GDPR

NEWSLETTER

PRIVACY NOTICE
pursuant to Article 13 of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (GDPR)

Vortice S.p.A. (hereinafter “Company”), with headquarter in Strada Cerca 2 – Frazione Zoate – 20067 Tribiano (MI), is the data controller and intends to inform you that the processing of your personal data is in compliance with the current legislation on the protection of personal data, including the EU Regulation 2016/679 (the "GDPR").

Type of personal data processed
The personal data processed by the controller are the following: Name, Surname, Mail Address, Address, Phone Number, Type of user.

Legal basis, Purposes and Nature of the processing
Legal basis of the processing is based on data subject’s consent to the processing of his/her personal data for marketing purposes, as described in this privacy notice.
The personal data provided by the data subject will be processed for the purposes of direct marketing activities also through the sending of the newsletter.
The provision of the consent is optional, however your possible refusal to provide the consent may lead to the result that is not possible for the Data Controller to pursue the purpose above mentioned.

Processing methods
Personal data will be processed with information systems suitable to ensure security and confidentiality, in full compliance with Chapter II (Principles)  and Chapter IV (Controller and processor) of the Regulation.
The processing can also be carried out by automated tools in order to memorize, manage or transmit personal data. The processing of your personal data is carried out by means of the operations indicated in Article 4,( 2) of the Regulation, to which it refers for any useful purpose.

Data Retention Period
Personal data collected will be processed and stored for the duration of 48 months. After that they will be erased or anonymized on permanent basis.

Access to personal data
Your personal data may be made accessible to:

• employees and collaborators of the Company, duly authorized by the Data Controller, in their capacity as persons authorized to process and / or system administrators within the Company;
• authorized representatives, including companies, consultants, self-employed professionals, also in associated form, and / or other collaborators, who provide services functional to the purposes, as data processors, with particular but not exclusive regard to technological, accounting, administrative, legal, fiscal and financial matters;
• subjects to which is entrusted the service of maintenance and development of our computer system, for the time strictly necessary to the execution of the services.

The complete list of all the external people which the data can be accessible could be available by sending an email at privacy@vortice.com

Data communication
Also without your explicit consent the data controller could communicate your personal data to authorities, supervisory bodies or any other subject where the data communication is mandatory by Law.

The complete list of all the external people which the data can be accessible could be available by sending an email at privacy@vortice.com

Data transfer
Management and storage of personal data shall be in servers located in European Union, belonging to the Data Controller or to third-party companies duly appointed as Processors. Data won’t be transferred outside European Union. However, the Data Controller has the right to change the servers’ location inside the European Union and/or to Countries Extra-UE.  In the latter case, the Data Controller ensures that Extra-UE data transfer shall be in full compliance with Articles 44 and following of the Regulation, and will provide appropriate safeguards by contractual clauses between the Data Controller and the recipient of the personal data in the third country.

Data Subject Rights
We inform you that at any time in relation to your data, you can exercise the rights under Articles 15 to 22 of the GDPR.
In order to exercise your rights, please contact the data controller with a written, dated and signed request, sent to the company's attention, at the following address: privacy@vortice.com; this request will be provided with appropriate feedback within 30 days.

In detail:

(a) You have the right to obtain from the Company 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 and the following information:

• The purposes of the processing;
• The categories of personal data concerned;
• The recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• The  period for which the personal data will be stored;
• Where the personal data are not collected from the data subject, any available information as to their source;
• The existence of automated decision-making, and, at least in those cases, meaningful information about the logic;
• The appropriate safeguards pursuant to Article 46 of the GDPR relating to the transfer.

(b) Moreover you have the right of the:

• Access, update, rectification, integration or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; 
• Obtain the data portability;
• Withdraw consent to the processing of personal data, if applicable;
• To lodge a complaint with a supervisory authority.

In order to exercise your rights, please contact the data Controller with a written request and send it at the following address privacy@vortice.com.

The Data Controller will provide information on action taken on a request under Articles 15 to 22 to you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Data controller will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

REGISTRATION

PRIVACY NOTICE
pursuant to Article 13 of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (GDPR)

Vortice S.p.A. (hereinafter “Company”), with headquarter in Strada Cerca 2 – Frazione Zoate – 20067 Tribiano (MI), is the data controller and intends to inform you that the processing of your personal data is in compliance with the current legislation on the protection of personal data, including the EU Regulation 2016/679 (the "GDPR").

Type of personal data processed
The personal data processed by the controller are the following: Name, Surname, Address, Mail Address, phone number,  Type of user.

Legal basis, Purposes and Nature of the processing
Legal basis of the processing is based on data subject’s consent to the processing of his/her personal data for purposes b) and c) and the execution of the contract for the purpose a)

The personal data provided by the data subject will be processed for the following purposes:

a.       Management and execution of the contractual relationship and related obligations;
b.       Direct marketing activities also through the sending of newsletter, SMS and MMS messages and other technological systems;
c.       Market  research or other research aimed at improving the company’s products and services.

The provision of the consent is optional, however your possible refusal to provide the consent may lead to the result that is not possible for the Data Controller to pursue the purpose above mentioned.

Processing methods
Personal data will be processed with information systems suitable to ensure security and confidentiality, in full compliance with Chapter II (Principles)  and Chapter IV (Controller and processor) of the Regulation.
The processing can also be carried out by automated tools in order to memorize, manage or transmit personal data. The processing of your personal data is carried out by means of the operations indicated in Article 4,( 2) of the Regulation, to which it refers for any useful purpose.

Data Retention Period
Personal data collected will be processed and stored for the duration of the contract between you and the Company and, after its termination, for purposes related to the fulfilment of regulatory obligations in the administrative-accounting, tax, fiscal and civil matters for the purpose a).
Personal data collected will be processed and stored for the duration of 48 months for the purposes b) and c). After that they will be erased or anonymized on permanent basis.

Access to personal data
Your personal data may be made accessible to:

• employees and collaborators of the Company, duly authorized by the Data Controller, in their capacity as persons authorized to process and / or system administrators within the Company;
• authorized representatives, including companies, consultants, self-employed professionals, also in associated form, and / or other collaborators, who provide services functional to the purposes, as data processors, with particular but not exclusive regard to technological, accounting, administrative, legal, fiscal and financial matters;
• subjects to which is entrusted the service of maintenance and development of our computer system, for the time strictly necessary to the execution of the services.

The complete list of all the external people which the data can be accessible could be available by sending an email at privacy@vortice.com

Data communication
Also without your explicit consent the data controller could communicate your personal data to authorities, supervisory bodies or any other subject where the data communication is mandatory by Law.

The complete list of all the external people which the data can be accessible could be available by sending an email at privacy@vortice.com

Data transfer
Management and storage of personal data shall be in servers located in European Union, belonging to the Data Controller or to third-party companies duly appointed as Processors. Data won’t be transferred outside European Union. However, the Data Controller has the right to change the servers’ location inside the European Union and/or to Countries Extra-UE.  In the latter case, the Data Controller ensures that Extra-UE data transfer shall be in full compliance with Articles 44 and following of the Regulation, and will provide appropriate safeguards by contractual clauses between the Data Controller and the recipient of the personal data in the third country.

Data Subject Rights
We inform you that at any time in relation to your data, you can exercise the rights under Articles 15 to 22 of the GDPR.
In order to exercise your rights, please contact the data controller with a written, dated and signed request, sent to the company's attention, at the following address: privacy@vortice.com; this request will be provided with appropriate feedback within 30 days.

In detail:

(a) You have the right to obtain from the Company 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 and the following information:

• The purposes of the processing;
• The categories of personal data concerned;
• The recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• The  period for which the personal data will be stored;
• Where the personal data are not collected from the data subject, any available information as to their source;
• The existence of automated decision-making, and, at least in those cases, meaningful information about the logic;
• The appropriate safeguards pursuant to Article 46 of the GDPR relating to the transfer.

(b) Moreover you have the right of the:

• Access, update, rectification, integration or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; 
• Obtain the data portability;
• Withdraw consent to the processing of personal data, if applicable;
• To lodge a complaint with a supervisory authority.

In order to exercise your rights, please contact the data Controller with a written request and send it at the following address privacy@vortice.com.
The Data Controller will provide information on action taken on a request under Articles 15 to 22 to you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Data controller will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

COOKIES

COOKIES PRIVACY NOTICE
Pursuant to Art. 13 of Regulation UE 2016/679 on the Protection of Personal Data, we inform you that information may be collected through “Technical Cookies” and “Third-party Analytical Cookies with reduced identification power” (for further information in this regard, refer to the section “Categories of Cookies” given below).

What are Cookies?
Cookies are made up of portions of code installed within the browser that help the Data Controller deliver the service, based on the purposes described.

Through Cookies, the website retains certain information that may later be retransmitted when you return to the website or navigate from one page to another. Cookies are also usually used to store anonymous information regarding the navigation of the pages (entry and exit links, time spent on the page), monitoring and analysing the performance, operation and effectiveness of the Website in order to be able to improve and optimise it.

Some of the purposes of installing Cookies could, moreover, require the consent of the user.

Data Controller
Data Controller is Vortice S.p.A. (hereinafter “Company”), with headquarter in Strada Cerca 2 – Frazione Zoate – 20067 Tribiano (MI)

Categories of Cookies – Data Processing Purposes
Technical cookies

These cookies aid navigation or provide a service requested by the user. They are not used for additional purposes and are usually installed directly by the Data Controller of the website.

Without using these cookies, certain operations could not be carried out or would be more complex and/or less secure, such as, for example, the activities for which cookies are indispensable to enable the identification of the user to be carried out and maintained during the session.

This type of cookie is strictly necessary for the proper operation of some sections of the Website. There are two categories:

1.            persistent: once the browser is closed, they are not destroyed but remain until the preset expiry date
2.            session: they are destroyed every time the browser is closed.

These cookies, always sent by our website, are necessary to properly display the website and for the technical services offered. They will therefore always be used and sent, unless the user changes the settings in their browser (thereby affecting the display of the pages of the website.

First-party analytical cookies
Cookies in this category are used to collect information on the use of the website.
These cookies, which collect information in aggregate form on the number of users and how they visit the website, are used for the purpose of optimising the website directly by the website’s Data Controller.

Third-party analytical cookies with reduced identification power
Cookies in this category are used to collect information on the use of the website.
They are cookies created and made available by Third Parties merely for statistical purposes that adopt suitable tools to reduce the identification power of the analytical cookies that are used (for example, by masking significant portions of the IP address).

Third-party analytical cookies without reduced identification power
Cookies in this category are used to collect information on the use of the website.
They are cookies created and made available by Third Parties merely for statistical purposes that do NOT adopt suitable tools to reduce the identification power of the analytical cookies that are used (for example, by masking significant portions of the IP address).

First-party profiling cookies
These are cookies used by the website provider to track the user’s navigation on the internet and create profiles on their tastes, attitudes, choices etc. Through these cookies, advertising messages can be transmitted to the user's terminal in line with the preferences already displayed by the same user in their online navigation.

Third-party profiling cookies – Purpose of the Processing
These are cookies used by third parties to track the user’s navigation on the internet and create profiles on their tastes, attitudes, choices etc. With these cookies, advertising messages can be transmitted to the user's terminal in line with the preferences already displayed by the same user in their online navigation.

Cookies used by the Website
Our website does not in any way use the following Cookies:

• First-party analytical cookies
• Third-party analytical cookies without reduced identification power
• First-party profiling cookies
• Third-party profiling cookies

However, our website does use the following Cookies:

• Technical cookies – the website uses technical cookies for its proper operation.
• Third-party analytical cookies with reduced identification power – the Google Analytics system is used to track user navigation data for statistical purposes. A mechanism for reducing the identification power is used to preserve the user's privacy.

In order to decide whether to accept or reject the use of cookies, a description is given below of the various types of those potentially used on our website:

How can I control the installation of Cookies?
In addition to what is indicated in this document, the user can manage their preferences regarding Cookies directly within their own browser and prevent - for example – third parties installing them. Through the browser’s preferences, it is also possible to eliminate Cookies installed in the past, including Cookies for which the consent to the installation of Cookies by this website may have been saved.

It is important to note that, by disabling all Cookies, the operation of this website could be compromised.

The user can find information on how to manage Cookies by viewing the information in the last column of the table above..

Data Processing Nature and Legal Basis of Processing
In order not to consent the data processing related to the use of cookies, it is necessary to disable them.
The consent of personal data through cookies is optional, but some services, should cookies be disabled, could be unusable or difficult to use.
Lawfulness of processing is based on purposes of the legitimate interests pursued by the controller, which means the website technical operation of the Website and on consent to the processing of data subject’s personal data for purposes described in this privacy notice.

Data Processing Modalities
The Data Controller stores and processes personal data with electronic tools. Data will be stored both on digital media and on paper, organised in databases, in compliance with security measures pursuant to Chapter II (Principles) and Chapter IV (Data Controller and Data Manager) of the Regulation.

Recipients or Categories of Recipients of Personal Data
Data collected are processed by Company’s personnel under the authority of the controller according to instructions provided by the Controller pursuant to Art. 29  of Regulation.

Data could be communicated to third parties appointed as Data Processor pursuant to Art. 28 of Regulation, for purposes described in this Privacy Notice:

• qualified subjects that provide the Company with supplies or services instrumental to the purposes referred to above, subjects and companies that may be called upon to manage and/or take part in the management and/or maintenance of our internet sites and the electronic and/or digital transmission tools, appropriately appointed as External Data Processor pursuant to Article 28 of the Regulation through specific appointment clauses defining data processing and data retention security measures to be implemented;
• parent companies, subsidiaries and/or affiliates for accounting administration purposes;
• any other subject to which the data may have to be communication on the basis of an express legal measure.

The completed list of Data Processors is available sending a request via e-mail to the address privacy@vortice.com

Transfer of Personal Data
The management and retention of the personal data shall take place on servers, located within the European Union, of the Data Processor and/or third-party companies duly appointed as Data Managers.
The data are not currently subject to transfer outside the European Union. In any event, it remains understood that the Data Controller, should it be necessary, shall have the right to change the location of the servers within the European Union and/or to countries outside the EU.
In this case, the Data Controller guarantees henceforth that the transfer of the data outside the EU shall take place in compliance with articles 44 and subsequent of the Regulation and the applicable legal measures stipulating, where necessary, agreements that ensure an adequate level of protection.

Data Retention Period
The data concerning you shall be retained in accordance with the following criteria:

• for a period of time no longer than that necessary to attain the purposes for which they are processed. Should you refuse to give consent to any cookies, your data shall be deleted;
• for a period of time no longer than necessary to fulfil regulatory obligations.

Data Subject Rights
We inform you that at any time in relation to your data, you can exercise the rights under Articles 15 to 22 of the GDPR.
In order to exercise your rights, please contact the data controller with a written, dated and signed request, sent to the company's attention, at the following address: privacy@vortice.com; this request will be provided with appropriate feedback within 30 days.

In detail:

(a) You have the right to obtain from the Company 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 and the following information:

• The purposes of the processing;
• The categories of personal data concerned;
• The recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• The  period for which the personal data will be stored;
• Where the personal data are not collected from the data subject, any available information as to their source;
• The existence of automated decision-making, and, at least in those cases, meaningful information about the logic;
• The appropriate safeguards pursuant to Article 46 of the GDPR relating to the transfer.

(b) Moreover you have the right of the:

• Access, update, rectification, integration or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; 
• Obtain the data portability;
• Withdraw consent to the processing of personal data, if applicable;
• To lodge a complaint with a supervisory authority.

In order to exercise your rights, please contact the data Controller with a written request and send it at the following address privacy@vortice.com
The Data Controller will provide information on action taken on a request under Articles 15 to 22 to you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Data controller will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

	CUSTOMER INFORMATION			SUPPLIER INFORMATION