La Procosil S.r.l., P.IVA SM06090, data controller pursuant to European Regulation 679/2016, (hereinafter, for brevity, Owner) and European Regulation (EU) 2016/679 (hereinafter GDPR) and Law 171/ 2018 adopted by the State of San Marino.

IN SHAPE

that the personal data provided by the interested parties through the various collection channels, directly or indirectly managed by the Data Controller, or acquired from third parties in compliance with the conditions of the law, will be processed lawfully and fairly, in compliance with the principles established by the community law and Italian.

Purposes and methods of treatment

The collection and consequent treatment are carried out by the Data Controller at the company headquarters, in compliance with the security measures and requirements imposed by the aforementioned standard, or by subjects delegated by it (specially selected and equipped with the necessary professionalism), with manual procedures and computerised, in order to execute specific requests from the interested party, for pre-contractual and contractual obligations, for ordinary administrative, financial and accounting activities, to ensure the correct management of customers during the marketing and sale of products, for the after-sales assistance, for the fulfillment of legal obligations.
The treatment is also aimed at the elaboration of statistics in anonymised or pseudonymised form.

Nature of the contribution

The Data Controller processes the personal data, addresses and telephone and telematic numbers, as well as other data essential to satisfy the requests of the interested parties or fulfill the commitments undertaken. The conferment is therefore mandatory, as it is not possible, in the event of failure to issue the consent or revocation of the same, to give rise to the treatment.
It is necessary to point out that any incorrect or insufficient communication of the requested data may lead to the total or partial impossibility of carrying out the requests of the interested party or the obligations connected to the commitments undertaken, with consequent possible mismatch of the results of the treatment with the agreements made or the obligations imposed by rules and regulations.

Data of minors

Children under the age of 18 cannot provide data except with the consent of their parent or guardian. The holder will not be in any way responsible for any false declarations that may be provided by minors and, should he ascertain the falsity of the declaration, he will immediately cancel any personal data and any information acquired.

Navigation data

The IT system and the software used for the corporate web portal acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication products.
This information is not stored to identify the interested parties but, due to their nature, they can, through processing and association with other data managed by third parties, allow the identification of the user.
This category of data concerns the IP addresses and domain names of the computer used by the user to connect to the site, the URL addresses (Uniform Resource Locator) of the requested resource, the time of the request, the method used to send the request to the server, the size of the file received, the numerical code used to indicate the status of the response given by the server (executed or error, etc.) and other parameters relating to the operating system and the user’s computer.
These data are used only to create anonymous statistics on the use of the site and to check its correct functioning. They are usually deleted immediately after processing. They can be used and provided to the police and the judiciary to ascertain responsibility in the event of damage to the site or of offenses perpetrated via the network.
Data transferred by the user.
The compilation of any forms present on the pages of the site involves the acquisition of data in the system memory. The information is protected by an authentication system and can only be used by those in possession of the credentials. They are also kept up-to-date and adequately protected, based on the best practices available.
Requests for information by e-mail involve the storage of the user’s e-mail address, necessary to respond to the sender’s requests. The data stored in the message is included.
The Data Controller advises its customers, during their requests for services and information, not to transmit the data or personal information of third parties, unless absolutely necessary.

Cookies

As with most websites, information about site navigation is kept for statistical purposes. The collection of information is possible thanks to the use of cookies. A cookie is a small file that is transferred to your computer’s hard drive when you connect to a site.
These data are not of a personal nature, as they do not allow specific identification of the user. The data collected concern the geographical location of the service provider, the type of browser used, the IP address, the pages visited, etc. The information collected in this way makes it possible to see the frequency of visits to a site and the activity carried out while browsing.
In this way, over time, it is possible to improve the contents of the site and facilitate its use
Even companies that transmit content to the site or whose sites are accessible via links can use cookies when the user selects the relevant link.
In these cases the use of cookies is not under the direct control of the Data Controller. Most browsers automatically accept cookies, but it is possible to refuse them or select only some, according to the preferences set by the user.
However, if the user inhibits the loading of cookies, some components of the site may stop working and some pages may be incomplete.
Essential technical cookies
These are cookies necessary to ensure correct and fluid functioning of the site: they allow page navigation, content sharing, memorization of access credentials to speed up access to the site and to keep preferences and credentials active during navigation and improve the browsing or shopping experience. Without these cookies it is not possible to provide, in whole or in part, the services for which users access the site.
Statistical cookies
These cookies make it possible to understand how users use the site in order to then be able to evaluate and improve its functioning and create content that is increasingly appropriate for user preferences. For example, these cookies allow you to know which pages are the most and least visited, how many visitors there are to the site, how much time the average user spends on the site and how visitors arrive on the site. In this way it is possible to determine which are the optimal functioning and the most welcome contents and how the contents and functionality of the pages can be improved. All information collected by these cookies is anonymous and not linked to the user’s personal data.
Third-party profiling cookies
These are cookies used by third parties not directly controlled by the owner. The company cannot provide guarantees regarding the use that will be made of the data, the treatment of which is directly operated by an external subject
Cookies from these third-party operators allow us to offer advanced features, as well as more information and personal functions. This includes the ability to share content through social networks and to have a personalized site experience based on the preferences expressed through the pages visited.
If you have an account or if you use the services of these other data controllers, they may be able to know that the user has visited the company site. The use of data collected by these external operators through cookies is subject to their privacy policies. Third-party profiling cookies are identified with the names of the respective operators and can be deactivated.
Management of cookies
You can change the settings of the cookies that are downloaded to the user’s computer through the browser functions. By doing so, it is also possible to prevent the installation of third-party cookies and to remove previously installed cookies, including those containing cookie preferences. To adjust or change your browser settings, you need to consult the manufacturer’s guide.
The instructions for managing and removing the cookies of the most popular browsers are available on the websites of the respective manufacturers. Disabling cookies can cause the website or part of it to malfunction.
Acceptance and renunciation of cookies
Continuing to browse the site after viewing the information that appears superimposed, the company policy is accepted. It is always possible to remove cookies already downloaded using the browser functions or specific applications
Third Party Sites.
The company site, even if only periodically, could contain links to other third-party sites, to provide additional services and information to the user. When the user uses these links, he leaves the company site and accesses other resources that are not under the direct control of the Data Controller, who, therefore, will not be responsible for the procedures relating to navigation, security and data processing. personal data operated by other sites, even in the presence of co-branding or display of the company logo. A careful examination of the security and confidentiality procedures of the site visited is recommended, which could transmit additional cookies, read those already present on the user’s hard drive and request / acquire further personal information.

Communication and dissemination

The data processed are exclusively of a common nature and are not intended for dissemination. The Data Controller does not request and has no interest in collecting and processing data classified by the Regulation as “particular” (sensitive, judicial, genetic, biometric, etc.) without prejudice to legal obligations.
The data must be transferred to third parties in the fulfillment of obligations deriving from laws or regulations (Institutions, Law Enforcement, Judicial Authorities, etc.) or for activities directly or indirectly connected to the relationship established. By way of non-exhaustive example, the following are mentioned:
• Subjects who need to access the data of the interested party for purposes concerning the relationship with the Data Controller (Credit institutions, Financial intermediaries, Electronic money and payment management institutions, Debt collection companies, Customer verification companies, Carriers, etc.);
• Companies that will provide any technical services;
• Consultants, collaborators, service companies, within the limits necessary to carry out the task assigned by the Data Controller;
• Subsidiary and/or affiliated companies that can access the data, within the limits strictly necessary to carry out tasks entrusted by the Data Controller.
The data may be communicated to subjects operating within the European Union, or in countries that guarantee the same level of protection provided for by European Regulation 679/2016. They may also be communicated to subjects operating in non-EU countries where expressly permitted by the interested party.
In any case, the processing of data operated in the various countries will be adapted to the most restrictive regulations, in order to ensure the maximum level of protection of the data of the interested party in any case. They may be transferred to third parties, even for consideration, if the interested party has given express consent, for purposes directly or indirectly connected to the activity of the Data Controller.

Data retention times

The data processed by the Data Controller, without prejudice to legal obligations, are kept until an express request for cancellation by the interested party and in any case periodically verified, even with automatic procedures, in order to guarantee their updating and effective compliance with the purposes of the treatment. If the purpose for which they were acquired has ceased to exist, the data are deleted, unless otherwise expressly requested by the interested party.

Rights of the interested party

The interested parties are entitled to the rights referred to in article 13 of the EU/2016/679 Regulation and, in particular, the right to revoke the consent to the processing of data at any time, request its rectification, updating, transformation into anonymous, limit its use, even partially, request its portability and possible cancellation. The rights can be exercised to the extent that the processing is not mandatory by law or regulation.
Requests relating to the exercise of the rights of the interested party can be addressed directly to the Data Controller or to the email address procosil1@procosil.com
If the interested party is not satisfied with the response provided to his requests by the Data Controller or the Data Protection Officer, he can lodge a complaint with the Guarantor Authority for the Protection of Personal Data, based in Rome, Piazza di Monte Citorio n . 121, www.garanteprivacy.it