3.1 Navigation data
3.2 Data supplied voluntarily by the User (messages)
3.5 Marketing purpose and softspam
3.7 Reserved area
1. DATA CONTROLLER
The Controller of the processing of personal data is Fortech S.r.l. (P.IVA 03618500403), with registered office in Via Rigoletto n. 4, 47922, Rimini (RN), Italy, tel.: 0541/364611, fax: 0541/753013, E-mail: firstname.lastname@example.org; P.E.C.: email@example.com.
2. DATA PROTECTION OFFICER AND CONTACT POINT
The Data Controller has appointed a Data Protection Officer (DPO) that Data Subjects can contact to exercise their rights and for any question and request concerning personal data processing activities. The DPO is reachable at Data Controller register office located in Via Rigoletto n. 4, 47922, Rimini (RN), Italy and to the following e-mail address: firstname.lastname@example.org.
3. CATEGORIES OF DATA PROCESSED
Different types of personal data may be processed and treated differently, depending on the services rendered.
3.1 Navigation data
The information systems and software procedures used to the operation of this web site acquire personal data as part of their standard functioning. Such information is not collected in order to relate it to identifiable data subjects; however, it may allow User identification after being processed and matched with data held by third parties.
This data category includes the: IP addresses or names of computer domains used by visitors who access the website; URI (Uniform Resource Identifier) addresses of the requested resources; time of request; method used to submit the request to the server; size of the file obtained in response; numerical code indicating the status of the response from the server and other details relating to the operating system and the information environment of Users. This data is used only to obtain anonymous statistical information about the website and to check its correct functioning and is deleted immediately after processing. This data may also be used to ascertain responsibility in the case of possible computer crimes against the website. Excepting this, data on web contacts is not stored for more than seven days.
3.2 Information requests
The user can optionally, explicitly and voluntarily send communications or requests to Fortech by using the contact forms on the Site or by writing an e-mail to the addresses indicated on the Site itself: this involves the subsequent acquisition of the data communicated by the user, including his e-mail address, and his consent to receive any response messages to his requests.
a) Contacts and Footer of the site: by clicking on the e-mail address email@example.com, which incorporates a mailto link;
b) Information request form;
c) Pages of the site dedicated to services and products: by clicking on the e-mail address firstname.lastname@example.org or other e-mail addresses published on the Site, which incorporate mailto links.
What is a cookie? Cookies are information stored by the browser when you visit a Web Site using a PC, smartphone or tablet. Each cookie contains several pieces of data (e.g., the name of the server from which it originates, a numeric identifier, etc.). Cookies can remain in the system for the duration of a session (until the closing of the browser), or for long periods, and may contain a unique identifier.
When you will visit the website again, cookies will be reforwarded to the website that has generated them (first-party cookies) or to the ones that were provided by third parties and that are able to recognize them (third-party cookies).
In any case, Fortech S.r.l. S.r.l. grants that the cookies used in its website are safe: they will not cause any damage to your device and they will allow you to surf faster the website.
What are they used for? Cookies are used for different purposes, depending on their type: some are strictly necessary for the correct function of the Web Site (technical cookies), whereas others optimise performance in order to provide the User with a better experience while they are visiting the Web Site. In addition, cookies allow Web Site usage statistics to be obtained, such as cookies analytics; others are for the purpose of displaying advertisements (in some cases advertisements are targeted based on cookie profiling).
Fortech’s website uses both cookies that do not require your previous consent (e.g. Technical cookies) and cookies you will have to assent to (e.g. profiling cookies). In detail, on the website might be active:
Types of cookies used on the Web Site
a) Technical cookies (which do NOT require your consent):
These are cookies necessary for the functioning of the site and allow you to access its functions (so-called navigation cookies) or to authenticate yourself in the session.
Functional cookies are also used to store your preferences and settings, thus improving your browsing experience on the site.
In order to guarantee their functionality, these cookies are generally not deleted when you close your browser; however, they have a default duration (generally up to a maximum of 2 years) and after this period they are automatically deactivated. These cookies and the data they collect will in no way be used for further purposes.
The installation of technical cookies takes place automatically when you access the site or to activate certain functions (e.g. by selecting the “remember me” option). You can always decide to disable them at any time by changing your browser settings: in this case, however, you may have some problems viewing the site.
b) Analytical cookies (which may NOT require your consent)
These cookies keep track of the choices made on the site and data relating to users’ online browsing (for example, pages viewed, dwell times on a page, etc.), in order to perform statistical analysis, in an anonymous and aggregate form.
These tools can only be used after expressing the user’s consent, unless their settings meet the following requirements:
– the duly anonymized IP address;
– the information obtained with analytical cookies refers to a single IT resource (site, app, etc.) and is used only in anonymous and aggregate form;
– the cookie provider does not combine the information with other processing and does not pass it on to third parties.
If these requirements are met, the complete anonymization of the collected data is guaranteed and even the cookies falling into this category can be activated without the need for the user’s consent, precisely because the data processed cannot be linked to any identifiable user.
c. Tracking and Profiling cookies (requiring your CONSENT):
This site also uses profiling and third-party cookies. However, your prior consent is required for their installation.
Profiling cookies may include several categories, including advertising profiling, retargeting or social cookies.
– Advertising profiling cookies: create a user profile that allows you to view advertising content in line with your preferences while browsing the site;
– Retargeting cookies: are designed to create a user profile in order to send you personalized advertising content related to products in which you have expressed interest;
– Social cookies: this site provides for the installation of cookies related to social network plug-ins. These cookies are managed directly by third parties and allow the display of advertising messages in line with your preferences.
d. Social media plugin
On the Site there are some buttons that refer the user to the Controller’s profiles on social networks. Only after clicking on these buttons, some cookies could be activated for marketing and profiling purposes by the third parties that manage the social networks. The Controller does not directly manage these tools, but informs you of the possibility that, by making use of the Site’s features, they may be activated.
For more information, including on how to disable these cookies, please read the information on the processing of personal data on social networks:
– YouTube: https://policies.google.com/privacy?hl=it
– LinkedIn: https://it.linkedin.com/legal/privacy-policy?trk=public_authwall_company-scraping_join-form-privacy-policy
– Facebook: http://www.facebook.com/policy.php
When you access the site, through a special banner you will be informed of the presence of profiling and retargeting cookies and, through it, you can consent or not to their installation. Of course, you can revoke your consent at any time, without any prejudice to the possibility of visiting the site and enjoying its contents.
Therefore, cookies can easily be disabled or turned off by accessing the browser’s options or preferences, and in general third-party cookies can also be blocked. As a general rule, these options will only have an impact on that browser and on that device, unless there are active options to synchronize the preferences on different devices. Specific instructions can be found on the Options page or Help page of the browser itself. Disabling technical cookies, however, may affect the full and/ or proper functioning of different sites, including this one.
Normally, browsers used today:
– offer the “Do not track” option, which is supported by some websites (but not all). Thus, these websites are no longer able to collect certain navigation data;
– offer the option of anonymous surfing or incognito mode: in this way, data will not be collected in the browser and browsing history will not be saved, but the navigation data may still be acquired by the operator of the Web Site that was visited;
– allow the deletion of cookies stored in whole or in part, but after visiting a Web Site again they are usually installed, where such possibility is not blocked.
Below are links to the support pages for the most popular browser (with instructions on how to disable cookies on these browsers):
– Firefox: (https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie);
– Internet Explorer e Microsoft Edge: (https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies);
– Safari: (iOS) (https://support.apple.com/it-it/guide/safari/sfri11471/mac) and (https://support.apple.com/it-it/HT201265#:~:text=Per%20cancellare%20i%20cookie%20senza,o%20disattiva%20la%20navigazione%20privata);
– Chrome: (https://support.google.com/chrome/answer/95647?hl=it).
On-line tools: You may notice that from http://www.youronlinechoices.com/ you can not only learn more about cookies, but also check the installation of numerous cookies on your browser and/or device and, if supported, also disable them.
Fortech’s newsletter is sent by e-mail to those who explicitly request it, by filling out the appropriate form on the Website and authorizing the Data Controller to process their personal data for the aforementioned purpose.
Consent: The service is provided only following explicit and unequivocal consent (released by the user selecting the appropriate box on the Website) and the provision of data is mandatory only for the purpose of receiving the newsletter. Any failure to provide consent will prevent the user to use the service, without further consequences.
Removal from the service: in order to stop receiving the newsletter, you can simply select the link for removal at the end of each e-mail or send a specific request to the e-mail address email@example.com.
The erasure could be managed automatically, therefore the user may receive for a period no longer than 72 hours further newsletters, whose submission had been planned before the reception of the cancellation request.
The newsletter service is provided by Campaign Monitor Pty Ltd., 404/3-5 Stapleton Avenue Sutherland, NSW 2232 Australia; for further information, please visit the following page: https://www.campaignmonitor.com/policies/#privacy-policy or contact firstname.lastname@example.org.
3.5 Data that can be used for sending soft-spam communications
Only in the event that the e-mail address is provided by the data subject in the context of the purchase of products or in the event that you have shown interest in our products and have requested information from us, the data thus collected by the Data Controller they can also be used to send e-mail communications relating to products similar to those already purchased or of interest to the user, pursuant to art. 130, paragraph 4, legislative decree 196/2003 and art. 6, lett. f, of the GDPR, without the need for express and prior consent (so-called soft spam). In every communication, the user is reminded that he can revoke the consent at any time and without formalities.
3.6 Data that can be used for sending communications for marketing
The user can receive communications of a commercial nature with which the Controller promotes its own and / or third-party services only in the case of express and specific consent. However, data subject is always entitled to withdraw consent and request immediate interruption of the sending of such communications, in a simple and free way: just click on the link indicated in each e-mail or send us a request by e-mail.
3.7 Data required to access the restricted area
To access the services and interface platforms of Fortech products (for example, datamanager, invoice1clic, cards, sitemanager), data subjects must use a username and password, using which they have the opportunity to properly use the services purchased.
For registration and access to the reserved area, in addition to the access credentials, the data relating to the contractual relationship between the data subject and Fortech are used.
For data processing carried out using one or more Fortech services, please refer to the specific information relating to each service.
4. IN WHAT OTHER CASES WE MAY USE THE DATA?
Your personal data may also be used in order to:
a) comply with legal obligations and requests from public or government authorities;
b) manage any disputes or contentions and therefore defend the rights of Fortech S.r.l. both in court and out of court.
In such cases, the legal bases of the processing will be:
– for point a), the fulfillment of a legal obligation;
– for point b), the legitimate interest of the Data Controller in the protection of their rights, as long as they are adequately balanced, from time to time, with the rights of the data subject.
5. HOW ARE THE DATA PROCESSED?
Data will be managed lawfully and used only for the aforementioned purposes. It will be processed using suitable means to guarantee its security and confidentiality, using the most appropriate, also automated, means (hard copy or electronic) to store, manage and transmit the data. The Controller assess the appropriate level of security in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
This data will be retained for the period stipulated under the relevant law and, anyway, for no longer than is necessary for the purposes for which the personal data are processed and/or until the data subject revokes the consent given for the purposes referred to above.
Fortech S.r.l. will limit the number of subjects that will be allowed to have access to servers or databases, setting out a system to prevent cyber-attacks.
6. TO WHOM CAN THE COLLECTED DATA BE DISCLOSED?
The processing operations related to the web services of this Site are only handled by internal and/or external technical staff specifically delegated for processing. In particular, where necessary and only with prior consent, the data may be disclosed to third parties whose collaboration is needed for the performance of the services offered. The data collected via the web, or in any case arising from web services, may be disclosed to the technological and instrumental partners who cooperates with the Data Controller to provide the services required by users, always in compliance with the purposes set forth in article 2. To this purpose, the subjects who will have access to personal data will be specifically authorized for processing by the Data Controller and, if due, appointed as Data Processors, pursuant to Articles 28 and 29 of the GDPR.
The data collected for the aforementioned purposes may also be disclosed to subjects authorized under the relevant legislation.
Indeed, we will adopt all the necessary precautions in order to ensure a complete data protection. The data transfer will be based on: a) an adequacy decision of the European Commission about a third country designed as receiver; b) appropriate and explicit safeguards of the third subject designed as receiver pursuant to art. 46 GDPR; c) the adoption of Corporate binding rules. These requirements are always ensured by Fortech S.r.l.’s suppliers.
In particular, the newsletter service is provided through the Platform of the company Campaign Monitor Pty Ltd., based in 404 / 3-5 Stapleton Avenue Sutherland, NSW 2232 Australia, and this could involve a transfer of data also outside Europe. The protection of personal data and the guarantees of correct processing of the same are in this case ensured by the adequacy decision of the European Commission regarding the processing of data in Australia.
Further information in this regard can be requested from the Data Controller or the Data Protection Officer, using the contact details referred to in Par. 1 and Par. 2.
7. WHICH IS THE DATA SUBJECT’S RIGHTS?
With regard to your personal data and according to GDPR provisions, Fortech S.r.l. informs you that you have the right to:
– confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data (art. 15 GDPR);
– correction of his or her personal data if it is incomplete or inaccurate (art. 16 GDPR);
– obtain the erasure of personal data (right to be forgotten) (art. 17 GDPR);
– deletion or restriction of personal data in certain circumstances provided by applicable law (art. 18 GDPR);
– an electronic copy of personal data (portability) (art. 20 GDPR);
– the right to withdraw his or her consent at any time (art. 21 GDPR).
Further information and some templates are available here: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1089924
The exercise of these rights can be exercised by communicating to the Data Controller or Data Protection Officer, using the contact details referred to in Par. 1 and Par. 2.
We ensure that we will answer to your requests within 30 days from the receipt.
If you think that Fortech S.r.l. S.r.l. personal data processing is unlawful or violates GDPR, you also have the right to lodge a complaint to the competent supervisory authority. For further details see next paragraph.
8. RIGHT TO WITHDRAW CONSENT, TO OBJECT AND TO LODGE A COMPLAINT
Each data subject has also the right to withdraw his or her consent at any time, without prejudice to the lawfulness of the processing based on consent before its withdrawal.
The data subject is also always entitled to object to the processing of any data concerning him or her if it was carried out for direct marketing purposes by the Data Controller; in this case, his/her data will no longer be processed for these purposes (right of objection).
You have the right to lodge a complaint to a supervisory authority, if you think that Fortech S.r.l.’s personal data processing is not compliant to GDPR or any other national law.
In Italy, the competent authority is Garante per la protezione dei dati personali, whose contact are accessible at the following page: http://www.garanteprivacy.it/.
Further information and a template to lodge a complaint are available here: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524.
Finally, in case there are the conditions of artt. 78 e 79 GDPR, you have the right to an effective judicial remedy at the competent court.