A.T.O. S.r.l. in its role of data controller, pursuant to the European Regulation 679/2016 concerning the protection of personal data (GDPR), wishes to provide you with the following information.

IDENTITY AND CONTACT DETAILS OF THE CONTROLLER

The Data Controller, pursuant to art. 4 of the Regulation, is A.T.O. S.r.l. (C.F.: 02384740268), with registered office in Castello di Godego (TV), via dell’Artigianato n. 24, represented by its legal representative for the time being. In case of need, controller is available at the following email address: info@sincold.com

TYPES OF PERONAL DATA

The data provided by You and concerning the personnel assigned to the performance and management of the agreements with the Company are:

• Name, surname, contact data, email address, position where relevant;
• Name, surname, contact data, email address, of directors, employees and collaborators whose data may be processed by the Company for perfomance of the agreement;
• Bank data, economic and finalcial data related to invoicing and payments (included tax code an VAT number, etc..);
• Contact data and personal data of website users.

The Company will not ask for special categories of personal data (art. 9 of the Regulation).

If Controller will process special categories of personal data, it will ask for your specific consent, under specific information notice.

PURPOSES OF THE PROCESSING

The Company will process the data as follows:

PURPOSES OF THE PROCESSING

Within the performance of its own commercial and financial activities, in particular in order to comply with legal obligations

LAWFULNESS OF PROCESSING

Art. 6.1 lett. b) of the Regulation (“processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”)

PURPOSES OF THE PROCESSING

Registration of suppliers and customers into the Company’s Management System, for the administrative management of the contacts

LAWFULNESS OF PROCESSING

Art. 6.1 lett. b) of the Regulation (“processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”)

PURPOSES OF THE PROCESSING

For the compliance with legal or Authority obligation to which the controller is subject

LAWFULNESS OF PROCESSING

Art. 6.1 lett. c) of the Regulation (“processing is necessary for compliance with a legal obligation to which the controller is subject”)

PURPOSES OF THE PROCESSING

In the future, send promotional communications by email on products and services of the Holder similar to those required by contract, without prejudice to its right to object to such communications on the occasion of each dispatch.

LAWFULNESS OF PROCESSING

Art. 6.1 lett. F of the Regulation (“for the purposes of the legitimate interests pursued by the controller” and Whereas 47 of GDPR, and art. 130.4 D.lgs 196/03)

PURPOSES OF THE PROCESSING

Manage requests for information received by the contact form or by a direct request sent by email to the addresses found on the website.

LAWFULNESS OF PROCESSING

Art. 6.1 lett. b) of the Regulation (“processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”)

Art. 6.1 lett. a) of the Regulation (“the data subject has given consent to the processing of his or her personal data for one or more specific purposes”)

PURPOSES OF THE PROCESSING

Sending newsletters, except with the revocation of your consent.

LAWFULNESS OF PROCESSING

Art. 6.1 lett. a) of the Regulation (“the data subject has given consent to the processing of his or her personal data for one or more specific purposes i.e. in person, by delivering your business card, through the website of the owner ...)

A.T.O. does not make automated individual decision, including profiling.

NATURE OF COLLECTION

The collection of the data concerning a Data Subject is a requirement: failing this, it becomes impossible to enter into a commercial agreement, to duly fulfill the relevant pre-contractual or contractual obligations or, in case of existing agreements, to fulfill the obligations and commitments arising from such agreements.

PROCESSING DATA MEANS

Data will be processed by means of electronic or manual systems, and according to the principles of fairness, integrity and transparency that are required by applicable laws on data protection, as well as by preserving the privacy of the concerned persons through the implementation of the technical and organizational measures ensuring an adequate safety level.

Data could be processed by authorized persons pursuant to art. 29 or art. 28 of the Regulation.

PLACE OF PROCESS

Personal data will be stored by Company in its headquartes and offices.

DISCLOSURE, DISSEMINATION OF DATA

The data shall be processed by entrusted personnel by the Company, generally by the Purchaising department and by the Administration and Finance department, as well ad by other staff employees who could have the need to process them, pursuant to art. 29 of the Regulation.

Without prejudice to the duty of disclosure in order to fulfill any legal or contractual obligations, the data may be disclosed to tax or legal consultants, to Company’s collaborators, to the banks, to public entities as well as to those persons that are authorized by the laws to receive such data, if required, to Italian or foreign judicial or other public authorities for the fulfillment of legal obligations, or for the performance of the obligations arising from an agreement, including for the purposes of defence before the Courts. Such entities act as independent data controllers.

In order to perform certain services implying the need of personal data processing, the Company may also avail of third parties, pursuant to art. 28 of the Regulation, including in respect of the service of substitive filing or quality, process and product audit services. These companies shall operate as external data processor in compliance with specific and adequate directions concerning the processing methods and safety measures as specified in specific contractual documents. The full and updated list of the companies acting as data processors is available on request to the contacts already mentioned.

Personal data shall not be disseminated.

TRANSFER OF DATA

The Company does not transfer personal data outside the European Union.

In the case, in future, Controller will transfer the data to countries located outside the European Union, the Company undertakes to ensure a level of protection and preservation, also by means of entering into specific contracts, adequate to the applicable laws, including the entering into standard contractual clauses.

STORAGE OF DATA

All data will be kept for the time necessary to pursue the above-mentioned purposes for which they were collected (first, for the management and development of the commercial and contractual relationship), in compliance with the principle of minimization and limitation of conservation pursuant to the art. 5 of the GDPR.

The data will be stored to fulfil legal obligations and to pursue the above-mentioned purposes in compliance with the principles of indispensability, non-surplus and relevance.

The Holder could keep the data after the termination of the contractual relationship in order to fulfil regulatory and / or post-contractual obligations and for the purposes of a possible defence in court; subsequently, once the aforementioned reasons for processing cease to exist, the data will be deleted, destroyed or simply stored anonymously. The receipt of communications for commercial or informational purposes by A.T.O. will occur until consent is revoked. In this case, the company will delete the data from its databases.

RIGHTS OF DATA SUBJECTS

A Data Subject shall have the rights contemplated in the Regulations, from art. 15 to 22, and in particular:

RIGHT: Withdraw the consent (art. 13.2 lett. A and art. 9.2 lett. A)

DESCRIPTION: Data Subject has the right to withdraw previously given consent, if any, without prejudice to the lawfulness of processing based on that consent.

HOW TO EXERCISE THE RIGHT: By sending an email to Controller

RIGHT:  Right of access by the data subject (art. 15)

DESCRIPTION: The data subject shall have the right to obtain from the controller 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; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal data are not collected from the data subject, any available information as to their source;

the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. You can obtain a copy of the requested information.

HOW TO EXERCISE THE RIGHT: By sending an email to Controller

RIGHT: Right to rectification (art. 16)

DESCRIPTION: The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. 2Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
HOW TO EXERCISE THE RIGHT:By sending an email to Controller

RIGHT: Right to erasure (‘right to be forgotten’) (art. 17)

DESCRIPTION: The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

the data subject withdraws consent; the personal data have been unlawfully processed; the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

the personal data have been collected in relation to the offer of information society services referred to in Article 8. Erasure shall not be applied when the processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; for reasons of public interest in the area of public health; for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes or for the establishment, exercise or defence of legal claims.

HOW TO EXERCISE THE RIGHT:  By sending an email to Controller

RIGHT: Right to restriction of processing (art. 18)

DESCRIPTION: The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

HOW TO EXERCISE THE RIGHT:  By sending an email to Controller

RIGHT: Right to data portability (art. 20)

DESCRIPTION: The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

the processing is based on consent and the processing is carried out by automated means. In exercising his or her right to data portability, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible. The right referred shall not adversely affect the rights and freedoms of others

HOW TO EXERCISE THE RIGHT: By sending an email to Controller

Data Subject may also lodge a complaint with the Supervisory Authority in case of infringement of regulations concerning the protection of personal data.

For the exercise of the rights above and in case of further requests for information regarding the present privacy notice, the Data Subject can contact the Controller by sending an email to info@sincold.com, or by a registered letter to the following address: A.T.O. S.r.l., Castello di Godego (TV), via dell’Artigianato n. 24.

FURTHER OR NEW PROCESSING

Any further processing of personal data other than as indicated in this information notice will be communicated before the same treatment and by a previous consent collection, if it is included in the cases provided for by the legislation Applicable.

FUTURE INFORMATION NOTICE

This notice may be subject to changes that will be adequately communicated. In addition, if this notice is not sufficient for this purpose, additional information will be sent.

MINORS

A.T.O. Srl does not knowingly use its website to request data for persons under the age of 14.

COOKIES

This statement explains in detail how the site uses cookies and cookie type files and technologies in its websites, for example Local Shared Objects, also known as "Flash cookies", Web beacons, etc. We will generally refer to these as "cookies". If you visit our website and your browser settings accept cookies, the use of our cookies will be considered accepted.

Cookies are small files sent and stored on your computer by the websites you visit. Cookies are stored in the file directory of your browser. The next time you will visit the site, your browser will read the cookie and relay the information to the website or to the entity that originally created the cookie. To learn more about these technologies and about how they work, we invite you to visit, for example, the site www.allaboutcookies.org.

The session cookies used on this site avoid the use of other IT techniques that are potentially prejudicial to the privacy of users' browsing and do not allow the acquisition of personal identification data of the user.

The storage time of the data acquired depends on the types of cookies. Session cookies expire when the browser is closed. Persistent cookies, including Local Shared Objects "Flash cookies", have typical expiration dates ranging from two months to a couple of years.

How to unable cookies (opt-out)

Most internet browsers are initially set up to accept cookies automatically. This means that you have the possibility, at any time, to set your browser to accept all cookies, only some, or to refuse them, disabling their use by the websites. Furthermore, you can normally set your browser preferences in order to be notified whenever a cookie is stored on your computer. Finally, at the end of each browsing session, you can delete the cookies collected from the hard drive of your device. If you want to delete the cookies installed in the cookie folder of your browser, remember that each browser has different procedures to manage this setting.

You can find further information on how to manage cookies in your browser at the following addresses:

Google Chrome (https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies)

Mozilla Firefox (https://support.mozilla.org/it/kb/Activate and deactivate cookies)

Apple Safari (https://support.apple.com/kb/PH19214?viewlocale=it_IT&locale=en_US)

Microsoft Windows Explorer (http://windows.microsoft.com/en-it/windows-‐vista/block-‐or-‐allow-‐cookies)

Lastly, in order not to receive Google Analytics cookies, you can visit the page:

https://tools.google.com/dlpage/gaoptout/

Alternatively, only Google Analytics cookies can be disabled, using the opt-out add-on provided by Google for the main browsers.

If you want to learn more about cookies in general, visit www.allaboutcookies.org or www.garanteprivacy / cookies.

Services and cookies provided by Third Party

In the case of services provided by third party, you can also exercise your right to oppose the tracking by informing yourself through the privacy policy of the third party, via the opt-out link if explicitly provided or by contacting the third party directly.

Notwithstanding what it has been stated above, the Owner informs that you can have recourse to Your Online Choices (http://www.youronlinechoices.com/). You can manage the tracking preferences of most advertising tools through this service. The Owner, therefore, advises to use this resource in addition to the information provided in this document.

Since the installation of Cookies and other tracking systems operated by third party through the services used in this Website cannot be technically controlled by the Owner, any specific reference to Cookies and tracking systems installed by third party has to be considered indicative. For complete information, see the privacy policy of any third-party services. Given the objective complexity linked to the identification of technologies based on Cookies and their very close integration with the functioning of the web, you are invited to contact the Owner if you wish to receive any further information on the use of the Cookies and any use of them; i.e. by a third party - made through this site.

Use of Google Analytics

Using Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, Kalifornien, 94043 USA, (hereinafter "Google"). Google Analytics uses so-called "cookies", text files that are stored on your computer to help analyze how you use the website. The information on the use of the website (including your IP address) obtained through cookies will be sent and stored on a Google server in the United States. Google will use this information for the purpose of analyzing your use of the website, compiling reports for the Owner on the website traffic and offering additional services related to the use of Internet and of the website. Google may also transmit this information to third parties where required by law or where such third parties process the information on Google's behalf. Under no circumstances will Google associate your IP address with other data held by Google. You can avoid the installation of cookies by changing the settings of your browser, however, we point out that this may prevent from using all the features of this website. By using this website, you consent to the processing of your data by Google in the ways and for the purposes set out above. You can revoke your consent to the future collection and storage of the widersprochen data at any time. With reference with this purpose our contacts are listed in the colophon. In alternative, you can use the Google Analytics deactivation add-on (http://tools.google.com/dlpage/gaoptout?hl=de), if available for your browser.

Please note that this website uses Google Analytic with the extension "_anonymizeIp ()" and therefore a short version of the IP addresses is used in order to avoid direct personal identification.

To consult the privacy policy of Google company, relating to the Google Analytics service, please visit the website http://www.google.com/intl/en/analytics/privacyoverview.html.

To learn more about Google's privacy policies, we invite you to visit the website http://www.google.com/intl/it/privacy/privacy-policy.html.

By using our website, you consent to the processing of your data by Google in the ways and for the purposes indicated above.

Best Regards,

A.T.O. S.r.l.