Asolo S.r.l. based in Via delle industrie no. 2, 31040 Nervesa della Battaglia (TV) (hereinafter “ASOLO”), as the Controller of personal data pursuant to applicable Italian law on the protection of personal data (the "National Law") and the EU Regulation 679/2016 - General Regulation on Data Protection ("RGPD") (hereinafter the National Law and the RGPD are collectively referred to as "Applicable Law"), recognizes the importance of protecting personal data and considers its protection one of the main objectives of its business. Before disclosing any personal data, ASOLO would like you to carefully read this Privacy Policy, as it contains important information on the protection of personal data and the security measures taken to ensure its confidentiality in full compliance with the Applicable Law.

This Privacy Policy, moreover, is intended only for the website www.asolo.com ("Site") while it does not apply to other websites that may be consulted through external links; it is to be understood as information provided pursuant to Article 13 of the Applicable Law to those who interact with the Site. ASOLO informs you that the processing of your personal data will be based on the principles of lawfulness, correctness, transparency, restriction of purposes and retention, data minimization, accuracy, integrity and confidentiality. Your personal data will therefore be processed in accordance with the legal provisions of the Applicable Law and the confidentiality obligations set out therein.

1. CONTROLLER

With reference to the Applicable Law we inform you that the Data Controller is ASOLO, whose data is reported on the website on the Home Page and/or on other web pages therein.

2. PERSONAL DATA TO BE PROCESSED

The types of personal data collected from the Site are the following: 

a. Navigation data: the Site's computer systems collect certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with you, but by its very nature could, through processing and the association with data retained by third parties, allow us to identify you. This includes the IP addresses or domain names of the devices used to connect to the Site, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit 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 (successful, error, etc.) and other parameters relating to your operating system and IT environment. This data is used in order to obtain anonymous statistical information on the use of the Site and to check its correct functioning; to allow - given the architecture of the systems used - the correct provision of the various functions you requested, for security reasons, and to ascertain liability in the event of hypothetical cyber-crimes against the Site or third parties and is deleted after 7 days; this data is retained by the Site Controller in any case, for the period strictly necessary and in compliance with the relevant regulations in force. 

b. Data provided voluntarily: through the Site you have the possibility to voluntarily provide Personal Data such as your name and e-mail address, to subscribe to the newsletter service, to contact ASOLO through the "Contact us" form, to manage orders on the e-commerce platform, shipping, data acquired from answers to questionnaires for participation in the survey, marketing etc. or other similar services. Users are free to provide their personal data but failure to do so may make it impossible to obtain the service requested. ASOLO shall process this data in compliance with the Applicable Law, assuming that it refers to you or to third parties who have expressly authorized you to provide it based on an appropriate legal basis that legitimizes the processing of the data in question. With respect to the latter hypothesis, you are acting as an independent Data Controller, assuming all legal obligations and responsibilities. To this effect, you are hereby granting full indemnity with respect to any dispute, claim, request for compensation for damage from processing, etc., that ASOLO may receive from third parties whose Personal Data has been processed through your use of the Site in violation of the Applicable Law. 

c. Cookies and similar technologies: ASOLO collects Personal Data through cookies. More information on the use of cookies and similar technologies can be found here.

3. PURPOSE, LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF PROCESSING

The Personal Data you provide through the Site will be processed by ASOLO for the following purposes: 

Data may be processed by paper, automated or electronic means and, in particular, by post or e-mail, telephone (e.g. automated calls, SMS, MMS), fax and any other computer channel (e.g. websites, mobile apps).

a) purposes strictly connected to the execution of the contract, instrumental to managing the relationship with the customer and connected to the fulfilment of legal obligations (e.g. in accounting, fiscal and tax matters) by the company that acts as the Data Controller;

b) purposes strictly connected to managing the relationship with the customer. In particular, the processing of the Data will be carried out as an independent Controller for: the fulfilment of the obligations regarding the services you requested; the performance of internal audits at the Company; the management of customer service; the carrying out of surveys aimed at improving the quality of the services provided;

c) with the customer's prior consent: to allow the Company or third party companies to send commercial and/or promotional communications about their products and services, as well as to carry out market research ("Marketing").

d) purposes needed to ascertain, exercise or defend a right in court or whenever the courts exercise their judicial functions.

e) purposes of statistical research/analysis on aggregate or anonymous data, without the possibility of identifying the user that is aimed at measuring the functioning of the Site, its traffic and assessing usability and interest.

Data processing for each of the above purposes shall be carried out by paper, automated or electronic means and, in particular, by post or e-mail, telephone (e.g. automated calls, SMS, MMS), fax and any other computer channel (e.g. websites, mobile apps). The provision of Data is optional. However, any refusal to provide the Data for the purposes under sub sections (a) and (b) of Part 1) above, the processing of which does not require the customer's consent, will make it impossible to perform the services and obligations under the contract. The refusal to process data for the purposes under sub section (c), shall in no way affect the contractual relationship with the Company and the consequent activities connected or dependent on it. The purpose referred to under sub section (d) represents the legitimate processing of Personal Data pursuant to the Applicable Law since, once the Personal Data has been provided, its processing is indeed necessary to fulfil a legal obligation to which ASOLO is subject. The purpose under sub-section e) does not involve any processing of Personal Data.

4. RECIPIENTS

Your Personal Data may be shared for the purposes specified in point 3, with: a. persons required to provide the services offered by the Site, including, for example, the company responsible for managing order payments, sending e-mails and analyzing the functioning of the Site, who typically act as ASOLO Data Processors; b. persons authoriZed by ASOLO to perform personal data processing who are committed to confidentiality or have an appropriate legal obligation of confidentiality; (e.g., persons authorized by ASOLO); (a. and b. are collectively “Recipients”); c. third parties (companies, freelance professionals, etc. ...) operating both inside and outside the European Union and Authorities (e.g. judicial, administrative, etc. ...), acting as: 1) Data Controllers, being parties that determine the purposes and means of personal data processing; 2) Data Processors, being parties that process personal data on behalf of the Controller. 

5. TRANSFERS

Some of your Personal Data is transferred to Recipients that may be found outside the European Economic Area. ASOLO ensures that the electronic and paper processing of your Personal data by Recipients is carried out in accordance with Applicable Law. Indeed, transfers are alternatively based on an adequacy decision or on Standard Model Clauses approved by the European Commission.

6. DATA RETENTION

ASOLO shall process your Personal Data for the time strictly necessary to achieve the purposes indicated in point 3. For example, ASOLO shall process your Personal Data for the newsletter service until you decide to unsubscribe from it. Without prejudice to the above, ASOLO shall process your Personal Data until the time allowed by Italian law to protect its interests (Articles 2946 and 2947(1)(3) of the Italian Civil Code). 

7. YOUR RIGHTS

As a data subject, you may exercise the rights provided for in the Regulations listed below at any time against the Controller by sending a written request to [email protected]

You may revoke the consent expressed in this Policy at any time in the same way.
 

Any communications and actions taken by the Company concerning the exercise of the rights listed below will be made free of charge. However, if your requests are clearly unfounded or excessive, in particular due to their repetitive nature, the Company may charge you a fee, taking into account the administrative costs incurred, or refuse to meet your requests.

The customer is entitled to the following rights:

1. right of access, being the right to obtain confirmation from the Controllers whether or not the Data is being processed and, if so, to obtain access to it;

2. right to rectification and deletion, being the right to obtain the rectification of inaccurate Data and/or the integration of incomplete Data or the deletion of Data for legitimate reasons;

3.right to the restriction of processing, being the right to request the suspension of processing if there are legitimate reasons;

4. right to data portability, being the right to receive the Data in a structured, commonly used and readable format, as well as the right to transmit the Data to another Data Controller;

5. right to object, being the right to object to the processing of the Data if there are legitimate reasons, including data processing for marketing and profiling purposes, if any;

6. right to contact the competent Data Protection Authority in case of unlawful processing of the Data.

8. MODIFICATIONS

This Privacy Policy is effective from 25 May 2018. ASOLO reserves the right to partly or completely modify or simply update its contents, even due to changes in the Applicable Law. ASOLO will inform you of such changes as soon as they are introduced, which will be binding as soon as they are published on the Site. ASOLO therefore would like you to visit this section regularly to read the most recent and updated version of the Privacy Policy so that you are always up to date on the data collected and the use made of it by ASOLO.

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