DATA PROTECTION POLICY
In accordance to the Italian Legislative Decree June 30, 2003 No. 196
1. Introduction and purpose
1.1 This Data Protection Policy (hereinafter, the “Data Protection Policy”) exclusively refers to www.bakel.it and e-shop.bakel.it sites (hereinafter, collectively, the “Sites”) and describes the personal data processing activities carried out by Bakel S.r.l. (hereinafter, “Bakel”), acting as owner and manager of the Sites, whenever a visitor and/or user of any of the Sites (hereinafter, the “Data Subject”) visits any of such Sites and/or uses any of the services and/or actions available therein (hereinafter, the “Services”).
1.2 The Data Protection Policy is also an information given to the Data Subject in accordance with Article 13 of Italian Legislative Decree June 30, 2003 No. 196 (hereinafter, the “Privacy Code”), about the collection and processing of personal data carried out by Bakel also through the use of the Sites.
2 Terms and duration of data processing
2.1 Bakel will process the personal data provided by the Data Subject in full compliance with the Privacy Code and, in particular, with the principles of correctness, lawfulness, transparency and data protection.
2.2 Personal data will be processed - manually and/or with electronic devices - strictly for the time necessary to achieve the purpose for which such personal data are gathered and, anyhow, in full compliance with the provisions contained in the Privacy Code.
3 Surfing data and cookies. Data provided freely by Data Subject
While surfing the Sites - given the dynamic nature thereof - different types of personal data, relating to the Data Subject, may be obtained:
3.2 personal data freely provided by Data Subject: Data Subject may freely choose to use the Services. In such case, before starting or using a particular Service, or before submitting a specific request - subject to information provided (“Informativa”, as such term is defined in the Privacy Code) and, if necessary, subject to given consent - Data Subject provides Bakel with its personal data necessary to use the required Services. Such personal data may be different depending on the form used from time to time.
4 Purpose of processing
Personal data freely provided by Data Subject will be used for the following purposes:
4.1 for offering and providing Services freely chosen by the Data Subject, as well as for fulfilling obligations or providing supplies related, linked and/or complementary thereto;
4.2 subject to prior consent, for sending any requested Newsletter and inserting the Data Subject in the mailing list concerning marketing and/or promotional information related to the business activity carried out by Bakel; and
4.3 subject to prior consent, for marketing purposes, including - without limitation - sending advertising material, concluding direct sales, providing business communication, carrying out market surveys, customer satisfaction surveys and/or statistical analysis with data in aggregate form. Such personal data use can take place both through traditional methods, such as sending postal mail, or through electronic automatic systems according to Article 130, paragraphs 1 and 2, of the Privacy Code, such as sending e-mail (even periodically in the form of newsletter), MMS (Multimedia Messaging Service) or SMS (Short Message Service) or otherwise.
4.4 For updating purposes, personal data provided may be crosschecked with other data - lawfully held by Bakel - provided by the Data Subject through electronic systems other than Sites or through paper forms.
4.5 By exercising the right provided for under Article 7, Data Subject who has given his consent for the purposes referred to in Article 4.2 above, may at any time withdraw such given consent interrupting therefore the receipt via e-mail of promotional and marketing materials and information.
4.6 By exercising the right provided for under Article 7, Data Subject who has given his consent for the purposes referred to in Article 4.3 above may at any time withdraw such given consent interrupting therefore the receipt of promotional and/or commercial materials and information. Any opposition to the use of automated contact way will also be automatically extended to any no automated contact way, provided however that the Data Subject may decide to exercise its right only in part or in full.
5 Data conferring
5.1 Data Subject may freely confer its personal data. However, failure to provide personal data qualified as “mandatory” in specific form will make it impossible for the Data Subject to use the Services that require personal data processing. Otherwise, failure to provide data qualified as “optional” will allow Data Subject to use such Services.
5.2 Conferring data for receiving the Service as referred to in Article 4.2 above, it is necessary for Bakel in order to send specific information, which may also contain commercial and promotional material. Failure to provide such personal data will prevent Bakel to provide such Service.
5.3 Conferring data for receiving the Service as referred to in Article 4.3 above, shall always be free and optional for the Data Subject. Conferring no data for receiving the Service as referred to in Article 4.3 above shall have no consequence on using the Services offered by the Sites. However, in such case Bakel shall have no possibility to contact the Data Subject for marketing activity purposes.
6 Data communication and data dissemination
6.1 Personal data may be solely processed by persons appointed by Bakel - in accordance with the Privacy Code - as data processors (“Responsabile del Trattamento”, as such term is defined in the Privacy Code) and persons in charge to data processing (“Incaricato al Trattamento”, as such term is defined in the Privacy Code) within its company structure.
6.2 Personal data may also be processed by other third parties working on behalf of Bakel under specific contractual obligations and, in any case, appointed as external data processors or external persons in charge to data processing, as well as their appointee.
6.3 Personal data may be transferred outside the Italian territory, both in countries belonging to the European Union, and in other Countries outside the European Union. However, personal data transfer will take place in full compliance with the Privacy Code.
6.4 In any case, personal data may be disclosed to third parties to comply with legal requirements or to comply with orders received from public authorities, or to exercise a specific right in any competent court.
6.5 Under no circumstances, personal data will be transferred or passed on to third parties, nor will they be disseminated.
7 Data Subject rights
In accordance with Article 7 of the Privacy Code, the Data Subject has the right to:
7.1 become aware of any personal data concerning him, even if not yet recorded, and obtain their communication in intelligible form;
7.2 become aware of: (a) the origin of his personal data; (b) the purposes and methods of processing thereof; (c) the reasons concerning the application of electronic instruments data processing; (d) the identity of the data controller, data processors and the representative designated pursuant to Article 5, paragraph 2, of the Privacy Code; and (e) recipient to whom personal data may be communicated or persons who may become aware of personal data as designated representative in the territory of the State, data processors or persons in charge to data processing;
7.3 obtain: (a) the update, amendment or correction or, when there is a Data Subject’s interest, integration of his personal data; (b) the removal, transformation into anonymous form or blocking of personal data unlawfully processed, including personal data whose retention is unnecessary for the purposes for which such personal data were collected or subsequently processed; and (c) a declaration that the operations referred to in points (a) and (b) above have been notified, as also related to their contents, to those persons to whom the personal data were communicated or disseminated, unless this request appears reasonably impossible, or will need actions, that are evidently not proportionate to the protected right; and
7.4 oppose, in whole or in part: (a) for legitimate reasons, to the processing of personal data concerning him, even if pertinent to the purpose of collection; and (b) to the processing of personal data concerning him for the purpose of sending advertising materials or direct sales, or for carrying out market research or sending of commercial communications.
7.5 To exercise their rights, Data Subject can contact Bakel, writing an e-mail to the following address email@example.com and directing such notice to the attention of the Data Controller of personal data.
8 Data controller
The data controller of personal data (“Titolare del Trattamento”, as such term is defined in the Privacy Code) is Bakel S.r.l., with registered office at Viale Ledra n. 56 - 33100 Udine (UD) - Italy. Data Subject may request to Bakel an updated list of data processors (“Responsabile del Trattamento”, as such term is defined in the Privacy Code) and persons in charge to data processing (“Incaricato al Trattamento”, as such term is defined in the Privacy Code), writing an e-mail to the following address firstname.lastname@example.org and directing such notice to the attention of the Data Controller of personal data.
9 Updates and changes
This Data Protection Policy may from time to time be subject to changes and updates, which will be both communicated by specific amendment on the Sites. The Data Protection Policy version currently in force is the one published on the Sites. Please check, from time to time, the Data Protection Policy in order to be properly informed and be certain to share and accept any changes thereto.