1) DATA CONTROLLER AND CONTACT DETAILS: The Data Controller is Ave S.p.A., acting through its pro tempore legal representative. The company registered office is located in Via Mazzini 75, 25086 Rezzato (Brescia), Italy, email email@example.com.
2) PROCESSING PURPOSE AND LEGAL BASIS: Your personal data will be acquired and processed, with your consent where required, to ensure the registration to Ave S.p.A. websites and to enable providing contents and services offered by the a.m. websites or any online platforms connected to them; to carry out market and statistical surveys for strategic and operational direct marketing purposes, including the despatch of advertising technical and promotional material (catalogues, newsletters and community events participation) by emails, SMS, mail or telephone calls done by operators. This may be used for customer satisfaction measurement of the products and service quality, for sales contracts (signing and execution) and for IT security purposes or to fulfil any obligations required by laws and regulations.The provision of personal data is freely chosen and optional. However, failure to provide data makes it impossible to register to websites and consequently to receive the requested services, information, communications, promotional advertising and technical material. Data are processed for the above purposes under art. 6, paragraph 1, letter a (consent), letter b (execution of pre-contractual and contractual obligations), letter c (fulfilment of legal obligations), letter f (legitimate interest) of EU Reg. 2016/679.
3) PERSONAL DATA CATEGORIES: The data collected and subject to processing are identification, personal or commercial data (e.g. name, surname, email address). Sensitive personal data (such as data relating to health or political opinions) or judicial data are not collected. Navigation or interaction data acquired from the IT systems and from software procedures of these websites or from third-party software are also collected (for example IP addresses, time of request). These data are used for comparing and in case improving the communication results.
4) LEGITIMATE INTERESTS OF THE DATA CONTROLLER: Processing your personal data is necessary for the above mentioned purposes. It is in Ave S.p.A.’s legitimate interest to process your personal data for direct marketing and IT security purposes. Your data will be processed using manual, IT and telematics tools in order to guarantee the security and confidentiality of your personal data, preventing their loss, illicit or incorrect use or any unauthorised access. The only parties entitled to process your data are the appointed Data Processors and Data Delegates. The collection, transmission, storage and retention of your personal data is protected by username and password, encryption protocols with SSL web certificates and by means of anti-brutal force and captcha protection systems. Your personal data are stored in protected electronic archives stored on Ave S.p.A. servers which are either located in its offices or managed by third-party providers. SSL protocols and special protection systems protect services used to communicate, promote, store and manage data.
5) DATA RECIPIENTS: Your personal data will not be disseminated, but they may be disclosed to those acting as Data Processors (e.g. Ave S.p.A agents or Technical Assistance Centre, companies or firms which carry out maintenance, management and consulting services to Ave S.p.A. IT systems), Data Delegates (Ave S.p.A. employees). Your data may be disclosed to third parties only when required to fulfil legal obligations or to protect Ave S.p.A contractual rights. A list of Data Processors is available at Ave S.p.A. registered office.
6) DATA RETENTION PERIOD: Your personal data will be processed using manual, IT and telematics tools and will be retained for the time required to pursue the purposes described above and diligently guarantee the provision of the requested services, unless a longer period is necessary or allowed by law.
7) RIGHTS OF THE DATA SUBJECT: You 1) are entitled at any time to know whether your personal data is being processed, and if so, to request and obtain access to your personal data and to the information about the data processing purpose, to the processed data categories and to the data recipients and the data retention period. You are also entitled to be informed about the origin of the data and to have a copy of the same (art. 15 EU Reg.); 2) are entitled at any time to request the amendment and/or integration of personal data (art.16 EU Reg.) and/or data cancellation (art. 17 EU Reg.) and/or processing restriction (art.18 EU Reg.); 3) are entitled to data portability (art. 20 EU Reg.); 4) are entitled to object to the processing (art. 21 EU Reg.); 5) are entitled to lodge a complaint with the competent supervisory authority (Data protection supervisor), if you consider that the processing of your personal data is contrary to the current legislation. Requests should be sent in writing and sent either by post to Ave S.p.A., Via Mazzini 75, 25086 Rezzato (Brescia), Italy, for the attention of Segreteria Generale or by email to firstname.lastname@example.org.
Policy on personal data processing published on 29th January 2018. Last update 27th April 2018.