This policy statement describes how the personal data of users and visitors of this website is processed and managed. This statement – in pursuance of Section 13 of Legislative Decree 196/2003 (Personal Data Protection Code) – is provided to those who interact with the services of ACM S.r.l., which can be accessed electronically through the web address
This statement applies exclusively to the aforementioned website and does not concern any other websites the user might access via links.
The following indications are based on the guidelines offered by the European Data Protection Authorities in order to lay down minimum requirements for the online collection of personal data, with special regard to the arrangements, timing and nature of the information to be provided by data controllers to users browsing web pages for whatever purpose.
1. DATA CONTROLLER
Browsing the website of ACM S.r.l. may entail the processing of data concerning identified or identifiable persons; logging in to the website and requesting online services will equally result in the processing of personal data, as specified below in the paragraph “Categories of Processed Data”.
The Data controller is ACM S.r.l., with offices in Bareggio (MI) Italy, Zip code 20010, Via XXV Aprile, 62 – VAT IT08188690153.
2. PLACE WHERE DATA IS PROCESSED
The processing operations related to the services provided by this website are carried out mainly at the premises of ACM S.r.l. exclusively by technical staff in charge of said processing. ACM S.r.l. may rely on third parties – such as external companies, advisors and software providers, to perform personal data processing support activities. Such third parties are designated as data processors and are under contractual obligation to comply with security and confidentiality measures for data handling and processing.
3. CATEGORIES OF PROCESSED DATA
3.1 Website navigation: Browsing data
The information systems and software procedures utilised to operate the website of ACM S.r.l. acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of internet communication protocols.
Such information is used to extract anonymous statistical information about the use of the website as well as to check on its functioning. It is not collected in order to relate it to identified data subjects; however, it might allow user identification per se after being processed and matched with data held by third parties. This data category includes, for example, IP addresses of computers employed to connect to the website.
This data is removed after statistics are elaborated, and it is stored offline in case it should be requested by judiciary authorities to establish liability in case of computer-related crimes.
3.2 Personal data voluntarily provided by the user for online services
Personal data freely provided by users to use online services requiring access credentials or submission of e-mails will be used as follows:
3.2.1 Website login and online services
Natural or legal persons can log in to the website to request specific online services (“Secure area”). Some personal data necessary to identify the registered user and to later access the website are requested when logging in.
3.2.2 Sending of e-mails to addresses indicated on the website
The optional, explicit and voluntary submission of e-mails to the addresses mentioned on this website entails the subsequent acquisition of the sender’s address – which is necessary for responses to requests – and of any other personal data contained in the message. ACM S.r.l. guarantees that personal data provided by users requesting information (first name, last name, e-mail address) will be used only for the purpose of providing the requested service. Failure to provide such data entails the impossibility to satisfy said requests.
3.2.3 Newsletter subscription and commercial services
Personal data provided by users can be utilized – only upon their explicit consent – for the provision of information and for marketing activities. Specific summary information notices and consent forms are available on the website pages dedicated to services on demand, with the purpose of calling the users’ attention to the processing of their personal data.
4. OPTIONAL DATA PROVISION
Users are free to provide their personal data either to log in to the website or to request online services, also if functional to the provision of said services: failure to provide such data may entail that the registration and subscription to such services cannot take place.
The provision of data for information and marketing purposes is optional and the user is free to give his consent to such processing: failing to provide such consent entails that ACM S.r.l. will be unable to inform the user about its commercial and promotional activities.
5. PROCESSING ARRANGEMENTS
Personal data is processed through automated means only for the time necessary to achieve the purposes for which it has been collected.
Specific security measures have been implemented to prevent unauthorised access to, loss of, or unlawful or improper use of data.
The collected data will neither be shared nor communicated to any other subjects for any other purpose than those related and required to provide the requested service.
6. UTILIZZO DEI COOKIE
7. DATA SUBJECTS’ RIGHTS
Data subjects are entitled at any time to obtain confirmation of the existence of personal data concerning them and to be informed of their contents and source, verify their accuracy, or else request that such data be supplemented, updated or rectified (Section 7 of Legislative Decree no. 196/2003).
As pursuant of the aforementioned Section, the data subject has the right to request the erasure, the anonymisation or blocking of any data that has been processed in breach of the law, and also to object – on legitimate grounds – to their processing. The text of the aforementioned Section is reproduced here for your convenience:
As pursuant of Section 7 of Legislative Decree no. 196/2003 the data subject shall have:
- The right to be informed of :
- the source of the personal data;
- The right to be informed of the purpose and method of processing;
- The right to be informed of the logic applied in case data is processed with the aid of electronic means;
- The right to be informed of the identification of the Data controller, of the persons in charge of the processing, of the subjects or categories of subjects that may access such data;
- The right to immediately obtain the updating:
- the supplementing, the erasure, the anonymisation or blocking of any data that has been processed in breach of the law, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
- the right to immediately obtain certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves to be impossible or involves a manifestly disproportionate effort compared to the right that is to be protected.
- The right to fully or partially object:
- on legitimate grounds, to the processing of his personal data, albeit relevant to the purpose of the collection, and to the processing of his personal data for the purposes of sending advertising material, or of performing direct sales, marketing research, or promotional communication.
- The right to be informed of :
All requests must be sento to the address of the data controller: ACM S.R.L. – Italy – CAP 20010 – Bareggio (MI) – Via XXV Aprile, 62, or emailed to firstname.lastname@example.org
Last updated on December 2017