Legal referencies:

– Regulation (EU) no. 679 of 27 April 2016 on 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

–Recommendation n. 2 of 17 May 2001 concerning the minimum requirements for online data collection in the European Union, adopted by the European authorities for the protection of personal data, gathered in the Working Party  established by art. 29 of the directive n. 95/46 / EC (hereinafter “Recommendation of the Working Party pursuant to art. 29”)

Addfor Industriale S.r.l. (hereinafter “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 the personal data of users who consult and use the Company’s website, which corresponds to the following domain: https://www.addfor-industriale.it/

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.

This policy does not extend to other websites that may be consulted by users through the links, including the Social Buttons, present on the Company’s website.

In particular, the Social Buttons are digital buttons or links for direct connection with the Social Network platforms configured in each single “button”.

By clicking on these links, users will be able to access the Company’s social accounts.

The editors of the Social Networks, to which the Social Buttons refer, operate as autonomous Data Controllers; consequently, any information relating to the methods by which the aforementioned Data Controllers carry out processing operations on users’ personal data can be retrieved on the related Social Network platforms.

1.Personal data subject to processing

In consideration of the interaction with this website, the Company may process the following personal data of users:

a) Navigation data: the computer systems and software procedures used to operate this website acquire, during normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with data subjects but which by their very nature could, through processing and association with personal data held by third parties, allow users to be identified. This category of personal data includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment. These personal data are used only to obtain anonymous statistical information on the use of the website and to check its correct functioning.

The navigation data does not persist for more than 12 months, without prejudice to any need for the investigation of crimes by the judicial authorities.

b) Personal data spontaneously provided: the optional, explicit and voluntary transmission of personal data to the Company, by filling in the forms on the website, involves the acquisition of the email address and all other personal data of the users requested by the Company in order to comply with specific requests.

With reference to the processing of personal data provided by completing the contact form located on this website, please refer to Contact Form Privacy Policy

• Purpose and legal basis of the processing of personal data

In relation to the personal data referred to in point 1), let. a) of this privacy policy, the personal data of users are processed, automatically and “mandatory” by the Company in order to allow navigation itself; in this case, the processing takes place on the basis of a legal obligation to which the Company is subject, as well as on the basis of the legitimate interest of the Company in ensuring the proper functioning and security of the website; therefore, the express consent of users is not required.

With regard to the personal data referred to in point 1), let. b) of this policy, the processing is carried out in order to provide information or assistance to users; 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.

• Nature of the provision of personal data

Without prejudice to what is specified for navigation data in relation to which the provision is required as it is instrumental to navigation on the Company’s website, users are free to provide or not personal data in order to receive information or assistance from the Company .

With reference to the processing of personal data provided by completing the contact form located on this website, please refer to the relative “contact form privacy policy”.

• Methods and duration of the processing of personal data

The processing of personal data is carried out by persons authorized to process personal data, specifically identified and instructed for this purpose by the Company.

The processing of users’ personal data is carried out through the use of automated tools with reference to the access data to the pages of the website.

With reference to the processing of personal data provided by completing the contact form located on this website, please refer to the relative “contact form privacy policy”.

In any case, the processing of personal data takes place in full 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 purposes stated in  this policy.

Users acknowledge that navigation data referred to in point 1, let. a) do not persist for more than 12 months, the processing of personal data takes place for the time strictly necessary to achieve the purposes for which they were collected or in any case on the basis of the deadlines set by law.

Furthermore, it is specified that the Company has adopted specific security measures to prevent the loss, illicit or incorrect use of personal data and unauthorized access to the same data.

• Recipients of personal data

Limited to the purposes identified in this policy, your personal data may be disclosed in Italy or abroad, within the territory of the European Union (EU) or the European Economic Area (EEA), for the fulfillment of legal obligations.

For more information with reference to the recipients of the personal data of the users provided by completing the contact form located on this website, please refer to the relative “contact form privacy policy”.

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.

• 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 e-mail address: privacy@vargroup.it

If the Company does not provide feedback within the time limits provided for by the law or the response to the exercise of 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

ISeSa S.p.A., the parent company of the corporate Group to which the Company belongs by virtue of the control of 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  Data Protection Officer cooperates with the Data Protection Authority. Below is an indication of the related contact details:

Email: dpo@sesa.it