1. Categories of Personal Data processed

   The Data Controller processes the following types of Personal Data provided voluntarily by the Data Subject:

   • Contact details: name, surname, address, email, telephone number, images, authentication credentials, any additional information sent by the interested party, etc.

   The Data Controller processes the following types of Personal Data collected automatically:

   • Technical dataPersonal Data generated by the devices, applications, tools, and protocols used, such as information about the device used, IP addresses, browser type, and Internet Service Provider (ISP). This Personal Data may leave traces that, particularly when combined with unique identifiers and other information received from servers, can be used to create profiles of natural persons.
   • Browsing and Application usage data: such as, for example, pages visited, number of clicks, actions performed, session duration, etc.
   • Data relating to the precise location of the interested partyFor example, geolocation data that precisely identifies the data subject's location, which can be collected via satellite networks (e.g., GPS) and other means, collected with the data subject's consent. The data subject may withdraw their consent at any time.

   Failure by the Data Subject to provide Personal Data for which there is a legal or contractual obligation, or where such data constitutes a necessary requirement for the conclusion of the contract with the Data Controller, will make it impossible for the Data Controller to establish or continue the relationship with the Data Subject.

   The interested party who communicates the personal data of third parties to the Data Controller is directly and exclusively responsible for their origin, collection, processing, communication, or dissemination.

2. Cookies and similar technologies

   The Application uses cookies, web beacons, unique identifiers, and other similar technologies to collect Personal Data from the Data Subject on the pages, links visited, and other actions performed when the Data Subject uses the Application. This data is stored and then transmitted during the Data Subject's next visit. The complete Cookie Policy can be viewed at the following address: CDRITALIA – COOKIE POLICY

3. Legal basis and purpose of the processing

   The processing of Personal Data is necessary:

   1. for the execution of the contract with the interested party and specifically:
      1. fulfillment of any obligation arising from the pre-contractual or contractual relationship with the interested party
      2. support and contact with the interested party: to respond to the interested party's requests
   2. by legal obligation and specifically:
      1. the fulfillment of any obligation required by current legislation, laws and regulations, in particular, in tax and fiscal matters
   3. based on the legitimate interest of the Data Controller, for:
      1. email marketing purposes for the owner's products and/or services
         to directly sell the Data Controller's products or services using the email address provided by the Data Subject in the context of the sale of a product or service similar to the one being sold
      2. statistics with anonymous data: to carry out statistical analyses on aggregate and anonymous data to analyse the behaviour of the interested party, to improve the products and/or services provided by the Data Controller and better meet the expectations of the interested party
   4. on the basis of the interested party's consent, for:
      1. profiling of the interested party for marketing purposes: to provide the interested party with information on the Data Controller's products and/or services through automated processing aimed at collecting personal information with the aim of predicting or evaluating his/her preferences or behaviors
      2. retargeting and remarketing: to reach the Data Subject who has already visited or shown interest in the products and/or services offered by the Application using his/her Personal Data with a personalized advertisement. The Data Subject can opt-out by visiting the Application page.
         Network Advertising Initiative
      3. marketing purposes of the Data Controller's products and/or services: to send commercial and/or promotional information or materials, to carry out direct sales activities of the Data Controller's products and/or services or to carry out market research using automated and traditional methods
      4. detection of the exact position of the interested party: to detect the presence of the interested party, to control access, times and presence of the interested party in a specific place, etc.

   Based on the Data Controller's legitimate interest, the Application allows interaction with external platforms or social networks whose processing of Personal Data is governed by their respective privacy policies, to which we encourage you to refer. The interactions and information acquired by this Application are, in any case, subject to the privacy settings chosen by the Data Subject on such platforms or social networks. This information—in the absence of specific consent to processing for additional purposes—is used solely to enable use of the Application and provide the requested information and services.

   The Data Subject's Personal Data may also be used by the Data Controller to defend itself in legal proceedings before the competent judicial authorities.

4. Methods of processing and recipients of personal data

   Personal Data is processed using paper and electronic means, following organizational methods and logic strictly related to the indicated purposes, and through the adoption of appropriate security measures.

   Personal Data is processed exclusively by:

   • persons authorized by the Data Controller who have undertaken to maintain confidentiality or have an appropriate legal obligation of confidentiality;
   • entities operating independently as separate data controllers or entities designated as data processors by the Data Controller in order to carry out all processing activities necessary to pursue the purposes set out in this policy (for example, commercial partners, consultants, IT companies, service providers, hosting providers);
   • subjects or entities to whom it is mandatory to communicate Personal Data by law or by order of the authorities.

   The subjects listed above are required to use appropriate safeguards to protect Personal Data and may access only that data necessary to perform the tasks assigned to them.

   Personal Data will not be disclosed indiscriminately in any way.

5. Place

   Personal Data will not be transferred outside the European Economic Area (EEA).

6. Personal Data Retention Period

   Personal Data will be retained for the period of time necessary to fulfill the purposes for which they were collected, in particular:

   • For purposes related to the performance of the contract between the Data Controller and the Data Subject, they will be retained for the entire duration of the contractual relationship and, after its termination, for the ordinary limitation period of 10 years. In the event of legal disputes, they will be retained for the entire duration of the same, until the time limit for filing appeals has expired.
   • for purposes related to the legitimate interest of the Data Controller, they will be retained until such interest is fulfilled
   • for the fulfillment of a legal obligation, by order of an authority and for legal protection, they will be retained in compliance with the timeframes established by said obligations, regulations and in any case until the expiry of the limitation period established by the regulations in force
   • for purposes based on the consent of the interested party, they will be retained until the consent is revoked

   At the end of the retention period, all Personal Data will be deleted or stored in a form that does not allow the identification of the Data Subject.

7. Rights of the interested party

   Data subjects may exercise certain rights with respect to the Personal Data processed by the Data Controller. In particular, the Data Subject has the right to:

   • be informed about the processing of your Personal Data
   • revoke consent at any time
   • limit the processing of your Personal Data
   • object to the processing of your Personal Data
   • access your Personal Data
   • verify and request the rectification of your Personal Data
   • obtain the limitation of the processing of your Personal Data
   • obtain the deletion of your Personal Data
   • transfer your Personal Data to another owner
   • lodge a complaint with the supervisory authority for the protection of your Personal Data and/or take legal action.

   To exercise their rights, interested parties may send a request to the following email address:
   info@cdritalia.it. Requests will be processed immediately by the Data Controller and processed as quickly as possible, in any case within 30 days.

Last updated: July 7, 2022