- D.Lgs. of 10th August 2018 n. 101 Adjustment of national norms to the GDPR (EU regulation n. 679 of 27th April 2016);
- EU regulation n. 679 of 27th April 2016 relating to personal physical security with regard to processing of personal data as well as free circulation of personal data (hereinafter refereed to as EU regulation);
- Recommendation n 2/2001 of 17th May 2001 relating to minimum requests for collection of on-line data in the European Union, adopted by the European Authority for data protection, collected in the Group instituted by art. 29 of directive n. 95/46/CE (hereinafter referee to as Recommendation of Work Group ex art. 29).
- have transferred their personal data to PROGEL SpA due to a legitimate interest of the Controller or the interested party;
- Interact with web services offered by PROGEL SpA.
PROGEL SpA, in application of the EU regulation, wishes to inform the interested parties that the personal data of the interested parties will be subject to processing according to the reference norms listed above.
Data processing controller
PROGEL SpA, Via Due Ponti, 2, 40050, Argelato, BO, 051 6639411 email: firstname.lastname@example.org acts as “Data Processing Controller”.
Personal data subject to processing
Free navigation data
The IT systems and software procedures for the functioning of this website acquire certain data during the course of their activity (see below) whose transfer is implicit in the use of the Internet communication protocols. This is information that is not collected to be associated to identified interested parties, but which, by its very nature, can be used to identify certain characteristics of the users through elaborations and associations with data controlled by third parties. In this category of data there are IP addresses or dominions of user computers that connect to the site, addresses in URI (Uniform Resource Identifier) form of the required resources, the time of the request, the method used to make 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 (positive, error etc…) and other parameters relating to the operating system and the IT environment of the user. This data is used exclusively to obtain anonymous statistical information on the use of the site and to monitor the correct functioning qnd is conserved for a maximum of 7 days (according to Art. 25 of the EU Regulation). The only information that may be conserved for a longer period of time is that regarding the IP address exclusively for possible investigations into any hypothetical Internet crimes against the site.
The navigation on the www.progel.it site is not limited, is free and does not necessarily require registration.
Data voluntarily transferred by the user
The non-compulsory, explicit and voluntary transfer of personal data:
- in email messages sent to contacts published on the Site;
- in Web Forms published on the Site;
implies the subsequent acquisition of data that is necessary to satisfy the requests of the interested parties. The Web Forms may contain specific information in cases of particular on-demand services.
The transfer of data is non-compulsory and is therefore only required when it is essential to maintain a dedicated business relationship with the interested party relating to products and services that require it. For example, registration is required to:
- Sign up for events organised by PROGEL SpA
Receive information about initiatives, events and promotional discounts offered by PROGEL SpA.
Also in the case of user registration, the process of navigation data collection is the same as the one described in the previous paragraph “free navigation data”.
Public Site Cookies
No personal user data is acquired by the site. Cookies are not used to transfer personal data nor are persistent cookies of any kind used or systems for tracing users. The use of session cookies (which are not maintained on the user computer and disappear when the browser is shut down) is strictly limited to the transfer of session identifiers (made up fo random numbers generated by the server) required for the safe and effective navigation of the site. The session cookies used on this site avoid the use of other IT techniques which could potentially impair user navigation privacy and do not allow the acquisition of personal user identification data.
All the information regarding Cookies can be consulted in the related policy notice.
Purpose and legal basis for processing
The data collected during navigation is processed automatically and “under obligation” by PROGEL SpA to allow navigation itself. In this case collection occurs based on legal obligations that PROGEL SpA is subject to, as well as per a legitimate interest of PROGEL SpA to guarantee the correct function and the security of the web site. Express consent of the interested party is therefore not necessary.
With regard to personal data transferred on a voluntary basis, processing is performed to offer the interested party prompt feedback. In this case the processing is based on the execution of a request. Therefore express consent is not necessary.
Nature of transfer of personal data
Without prejudice to the above specified for navigation data relating to which the transfer is compulsory as they are required for navigation on the PROGEL SpA website, the user is free to transfer personal data to receive information from PROGEL SpA.
Data transferred to PROGEL SpA is mainly processed with automatic tools exclusively for the indicated purposes and the time strictly necessary to perform the tasks for which they are collected. Specific security measures are taken to avoid loss of data, illicit or incorrect use and non authorised access. Processing of personal data is in any case performed by subjects designated to the processing of personal data, specifically designated, authorised and trained for said purpose.
The processing of personal data is performed with full respect of safety and privacy dispositions as well as the correctness, the update and the pertinence of the same with respect to the purposes declared.
Duration of processing (Conservation)
Without prejudice to the fact that navigation data does not last for more than 7 days, the processing of perusal data occurs for the time strictly necessary to pursue the purpose for which the same are collected and in any case based on the period indicated in the Processing Register.
Recipient of personal data
The data transferred will be used for the contractual purposes and possibly transferred to third parties or disseminated to pursue the same purposes. Unless otherwise indicted in the policies referring to single processing, the personal data collected will not be communicated to third parties or disseminated. In these cases specific consent will be requested.
Exclusively for the purposes identified in this policy document, the personal data of the interested party could be communicated in Italy and abroad, inside the EU territory to meet legal obligation or to meet requests of the interested party themselves.
The personal data will not be processed in third party countries and will not be disseminated and therefore not made available to the public or an undefined number of individuals.
Rights of the interested party
The subjects to whom the personal data that PROGEL SpA holds refers have the right, at any time, to obtain confirmation of the existence or not of said data and to know the content and origin, to verify the correctness or request updates, corrections or integrations by exercising the rights assigned under art. 15 of the EU Regulation and the rights under articles 16, 17, 18 and 21 of the same regulation regarding the correction, cancellation, limitation and opposition to processing of personal data.
The interested party can exercise their rights by contacting the Controller using the related address: email@example.com .
Unless otherwise specified, the response will be sent by PROGEL SpA to the sender’s email address.
If PROGEL SpA does not answer within the times set by the regulation or the answer to the exercise of rights is not suitable, the interested party may make a claim to the Guarantor for the Protection of Personal Data (Garante per la Protezione dei Dati Personali) at the following contacts:
Garante per la Protezione dei Dati Personali
Piazza Venezia n. 11 – 00187 Roma
Fax: (+39) 06.69677.3785
Phone operator: (+39) 06.69677.1
Policy updated to 14/09/2018