Privacy Policy Statement
(Articles 13 and 14 of EUROPEAN REGULATION NO. 679/2016)
Dear Guest/Visitor/Client,
4C INNOVATION srl, with registered office in Via di Montramito km 1722, postal code 55054 Massarosa, (LU) – Italy, Tax and VAT Number IT02400360463, as the “Data Controller”, informs you according to Articles 13 and 14 of European Regulation no. 679/2016 (hereinafter “EU Regulation”) that your data shall be processed according to the following policy:
1. Type of Data Processed
Type of Data Processed The Data Controller informs you that your personal data and personally identifiable information (e.g. name, surname, company name, address, telephone number, e-mail address, bank and/or payment information, etc.), hereinafter referred to as “Personal Data” or just “Data”, which have been or will be collected, including verbally collected, by us or by a third party, may be processed in full compliance with the EU Regulation. The Data Controller processes the Data in a lawful manner, in particular with the purpose of performing the contract you may sign or of performing other contract-related activities (e.g. preparing an offer, etc.) that you may request (Art. 6 of the EU Regulation).
Data processing means any activity or series of activities for collecting, storing, organizing, saving, consulting, processing, editing, selecting, extracting, comparing, using, linking, blocking, communicating, disclosing, or distributing data.
2. Legal Basis and Purpose of the Processing
Legal Basis and Purpose of the Processing Legal basis: EU Regulation no. 679/2016
A) Purpose of the processing without your express consent (Art. 6, Points b), c), e) of the EU Regulation):
– to fulfil contract-related and tax obligations arising from contracts you may sign
– to fulfil obligations required by the law, a regulation or an EU regulation, or to fulfil orders from Public Authorities (e.g. in the context of anti-money laundering)
– for the Data Controller to exercise its rights, e.g. the right to defend in court
– for general bookkeeping
– for management purposes (invoicing, any document management, etc.)
– for credit management
– for statistical analyses and quality control
– for assurance management
– for technical support In particular, your Data shall be processed to fulfil the following contractual and legislative obligations:
– user and technical access to the site: no data is stored after the browser is closed
– advanced navigation features or customized management of the content
– for statistical purposes and for analysing users and site navigation
B) Sales, marketing and/or profiling purposes, only with your express consent (Art. 7 of the EU Regulation):
– to send you newsletters, sales messages and/or marketing material about products and services offered by the Data Controller via e-mail, mail, text messages and/or telephone, or for satisfaction surveys relating to the quality of your experience with the service received
– to send you third-party (e.g. from a business partner) sales and/or marketing messages via e-mail, mail, text messages and/or telephone
3. Processing Methods
The methods used for processing your Personal Data, which are listed in Article 4, Point 2) of the EU Regulation, are as follows: collection, storage, organization, structuring, saving, adaptation or modification, extraction, consulting, use, communication (i.e. transmission, disclosure or any other way of making data available), comparing or linking, limitation, deletion or destruction, blocking. Your Personal Data are processed on paper and by electronic and/or automatic means (in such way as to guarantee data security and confidentiality).
4. Data Storage Times and other Information
The Data Controller shall process your Personal Data for the period of time necessary for the abovementioned purposes and in no case longer than the period of time permitted by law after the termination of your contract/relationship with the Data Controller. More precisely:
- Personal Data related to contracts, invoices, tax and accounting records shall be retained for 10 years as required by Italian law.
- Navigation data (technical cookies) are erased upon session end or shortly thereafter.
- Marketing Data shall be stored for a maximum of 24 months from the last interaction with the Data Controller.
- Profiling Data shall be stored for a maximum of 12 months. The Personal Data you communicate to the Data Collector shall be processed in a “lawful way according to the principles of fairness and transparency”, while at the same time protecting your privacy and your rights.
5. Access to the Data
Your Data can be accessed for the purposes mentioned at the above points 2.A) and 2.B):
– by shareholders, employees and personnel of the Data Controller in Italy and abroad as agents and/or employees in charge of the processing and/or as system administrators
– by third-party companies or other parties that carry out outsourced activities on behalf of the Data Controller as third-party persons in charge of the processing (e.g.: associate offices, lawyers, data processing companies, certification authorities, bookkeeping/tax consultants, assurance companies, IT providers, market researchers, etc.) The full list of all those who have or can have access to your Data is available at our registered office.
6. Communication of the Data
Communication of the Data Without your express consent (Article 6, Points b) and c) of the EU Regulation), the Data Controller may communicate your Data for the purposes mentioned at the above point 2.A) to Supervisory Bodies, Judicial Authorities, assurance companies for the provision of assurance services, and other parties to which the law prescribes that the Data must be communicated. During and after your visit to the website, your Data may be communicated to third parties, in particular to:
– Google services (Google Ads, Google AdWords, Google Analytics): for advertising, analytics, content personalization and optimization.
These third parties may operate in countries outside the European Economic Area, including the United States. Transfers to such countries will only occur in accordance with Articles 44 et seq. of the GDPR, based on adequacy decisions (e.g. EU-U.S. Data Privacy Framework) or using standard contractual clauses approved by the European Commission.
Your Data shall not be disseminated.
7. Transfer of the Data
Transfer of the Data Your Personal Data are stored on devices located within the European Union. If necessary, the Data Controller may transfer your Data to countries outside the EU.
In such cases, all appropriate safeguards required under GDPR will be adopted, such as adequacy decisions, binding corporate rules, or standard contractual clauses. Navigation: your navigation Data may also be transferred, only for the abovementioned purposes, to the following countries:
– EU countries;
– the United States of America.
8. Cookie Management
This website uses cookies to enhance your browsing experience, to provide personalized content and ads, and to analyze traffic. Some cookies are essential and are used for technical purposes, while others are optional and used only with your consent. You may manage your preferences at any time through the cookie banner displayed upon first access, or via your browser settings. Detailed information on cookies used by this site, including types, purposes, duration, and third-party recipients, is available in the Cookie Policy.
9. How You Communicate Your Data and What Happens if You Do Not Communicate Your Data
You have to communicate your Data for the purposes mentioned in the above point 2.A). If you refuse to do so, we may not be able to provide you with the services mentioned in the above point 2.A).
You are not required to communicate your Data for the purposes mentioned in the above point 2.B), but you may do so if you wish. You are free not to communicate any Data or you may revoke your consent to its processing at a later time: in this case, you will not receive any newsletters, sales communication and marketing material and/or any other services provided by the Data Controller. You will still be able to receive the services mentioned in the above point 2.A).
10. Your Rights
As the owner of your Data, you have the rights provided for by Articles 15 to 22 of the EU Regulation, including:
– the right to access your Personal Data
– the right to rectify, erase or limit processing
– the right to data portability
– the right to object to processing
– the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal
– the right to lodge a complaint with a supervisory authority
11. How to Exercise Your Rights
You can exercise your rights at any time by sending:
– a registered letter with return receipt to the Data Controller (address indicated above)
– an email at the address info@4cinnovation.it
12. Minors
The provision of any products and services by the Data Controller does not include the intentional collection of Personal Data of minors. In the case where any Personal Data of minors are unintentionally stored, the Data Controller shall immediately delete them upon request.
13. Personal Data Not Collected from You
In some cases, the Data Controller is not the initial collector of your Data, but rather a joint or third-party data controller that received your Data under contractual arrangements.
In such cases, the Data Controller undertakes to verify that you have been properly informed and that consent, where necessary, has been duly obtained.
14. Registered Users and Reserved Area
If you choose to register an account on the website, your Data shall be processed for the purpose of creating and managing your user profile. This includes: – collection and storage of identification data (e.g. name, surname, email address, username, password); – allowing access to the reserved area and enabling the download of documentation and other restricted content; – maintaining a log of activities linked to your account (e.g. access times, downloads made); – providing support and responding to queries related to your registration or the use of your account.
The legal basis for processing these Data is the performance of the contract (Art. 6(1)(b) GDPR) and, where applicable, your consent (Art. 6(1)(a) GDPR).
User credentials are encrypted and securely stored. Logs are kept for a limited time for technical and security purposes and are periodically deleted in accordance with the principle of data minimization.
15. Data Controller, Data Supervisor and Persons in Charge of the Processing Data Controller.
The Data Controller is 4C INNOVATION srl, with registered office in Via di Montramito km 1722, postal code 55054 Massarosa, (LU) – Italy, Tax and VAT Number IT02400360463. You may contact the Data Controller at info@4cinnovation.it Data Supervisor. The Data Controller has appointed Mrs Cantalupi Azzurra as Data Supervisor. She can be contacted at a.cantalupi@cantalupi.it Persons in Charge of the Processing. The updated list of all persons in charge of the processing is available at the registered office of the Data Controller.
4C INNOVATION S.R.L.
