the Data Controller.

Legal basis of the processing

The Owner 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 Data Controller may be authorized to process Personal Data without the User’s consent or another legal basis specified below, as long as the User does not object (“opt-out") to such treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;

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

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

–  processing is necessary for the performance of a task of public interest or for the exercise of public powers vested in the Data Controller;

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

It is in any case always possible to ask the Owner to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Place

The Data are processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, contact the owner.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of treatment, the User can refer to the section on the details on the processing of Personal Data.

In case of greater protection, the User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization of public international law or constituted by two or more countries, such as example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

If one of the transfers described above takes place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting him at the details indicated at the beginning.

Data retention

The data will be kept for the period provided for by the fiscal and civil law regulations corresponding to ten years.

The Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.

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

When the treatment is based on the consent of the User, the Owner may keep the Personal Data for longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep the 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, upon expiration of this term the right of access, cancellation, rectification and the right to the portability of the Data can no longer be exercised.

Purposes of the processes

In compliance with current legislation on the protection of personal data and without the need for specific consent from the data subject, the data will be processed by the Company for the following purposes:

  1. Business

– Advertising and propaganda

– Promotion

– Sale

– Post-sales assistance

– Customer care

2. Fulfillment of contractual obligations of which the person concerned is a party.

3. Accomplishment of legal obligations, tax and fiscal provisions deriving from the performance of the business activity and                         obligations connected to administrative-accounting activities, as well as provisions issued by authorities legitimated to do so by               law.

The legal bases of the processing for the purposes indicated above are the articles 6.1b), 6.1c) of the Regulations.

The provision of data for the following purposes is optional, but failure to provide the data and the refusal to provide it would make it impossible for the company to execute and / or enter into the contract and provide the services required by the same.

The User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Statistics, Access to accounts on third party services, Interaction with external social networks and platforms, SPAM protection, Content commenting, Management contacts and sending messages and displaying content from external platforms.

To obtain further detailed information on the purposes of the processing and on the Personal Data that are concretely relevant for each purpose, the User may refer to the relevant sections of this document.

Facebook permissions required by this Application

This Application may require certain Facebook permissions that allow it to perform actions with the user’s Facebook account and to collect information, including Personal Data, from it. This service allows this Application to connect with the User’s account on the Facebook social network, provided by Facebook Inc.

For more information on the following permissions, refer to Facebook permission documentation and to the privacy policy di Facebook.

The required permits are as follows:

Basic information

The basic information of the User registered on Facebook which normally includes the following Data: id, name, image, gender and language of localization and, in some cases, the “Friends" of Facebook. If the User has made additional data publicly available, they will be available.

Access to the News Feed

Provides access to News Feed posts and allows the app to search on it.

Sharing

Sharing in place of the User.

I Like

Provides access to the list of all the pages that the User has marked with the Like.

Details on the processing of Personal Data

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

Access to accounts on third party services

This type of service allows this Application to withdraw Data from your accounts on third party services and perform actions with them.
These services are not activated automatically, but require the express authorization of the User.

Access to Facebook account (this Application)

This service allows this Application to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.
Required permissions: Access to News Feed, Sharing and Like.
Place of processing: United States – Privacy Policy. Subject adherent to the Privacy Shield.

Content comment

The comment services allow Users to formulate and make public their comments regarding the contents of this Application.
Users, depending on the settings decided by the owner, can leave the comment anonymously. In the case of Personal Data released by the User there is email, this could be used to send notifications of comments regarding the same content. Users are responsible for the content of their comments.
In the event that a comment service provided by third parties is installed, it is possible that, even if the Users do not use the commenting service, it collects traffic data relating to the pages in which the commenting service is installed .

Facebook Comments (Facebook, Inc.)

Facebook Comments is a service managed by Facebook, Inc. that allows the User to leave comments and share them within the Facebook platform.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States– Privacy Policy. Subject adherent to the Privacy Shield.

Directly managed comment system (this Application)

This application has its own content commenting system. This application has its own content commenting system.

Personal Data collected: email, name and username.

Manage contacts and send messages

This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User.

These services could also allow you to collect data relating to the date and time of display of the messages by the User, as well as to the User’s interaction with them, such as information on clicks on the links inserted in the messages.

MailChimp (The Rocket Science Group, LLC.)

MailChimp is an address management and email message service provided by The Rocket Science Group, LLC.

Personal Data collected: surname, Cookie, email and name.

Place of processing: United States – Privacy Policy. Subject adherent to the Privacy Shield.

Interaction with external social networks and platforms

This type of service allows interaction with social networks, or other external platforms, directly from the pages of this Application.

The interactions and information acquired by this Application are in any case subject to the User’s privacy settings relating to each social network.

In the event that an interaction service with social networks is installed, it is possible that, even if the Users do not use the service, the same collect traffic data relating to the pages in which it is installed.

Like button and Facebook social widgets (Facebook, Inc.)

The “Like" button and Facebook social widgets are interaction services with the Facebook social network, provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Subject adherent to the Privacy Shield.

Tweet button and Twitter social widgets (Twitter, Inc.)

The Tweet button and Twitter social widgets are interaction services with the Twitter social network, provided by Twitter, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Subject adherent to the Privacy Shield.

YouTube social button and widgets (Google LLC)

The YouTube button and social widgets are interaction services with the YouTube social network, provided by Google LLC.

Personal Data collected: Usage data.

Place of processing: United States – Privacy Policy. Subject adherent to the Privacy Shield.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal Data collected: Cookies; Usage data.

Place of processing: Ireland – Privacy Policy. Subject adherent to the Privacy Shield.

Interaction with live chat platforms

This type of service allows you to interact with live chat platforms, managed by third parties, directly from the pages of this Application. This allows the User to contact the support service of this Application or this Application to contact the User while he is browsing his pages.
In the event that an interaction service is installed with live chat platforms, it is possible that, even if the Users do not use the service, it collects Usage Data relating to the pages in which it is installed. Furthermore, live chat conversations could be recorded.

Facebook Messenger Customer Chat (Facebook, Inc.)

The Facebook Messenger Customer Chat is an interaction service with the Facebook Messenger live chat platform, provided by Facebook, Inc.

Personal Data collected: Cookies; Data communicated during use of the service; Usage data.

Place of processing: United States – Privacy Policy. Soggetto aderente al Privacy Shield.

Registration and authentication

By registering or authenticating, the User allows the Application to identify him and give him access to dedicated services.
Depending on what follows, registration and authentication services could be provided with the help of third parties. If this happens, this application will be able to access some Data stored by the third party service used for registration or identification.

Direct registration (rentbikecarzante.it)

The User registers by filling out the registration form and providing his Personal Data directly to this Application.

Personal Data collected: surname; e-mail; first name; telephone number.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.

Protezione dallo SPAM

This type of service analyzes the traffic of this Application, potentially containing Personal Data of Users, in order to filter it from parts of traffic, messages and contents recognized as SPAM.

Akismet (Automattic Inc.)

Akismet is a SPAM protection service provided by Automattic Inc.

Personal Data collected: various types of Data as specified by the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.

Google Analytics (Google LLC)

Google Analytics is a web analytics service provided by Google LLC (“Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Luogo del trattamento: Stati Uniti – Privacy Policy – Opt Out. Subject adherent to the Privacy Shield.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
In the event that a service of this type is installed, it is possible that, even if the Users do not use the service, it collects traffic data relating to the pages in which it is installed.

Widget Video YouTube (Google LLC)

YouTube is a video content viewing service managed by Google LLC that allows this Application to integrate such content within its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Subject adherent to the Privacy Shield.

DATA SUBJECT RIGHTS

The person concerned:

–  has the right to ask the data controller to access their personal data and to correct or delete them or limit the processing that concerns them or to oppose their treatment, in addition to the right to data portability.

– if they have given their consent for a specific purpose, they have the right to revoke this consent at any time without jeopardizing the lawfulness of the processing based on the consent given before the revocation.

– has the right to lodge a complaint with a supervisory authority.

Users can exercise certain rights with reference to the Data processed by the Owner.

In case of greater protection, the User can exercise all the rights listed below. In any other case, the User can contact the owner to find out what rights are applicable in his case and how to exercise them.

In particular, the User has the right to:

–  withdraw consent at any time. The User can revoke the consent to the processing of his Personal Data previously expressed.

–  object to the processing of your data. You may object to the processing of your data when it takes place on a legal basis other than consent. Further details on the opposition right are indicated in the section below.

–  access to their Data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed.

–  verify and ask for rectification. The User can verify the correctness of his / her Data and request its updating or correction.

–  get the treatment limitation. When certain conditions are met, the User can request the limitation of the processing of his / her Data. In this case, the Owner will not process the Data for any other purpose than their storage.

–  obtain the cancellation or removal of your Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Owner.

–  receive your data or have it transferred to another owner. The User has the right to receive his / her Data in structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its transfer without obstacles to another holder. This provision is applicable when the Data is processed by automated tools and the processing is based on the consent of the User, on a contract to which the User is a party or on contractual measures connected to it.

–  to make a complaint. The User can make a complaint to the competent personal data protection supervisory authority or act in court.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public authority over which the Data Controller is invested or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons connected to their particular situation.

Users are reminded that, if their Data is processed for direct marketing purposes, they may oppose the processing without giving any reason. To find out if the Data Controller is processing data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

To exercise User rights, Users can address a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Applicability of the upper level of protection

While most of the provisions of this document apply to all Users, some are expressly subject to the applicability of a higher level of protection to the processing of Personal Data.

This higher level of protection is always guaranteed when the treatment:

–  it is executed by a Data Controller based in the EU; or

–  concerns Personal Data of Users located in the EU and is functional to the supply of goods or services for a consideration or free of charge to such Users; or

–  concerns Personal Data of Users located in the EU and allows the Owner to monitor the behavior of such Users to the extent that such behavior takes place within the Union.

Cookie Policy

This Application uses Cookies. To learn more and to view the detailed information, the User can consult the Cookie Policy.

Further information on treatment

Defense in court

The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Application or of the connected Services by the User.
The User declares to be aware that the Owner may be required to disclose the Data by order of the public authorities.

Specific information

At the request of the User, in addition to the information contained in this privacy policy, this Application could provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System log and maintenance

For needs related to operation and maintenance, this Application and any third party services it uses may collect system logs, that is files that record the interactions and that may also contain Personal Data, such as the User 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.

Respond to “Do Not Track" requests

This application does not support “Do Not Track" requests.
To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Application and, if technically and legally feasible, by sending a notification to Users through one of the details of contact of which the Holder is in possession. Please therefore consult this page regularly, referring to the date of the last modification indicated at the bottom.

If the changes involve processing whose legal basis is consent, the Owner will collect the User consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

Personal information is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes an individual identified or identifiable.

Usage data

The information collected automatically through this Application (also from third-party applications integrated in this Application), including: the IP addresses or domain names of the computers used by the User that connects with this Application, the addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (success, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment of the UIT you.

User

The individual who uses this Application which, unless otherwise specified, coincides with the interested party.

Interested

The natural person to whom the Personal Data refers.

Data Processor (or Manager)

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

Data controller (or owner)

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

This Application

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

Service

The Service provided by this Application 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 contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

Cookie

Small portion of data stored in the User’s device.


Legal references

This privacy statement is drafted on the basis of multiple legislative orders, including articles 13 and 14 of Regulation (EU) 2016/679.

Ove non diversamente specificato, questa informativa privacy riguarda esclusivamente questa Applicazione.

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