PRIVACY POLICY IN ACCORDANCE WITH ART. 13 AND 14 OF EU REGULATION NO. 2016/679 (GDPR)
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PRIVACY POLICY

Who is the Data controller for the processing of your personal data?

The data controller for the personal data collected through this website is Passodue Associazione Professionale, with main
offices in p.zza Learco Guerra 86, 47522 Cesena – FC , VAT number and fiscal code no. 04243280403 (henceforth referred to
as ‘Data controller’). An updated list of the authorized data processors and external joint processors is available at the Data
controller’s head office.

Why do we collect your personal data and when do we collect it?

Navigation data
While browsing our website we collect personal data from you, for example the IP address of your PCs, the domain names of
your computers and terminals, the URIs/URLs (Uniform Resource Identifiers/Locators) addresses of the resources requested,
the time of the request, the method used to submit the query to the server, the size of the reply file, the number code indicating
the status of the reply provided by the server (successful, error, etc.) and other parameters related to your operating system and
IT system.
Services data
Our website also features a ‘Contact us’ area. You can contact us there to ask for information and in these circumstances we
will process your personal and contact details – first name and surname, phone number, e-mail address. In addition, through
‘Request a quote’ area of our website you can request a quote. In this case we will process your personal and contact details,
and any other data useful for managing the transaction. On our website you can also subscribe to our newsletter whereupon we
will process your first name, surname and e-mail address.

What are we entitled to do by law?

In accordance with the UE Regulation no. 2016/679 (GDPR) we are allowed to process the various types of data mentioned
above for the following purposes:

Navigation data	This is needed for statistical purposes, to improve our website, and to protect your safety while browsing. This data does not enable us to identify you. We will process such data on the basis of our legitimate interest and that of the user (art. 6 let. f) of GDPR).
Navigation data (cookies)	We also collect data for the purpose of analysing and processing information about you, your preferences, habits, consumption choices and/or browsing experiences. We analyse and process such information through the use of technologies such as cookies – our own or third-party cookies. Data is collected through the use of cookies only after your express consent (art. 6 let. a) of GDPR). You will be informed of this through a dedicated banner at the bottom of the site when you log on for the first time. For more information please read our cookie policy.
Data from the ‘Contact us’ area (Services data)	We process your contact data such as your first name, last name, phone number, and e- mail address so to be able to process your contact request. I In accordance with the GDPR we are allowed to process this data without your consent as it necessary for the execution of pre-contractual measures (art. 6 let. b) of GDPR). You can choose not to provide us with the data at any time, but in such case you will not be able to send us any requests for quotes.
Data from the ‘Request a quote’ area (Services data)	We process your contact data such as your first name, last name, and e-mail address. In accordance with the GDPR we are allowed to process this data without your consent as it necessary for the execution of pre-contractual measures. You can choose not to provide us with the data at any time, but this means you will not be able to send us any requests for quotes (art. 6 let. b) of GDPR).
Communications and newsletters (Services data)	Collection of data in order to send newsletters and information material on our business activities. Any processing for these purposes is carried out upon specific consent provided by you. We process this data on the basis of your consent expressed by a flag in the ‘Sign up for our newsletter’ section (art. 6 let. a) of GDPR) and on the basis of our legitimate interest to keep you informed about offers and promotions reserved only for you as our client. We will only write to you in relation to products which are likely to be of interest to you and you will be allowed to unsubscribe at any time (art. 6 let. f) of GDPR).

 

How do we process your data?

The processing of your data occurs through the use of tools and procedures that ensure security and confidentiality, and can be
done both through our website and through other electronic tools (e.g. internal management platforms) including on occasion
via paper-based substrates. Besides the Data controller, in some cases other individuals involved in the organization of this
website (administrative and sales staff, system administrators, etc.) or external individuals (such as technical third-party service
providers, hosting providers, IT companies, communication agencies) may be appointed by us, as set forth by the regulations,
as Data processors. For the full list of our data processors please write to us at the following e-mail address
info@passodue.com

How long will we store your data for?

Navigation data: the data collected by the site while operating is stored for such time as is strictly necessary to execute the
specific activities. Upon expiration, data will be erased or anonymized, unless it is to be retained longer for other purposes. The
Data processor has no control over cookies entirely set by third parties and has no access to the information collected by such
cookies. For more information on the storage of personal data collected through cookies please read our Cookie policy.
Services data:

• Data from the ‘Contact us’ area: The data will be stored for such time as is strictly necessary to process the request made.
• Data from the ‘Request a quote’ area: data will be stored for 10 years from the time of collection (see art. 2220 of the Italian
  Civil Code), in case of contract termination or for the time necessary to process the request for a quote.
• Data related to communications and newsletters: data will be stored for 24 months after your latest interaction with us or at
  least up to the time when your consent is withdrawn (opt-out procedure) and/or you have requested to opt out.

Where is your data located?

The processing of your personal data related to the Service occurs in European and non-EU countries. In the latter case the
Data controller must have appropriate safeguards in place, such as standard contractual clauses, in accordance with art. 46 of
GDPR. Through the installation of cookies (for more information on cookies read our Cookie policy, your navigation data (IP
address) may be transferred outside the European Union, and in particular to the United States (by way of example, Google)
with appropriate safeguards.

Who accesses your data?

Your data may be made accessible to Data controller's employees and collaborators in their role as data processors and/or
system administrators and/or other individuals or organizations (e.g., professional firms, consultants, software houses providing
management software packages, etc.) that executed outsourced activities on behalf of the Data controller, in their role as
external data processors.
The Data controller may communicate your data to the Public Administration, Supervisory bodies and/or judicial authorities as
well as to all other individuals or organization to whom communication is mandatory or necessary by law. Your data will not be
disclosed.

What are your rights?

As a data subject, in the cases stipulated for by law you will have the right of access and the right to the rectification or erasure
of your personal data, the right to restrict and to object to the processing of your personal data. To find out more about your
rights, please consult articles 15 and the following of the EU Regulation. To exercise your rights please write to us at the
following address info@passodue.com.

Right to object

You will have the right to lodge a complaint with the Italian Data Protection Authority as provided for by art. 77 of the GDPR, or
to take appropriate legal action pursuant to art. 79 of the Regulation, if you believe that the processing of your data breaches the
GDPR provisions.

Protection of children’s privacy

This website is targeted at the general public; however, its services are intended for persons of 18 years of age or older. We do
not solicit, collect, use or disclose personal information from anyone under the age of 18 online. Should we discover that we
have personally collected data from a person under age, we will erase that data immediately.