– EU regulation no. 679 of 27 April 2016 concerning the protection of individuals with regard to the processing of personal data, as well as the free circulation of personal data (hereinafter “EU Regulation”)

– Legislative Decree n. 196 of 30 June 2003 (hereinafter the “Privacy Code”), as amended by Legislative Decree no. 101 of 10 August 2018

– Guidelines on promotional activities and the fight against spam “of 4 July 2013 (hereinafter” Guidelines of the Data Protection Authority  “)

Addfor Industriale S.r.l. (hereinafter also the “Company”), a company belonging to the Var Group S.p.a. corporate group, with registered office in Via Piovola n. 138, 50053 Empoli (FI) – Tax Code n. 12546450011, wishes to inform users about the methods and conditions applied by the Company to the processing operations carried out on personal data.

In particular, the privacy policy is provided in relation to personal data that are provided by users by filling in the contact forms found in the “Contacts” section of the Company’s website, as well as in the “Request information” section.

The Company acts as “Data Controller”, meaning “the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data “.

Specifically, the processing of personal data may be carried out by persons specifically authorized to carry out processing operations on the personal data of users and, for this purpose, duly instructed by the Company.

In application of the legislation on the processing of personal data, users who consult and use the Company’s website assume the quality of “data subjects”, by which we mean the natural persons to whom the personal data being processed refer.

1. Purpose and legal basis of the processing of personal data

The personal data processed by the Company are directly provided by users, by filling in the appropriate contact forms, in order to request information or receive assistance. In this case, the processing is based on the execution of specific requests and the fulfillment of pre-contractual measures; therefore, the express consent of users is not required.

Based on the specific and optional consent provided by users, personal data may be processed by the Company in order to send commercial and promotional communications relating to the Company’s services and products, as well as information messages relating to the Company’s institutional activities.

Furthermore, on the basis of the specific and optional consent provided by users, personal data may be disclosed to the companies belonging to the SeSa S.p.A. corporate group, to which the company belongs in consideration of the control exercised by Var Group S.p.A., in order to allow the latter the transmission of commercial and promotional communications relating to services and products of the aforementioned companies, as well as information messages relating to the institutional activities of the companies themselves.

It should be noted that users can revoke, at any time, the consent already given to the processing of personal data; the withdrawal of consent does not affect the lawfulness of the processing carried out before the withdrawal itself.

It is possible to revoke the consent already given to the Company by writing to the following email address: privacy@vargroup.it

2. Methods and duration of the processing of personal data

The processing of users’ personal data is carried out by company personnel specifically authorized by the Company; to this end, these subjects are identified and instructed in writing.

The processing can be carried out through the use of IT, telematic or even paper tools and supports in compliance with the provisions aimed at guaranteeing the security and confidentiality of personal data, as well as, among other things, the accuracy, updating and relevance of personal data with respect to the declared purposes.

The personal data collected will be stored in electronic and / or paper archives present at the Company’s registered office or operational headquarters.

The retention of personal data provided by users will take place in a form that allows their identification for a period of time not exceeding that necessary for the pursuit of the purposes, as identified in point 1 of this policy, for which the same data are collected and processed.

In any case, the determination of the retention period takes place in compliance with the terms permitted by applicable laws.

In relation to the purposes of marketing and commercial promotion, in case of manifestation of the optional consents requested, the personal data collected will be kept for the time strictly necessary for the management of the purposes indicated above according to criteria based on compliance with current regulations and accuracy as well as balancing between the legitimate interest of the Company and the rights and freedoms of users. Consequently, in the absence of specific rules that provide for different retention periods, the Company will take care to use personal data for the aforementioned marketing and commercial promotion purposes for an appropriate time.

In any case, the Company will take every care to avoid the use of personal data indefinitely, proceeding periodically to appropriately verify the effective persistence of the interest of users in having the processing carried out for marketing and commercial promotion purposes.

3. Nature of the provision of personal data

The provision of personal data is optional but necessary in order to respond to requests for information or assistance made by users.

In particular, failure to fill in the fields in the contact forms prevents the sending of requests for information or assistance to the Company.

In this case, the consent to the processing of personal data is “mandatory” as it is instrumental in order to obtain feedback on requests for information or assistance made to the Company.

In all other cases referred to in point 1 of this policy, the processing is based on the granting of specific and optional consent; as already specified, the consent is always revocable.

4. Recipients of personal data

Users’ personal data may be disclosed, in Italy or abroad, within the territory of the European Union (EU) or the European Economic Area (EEA), in fulfillment of a legal, or regulatory obligation; in particular, personal data may be disclosed to public authorities and public administrations for the performance of institutional functions.

Furthermore, without the user’s consent, personal data may be disclosed to companies belonging to the SeSa S.p.A. corporate group for the sole purpose of responding to requests for information or assistance addressed to the Company.

Subject to specific and optional consent provided by users, personal data may be disclosed to companies belonging to the SeSa S.p.A. corporate group (belonging to the product categories ATECO J62, J63 and M70 regarding IT products and services and business consultancy), in order to allow the latter to transmit commercial and promotional communications relating to services and products of the aforementioned companies, as well as related information messages to the institutional activities of the companies themselves.

Personal data will not be transferred outside the territory of the European Union (EU) or the European Economic Area (EEA).

Personal data will not be disclosed to the public or to an indefinite number of subjects.

5. Rights pursuant to art. 15, 16, 17, 18, 20 and 21 of EU Regulation 2016/679

Users, as data subjects, will be able to exercise the rights of access to personal data provided for by art. 15 of the EU Regulation and the rights provided for by art. 16, 17, 18, 20 and 21 of the same Regulation regarding the rectification, cancellation, limitation of the processing of personal data, data portability, where applicable and opposition to the processing of personal data.

The aforementioned rights can be exercised by writing to the following address: privacy@vargroup.it
If the Company does not provide feedback within the timeframe provided for by the law or the response to the exercise of the rights is not suitable, users can lodge a complaint with the Data Protection Authority.

Here are the coordinates:

Data Protection Authority

Piazza Venezia n. 11 – 00187 Rome

Fax: (+39) 06.69677.3785

Telephone switchboard: (+39) 06.69677.1

E-mail: protocol@gpdp.it

Data Protection Officer

SeSa S.p.A., the parent company of the corporate group to which the Company belongs by virtue of the control exercised by Var Group S.p.A., has appointed the Data Protection Officer. The Data Protection Officer monitors compliance with the legislation on the processing of personal data and provides the necessary advice. In addition, where necessary, the l Data Protection Officer cooperates with the Data Protection Authority. Below is an indication of the related contact details:

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Email: dpo@sesa.it