Privacy Policy

Information Notice pursuant to Art. 13 of the Regulation (EU) 2016/679 (“GDPR”) – GDPR – Information for the processing of personal data collected from the Data Subject.

 

In compliance with the General Data Protection Regulation (EU) 2016/679 we would like to kindly provide you with the necessary information regarding the processing of personal data supplied by you. This information notice shall not be considered valid for other websites that may be consulted through links on the domain owner’s Internet sites, which is not to be considered in any way responsible for third party websites.

 

DATA CONTROLLER

pursuant to articles 4 and 24 of GDPR, is De Padova Srl with registered address at Via Santa Cecilia 7, Milan, in person of its legal representative De Padova Luca Diomede. E-mail contact: privacy@depadova.it

As far as the purposes od marketing activities (B), profiling (C) and transfert of data (D) are concerned, DATA CONTROLLER, pursuant to articles 4 and 24 of GDPR, is Boffi spa with registered address at Via Oberdan,70 – 20823 Lentate sul Seveso (MB), in person of its legal representative. E-mail contact: privacy@boffi.com.

 

DATA PROTECTION OFFICER

is individualized BY Boffi Spa pursuant to art. 37 and art. 39 of the Regulation (EU) 2016/679. Contact e-mail: dpo.boffi@dpoprofessionalservice.it

 

PURPOSES AND LEGAL BASIS OF THE PROCESSING

The personal data provided will be processed, in compliance with the conditions of lawfulness pursuant to art.6 of Reg.UE 2016/679, for the purposes indicated here below:

A)

I. browsing the web site;

II. access to the restricted area by dealers and agents;

III. filling out the form for sending a spontaneous application for the selection of personnel;

B) Direct Marketing: throught completion and filling out of forms for the receipt of communication material, for direct marketing activities, newsletters, market researches or other sample searches, and sale via automated electronic mail, paper mail and telephone calls, material information on products from BOFFI, DE PADOVA, and MA/U Studio,or inherent events and initiatives by the Data controller, even through the companies appointed as Data Processors (De Padova Srl, single shareholder company, Boffi Trade srl MA/U Studio srl, Boffi Barberini srl). The data will be entered in the company CRM.
To compare and possibly improve the results of communications, Data Controller uses systems for sending newsletters and promotional communications with reports. Thanks to the reports, the Data Controller will be able to know, for example: the number of readers, openings, unique “clickers” and clicks; the devices and operating systems used to read the communication; the detail on the activity of individual users; the details of the emails sent, e-mails delivered or not, of those forwarded. All these data are used for the purpose of comparing, and possibly improving, the results of communications.

C) Profiling (non automated) with reference to preferences, personal interests, purchase habits, etc. in order to send commercial proposals of interest to the user.

D) marketing of third party, with transfert of data, for commercial and promotional communication, newsletter, market research, sample research measurement of satisfaction or communications, connected to events and initiatives promoted by partner Adielle Srl via Preazzi, 79 -36010 Zanè (VI) Italy.

 

LEGAL BASIS

Legal basis for the processing of data for the purpose A. I) is the legitimate interest art.6, par.1, lett.f): (recital 47) taking into consideration the reasonable expectations of Data Subjects at the time and in the context of the processing of personal data, when the Data Subject can reasonably expect their data to be processed for this purpose. Legal basis for the processing of data for the purpose A.II) is contract (art.6 par.1 lett. b). Legal basis for the processing of data for the purpose A.III is contract/ pre-contract (art.6 par.1 lett. b).
Legal basis for the processing of data for the purpose B) direct marketing and C) profiling (non automated) is the consent (art.6 par.1 lett.a). Legal basis for the processing of data for the purpose D) transfer of data is the consent (art.6 par.1 lett.a).

 

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA

Your processed data will be communicated to recipients, that will process the data as Data Processor (art. 28 del Reg. UE 2016/679) and/or as acting under the authority of the Data Controller and of Data Processor (art. 29 del Reg. UE 2016/679), or subjects having the role of Data Controllers, for the purposes indicated in point 3.
Precisely, data will be communicated to:subjects that provide services for the management of the information system used by De Padova Srl and the telecommunications networks (including e-mail and platforms);

– studies or companies in the context of assistance and consultancy relationships

– companies contractually linked to De Padova Srl and/or part of the to the sales/distribution network of Boffi Spa (such as branches, importers, distributors, forwarders, etc);

– competent authorities for fulfilling legal obligations and/or provisions of public bodies, upon request;

– to the sales/distribution network in the territory. The updated list of designated Data Processors is available at De Padova Srl and Boffi Spa – Boffi Spa for the processing for which is Data Controller.

 

DATA TRANSFER TO A THIRD COUNTRY AND/OR INTERNATIONAL ORGANISATION
Personal data will not transfer outside the European Union by De Padova Srl.
Personal data would by transfer outside the European Union by Boffi. Data will be transferred according to Articles 44 e 45 of Reg.UE 2016/679.
To receive information concerning the guarantees concerning the transfer of Data outside UE you can send an email to privacy@boffi.com

 

DATA RETENTION PERIOD OR RELEVANT CRITERIA

The processing will be carried out in automated and / or manual manner, with methods and tools aimed at ensuring the best security and confidentiality, by subjects specifically appointed to do so. In compliance with art. 5, paragraph 1 letter e) of EU Reg. 2016/679, the personal data collected will be stored in a form that allows identification of data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The retention of personal data provided depends on the purpose of the processing:
– for the purpose A.I see the following Cookie policy;
– for the purpose A.II as long as there is a contractual relationship between the parties;
– for purpose A.III retention for the spontaneous application for the selection of personnel is of 24 months;
– for the purpose B) the retention period is until the excercise of the right of withdrawal; – for the purpose C) the retention period is 12 months; – for the purpose D) the data will be processed until your objection contacting the partner Adielle Srl, via Prealpi, 79 – 36010 Zanè (VI) as autonomous Data Controller for this purpose.

 

DATA SUBJECT’S RIGHTS
You can exercise your rights as expressed in the GDPR by sending an e-mail to Data Controller at privacy@depadova.it for the purposes per which De Padova Srl is Data Controller. For the purposes for which Boffi Spa is Data Controller, (marketing, profiling and trasfert of data to Adielle Srl), you can send an e-mail to privacy@boffi.com o contact the Data Protection Officer at dpo.boffi@dpoprofessionalservice.it. In particular you can, at any time, ask the Data Controller to access your personal data (art.15), to rectify it (art.16), to erase it (art.17), to restrict the processing (art.18) or to object to processing of your personal data (art.21). Moreover you can ask for data portability (art.20). In any case the processing is based on consent, you can withdraw the consent at any time without prejudice to the lawfulness of the processing based on consent before withdrawal. You can object to the processing. In order not to receive commercial and promotional communications through automated means (e-mail), you can write an e-mail at any time at the following address privacy@boffi.com with the subject “automated unsubscription” or use our system for automatic unsubscription and you will no longer be disturbed. In order not to receive commercial and promotional communications through traditional direct marketing communications (telephone calls, paper mail), you can write an e-mail at any time at the following address privacy@boffi.com with the subject “traditional direct marketing unsubscription”. You have the right to object at any time to processing of personal data concerning profiling, with an e-mail at the following address privacy@boffi.com with the subject “no profiling”. Without prejudice to any other administrative and judicial appeal, if you believe that the processing of your data violates the provisions of Regulation EU 2016/679, pursuant to art. 15 letter f) of the aforementioned Regulation EU 2016/679, you have the right to lodge a complaint with the Data Protection Authority -(https://www.garanteprivacy.it/). There is no an automated individual decision-making.

 

NATURE OF DATA PROVISION AND REFUSAL

Provision of the data for the purposes indicated in points A.I, A.II and A.III are necessary. Any refusal to provide the necessary data shall make it impossible to use the services of the Data Controller, and, as far as puposes A.III is concerning, the refusal shall make it impossible to let Data Controller proceed with the evaluation of the curriculum vitae. The provision of the data for the purposes B) and/or C) and/or D) is optional. The refusal of the consent for the purpose express in point B), will not be a prejudice for the processing of personal data for the purposes indicated in point A) and C). Any refusal of the consent for the purpose indicated in point C) will not be a prejudice for the purposes indicated in point A) and B). Marketing activity is only possible and will be carried out only with the specific consent of the interested party. The inclusion of data in the CRM is optional and will automatically result in the visibility of the same by those who have access, i.e. the data processors and any person acting under the authority of the Data Controller, that works at point of sales in the world. Any refusal to provide the consent for the purposes indicated in point D), will not be a prejudice concerning the purposes indicated in point A), B) and C).

 

CHANGES TO PRIVACY POLICY STATEMENT

The Data Controller reserves the right to modify, update, add or remove parts of the privacy policy statement at the discretion of the same at any time. The Data Subject shall periodically verify these possible changes. In order to let Data Subject understand the modification, the informative notice shall contain the upgrade date. The use of the site, after the pubblication of the modification, shall constitute acceptance of these changes.

Upgrade date: 10th of March 2020