PRIVACY STATEMENT ON THE PROCESSING OF PERSONAL DATA

Rollwasch® Italiana s.p.a. takes the utmost account of the legislation on the processing of personal data and offers the utmost commitment to comply with the provisions of the EU Reg. (679/2016) (GDPR, available at the following link: https://www.garanteprivacy.it / the-text-of-the-regulation), and with the (It.) Legislative Decree 196/2003 (Privacy Code), as supplemented by (It.) Legislative Decree 101/2018.
The document herein describes the criteria, methods, limits, and scope of the processing of personal data of any users who access, consult and provide their data electronically through the sites below (both desktop and mobile versions):

 

Any access, consultation, and use of the functions of the aforementioned websites may involve the processing of personal data relating to identified and/or identifiable natural persons, hence the privacy statement herein.
Any processing of the data referred to in this document is, and shall be, carried out in a lawful, correct, and transparent manner.

PLEASE NOTE:
The information herein is not related to any other websites, pages or online services accessible via hyperlinks that may be published on the site but are referred to resources outside the domain of Rollwasch® Italiana s.p.a.
Concerning the processing of personal data carried out by the Social Media platforms used by Rollwasch® Italiana s.p.a., please refer to the information provided by them in their respective privacy statements.
Rollwasch® Italiana s.p.a. shall process any personal data provided by users through the pages of any Social Media platforms used by the company itself, exclusively to manage any interactions with users (comments, public posts, etc.), and in compliance with the current legislation.

DEFINITIONS:
Personal data: any information related to an identified or identifiable natural person ("data subject").
Processing: any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by supply, dissemination or otherwise making available, comparison or combination, limitation, erasure or destruction.
Data Controller: natural or legal person, public authority, service or other body which, individually or jointly with other subjects, determines the purposes and methods of the processing of personal data.
Data Processor: natural or legal person, public authority, service or other body that processes personal data on behalf of the Data Controller.

1) DATA CONTROLLER
The Data Controller (hereinafter, the Data Controller) is

ROLLWASCH ITALIANA S.P.A. (Tax Code 04561670151) in the person of the CEO and legal representative Miss Ambra Redaelli, with registered office in Milan, Corso Venezia no. 36.

In order to request any information or clarification concerning the processing of personal data envisaged by the privacy statement herein and to exercise any rights referred to in point 6) below, you may use one of the following methods:
    • You may send a communication by e-mail to privacy@rollwasch.it
    • You may send a communication by mail to the address below:

 

Rollwasch Italiana s.p.a.
For the attention of Miss Ambra Redaelli
Corso Venezia no. 36
20122 Milano (MI)

2) DATA PROCESSED, PURPOSE AND LEGAL BASIS OF THE PROCESSING

In compliance with the legislation concerning the protection of personal data, besides specifically indicating which personal data are processed and any related requirements/purposes of the processing itself, the Data Controller is required to process the data exclusively on the basis of one of the legitimate preconditions or reasons identified by the legislation itself, whose occurrence shall be required and shall make the processing lawful (so-called legal basis of the processing).
While browsing the site, the Data Controller may acquire information concerning the user in the following ways:
 

DATA COMMUNICATED BY THE USER

This category of data includes any information that the user provides optionally, explicitly and voluntarily by using the site (name, surname, address, contact details, any company name), in order to send any requests for information concerning Rollwasch products® by filling in the "Contacts" or "Looking for a solution - search for use" forms on the homepage of the site or by otherwise contacting the Data Controller through the contact details on the same site.
Such data (including any additional personal data contained in the aforementioned communications or user requests) shall be processed:

a) to contact the user to supply the requested information, providing as adequate and specific feedback as possible.

The voluntary, optional, and explicit provision of any data through the site equals the explicit consent to the Data Controller use of said information to answer any requests received.
The personal data collected will be processed and stored in the Data Controller's electronic or paper databases for the time strictly necessary to respond to the request and for a further 3 months after the last interaction with the user.
Once this time has elapsed, any personal data acquired shall be erased from any database, except for the recurrence of any further legitimate reasons for processing based on any subsequent requests or orders for products by the user who initially requested the information.
In such case, the Data Controller may combine the data acquired at the time of the first request for information and/or those acquired at the time of any subsequent requests to legitimately and more easily carry out any pre-contractual and contractual measures that may be necessary in case of an explicit request/order from the user, and for the entire duration of the period that is necessary to deal with such requests/orders.
PLEASE NOTE:
The express withdrawal of the consent given for the aforementioned purposes shall make it impossible for the Data Controller to provide any requested information.

    b) as far as contact details are concerned, even in order to send information and updates of a commercial nature about Rollwasch® products and services and to send invitations to any events and trade fairs concerning the product sector of the Data Controller's products.

Any requests for information sent through the website in connection with Rollwasch® products/services may demonstrate the user's interest to be kept up-to-date concerning such products/services, also by receiving offers tailored based on shared interests and preferences, as well as on major industry events/fairs.
In any case, the Data Controller shall use the contact details provided by the user for this purpose only and exclusively subject to the user's express consent to receive such communications.
The consent to such processing may be expressed by using the dedicated command that will be displayed during navigation when the data are provided through the site.
Once consent has been given, the Data Controller shall retain the aforementioned contact details and process them to send the information above until the user revokes, freely and at any time, the consent initially given by sending a specific request in the manner indicated in Section 1) above.
 

NAVIGATION DATA

During their regular operation, the IT systems and software procedures that are used to operate the websites acquire some personal data whose transmission is implicit in the use of the communication protocols of the Internet.
Such data are required to use the website, to guarantee its correct functioning and to monitor the security of the site itself.
In this regard, please refer to the "COOKIE" section below as well.

PLEASE NOTE:
The aforementioned personal data may also, where necessary, be transmitted to the police and the judicial and administrative authorities, in accordance with the law, for the detection and prosecution of crimes, the prevention and protection from threats to public safety, as well as to allow the Data Controller to exercise or protect its rights or those of third parties before the competent authorities, as well as for other reasons related to the protection of the rights and freedoms of others.
In this case, personal data will be stored for as long as is necessary to defend or enforce a right or to comply with any further legal obligations or orders issued by any Authorities.

3) COMMUNICATION OF DATA TO THIRD PARTIES

The personal data referred to in the privacy statement herein shall in no way be communicated directly to third parties, except for:

  • Subjects who are part of the Data Controller's distribution network, properly appointed as Data Processors, for the sole purpose of better managing any requests for information concerning Rollwasch® services and products and exclusively for the time frame that is necessary for such purpose.
  • Staff members duly and formally in charge of the data processing and adequately trained (personnel assigned to the administrative, commercial, technical, production or IT department) for any activities that are instrumental and/or connected to the provision of the information or service requested.
  • The company ALEKOS.NET di Dario Sabbadini, with registered office in P.za Giosia Monti no. 6, Milan, a company that takes care, monitors, and manages the operation of the website, thus appropriately appointed as Data Processor by the Data Controller.
    In performing said activities, the aforementioned company may have access to the personal data indicated above, which shall be processed (in the form of mere consultation and possible archiving as part of the aforementioned activities) exclusively for the time frame that is necessary for this purpose.
  • Administrative/judicial authorities to protect any rights or ascertain/prevent any offences or in the event of an explicit request by said Authorities.

 

4) SECURITY MEASURES
The Data Controller shall process and store the data both electronically and analogically by taking all the most appropriate IT, physical, logical and organisational security measures aimed at preventing any violation of the rights of the users conferred or legitimately acquired through the site.
The Data Controller shall test, check and regularly assess the effectiveness of security measures, to guarantee continuous improvement in the safety of the processing.

5) COOKIES
Cookies are usually strings of text that websites (so-called "first parties") visited by the user or other websites (so-called "third parties") place and store – directly, in the case of first parties, and indirectly, i.e. through the latter, in the case of "third parties – in a terminal device available to the user.
As an example, the terminals referred to are computers, tablets, smartphones or any other device capable of storing information.

The Data Controller does not use profiling cookies (usually used to link specific, identified or identifiable subjects, specific actions or behavioural patterns recurring in the use of the functions offered for the purpose of grouping the different profiles within homogeneous clusters of different width), nor cookies for statistical, analytical or marketing purposes.

Specifically, only a technical session cookie with a value equal to "1" or "0" is used, which indicates whether the user's browser type supports Javascript technology.

The use of such type of cookie does not require the user’s prior consent but, in any case, the user may disable them by following the instructions provided by the browsers used to navigate and available at the addresses below:

https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies
https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cooki...
http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
https://support.apple.com/kb/PH19214?viewlocale=it_IT&locale=en_US

Disabling such cookies may affect or prevent the correct or complete navigation of the site.

THIRD PARTY COOKIES

  • Within its pages, the site may even incorporate videos from YouTube, a platform owned by Google and used to share videos that use cookies to collect information concerning users and navigation devices.

 

By default, the site is structured in such a way that no cookies are installed on the user's device by the Data Controller when the user visits the site and when it views the video, except for technical/functional cookies.

In case the user visits the website of the third party mentioned above, including through any link to a video published on the site, any cookies installed by the third party and their relevant use are governed according to the rules established by that third party. Therefore, Users are recommended to read the privacy statements and instructions for the managing or disabling of cookies, available at:

https://consent.youtube.com/d?continue=https://www.youtube.com/%3Fhl%3Di...

 

  • SOCIAL NETWORK PLUGIN

Furthermore, the site may incorporate links to social media platforms (Facebook, LinkedIn, Twitter) to enable sharing of any site content on the related social networks.
In this case, by selecting the link while browsing the site, the corresponding social network provider may install additional cookies on the user's device.
By default, the site navigation does not allow the operator of the social media in question to install cookies until the user clicks on the related link.
As already mentioned in the introduction, these cookies are not managed by the Data Controller's site, and their relevant use is governed according to the privacy statements issued by the social networks in question.
Therefore, in case the Users do not want cookies to be placed through the aforementioned activity by the operators of the platforms indicated, they are invited to consult the related information available at the links below:

https://www.facebook.com/policies/cookies/
https://help.twitter.com/it/rules-and-policies/twitter-cookies
https://www.linkedin.com/legal/cookie-policy

6) RIGHTS OF THE DATA SUBJECTS
The data subject has the rights below:
  - the data subject has the right to ask the Data Controller to

  • access any personal data being processed and any information concerning them: should the data subject so wish, the Data Controller shall provide a copy of all personal data in its possession;
  • rectify any inaccurate data or integrate any incomplete data;
  • request to obtain the personal data from the Data Controller in order to transfer them to another Data Controller, in the cases envisaged by Article 20 of the GDPR (so-called right to data portability).
  • erase the personal data (upon the occurrence of one of the conditions indicated in Article 17, paragraph 1 of the GDPR and in compliance with the exceptions envisaged by paragraph 3 of the same article); 
  • restrict the processing of personal data (in the event of one of the cases indicated in Article 18, paragraph 1 of the GDPR);
  • object to the processing of personal data in compliance with the provisions of Article 21 of the GDPR.

 

The exercise of the right of restriction, objection, erasure or withdrawal of the consent given, where it is required by the data processing, may make it impossible for the Data Controller to provide the service or the information requested from the user.

To notify the Data Controller of the wish to exercise one of the rights listed above, the methods mentioned in section 1) above may be used.

  • lodge a complaint with the Italian Data Protection Authority, in case it deems that a violation of rights concerning the processing of personal data occurred or is in progress: for this purpose, the Data Controller shall recommend the users of the site to consult the specific operating instructions available at the address below:

 

https://www.garanteprivacy.it/modulistica-e-servizi-online/reclamo

7) CHANGES TO THE STATEMENT HEREIN
The Data Controller encourages users to monitor any changes to this privacy statement that may be necessary due to changes in the website functionality or to new legislation.
Where possible, the Data Controller shall promptly notify users of any changes made and their consequences.