EURO ETP Sas (hereinafter, also, “ETP”), a company based in Poggio a Caiano, Via Donizetti, 9 as Data Controller, wishes to provide you with information on the processing of your personal data. In case of any doubt or clarification with respect to the following, please contact us at the addresses indicated below
Premises and Definitions
The “Personal data” is any information concerning an identified or identifiable natural person (“interested party”); the natural person is considered identifiable who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychic, economic, cultural or social.
The “treatment” is any operation or set of operations, carried out with or without the aid of automated processes applied to personal data, such as the collection, registration, organization, structuring, storage, adaptation, modification , extraction, consultation, use, communication by transmission, dissemination, making available, comparison, interconnection, limitation, cancellation, destruction.
The “Data Controller” is the legal person who, individually or together with others, determines the purposes and means of the processing of personal data.
The “Joint Controller” is the legal person who jointly determines the purposes and means of the processing of the data subject’s personal data, together with one or more Controllers, the responsibilities regarding compliance with the obligations deriving from the applicable legislation. The “Data Processor” is the natural or legal person who processes personal data on behalf of the Data Controller.
The “consent” of the interested party is the manifestation of the free, specific, informed and unambiguous will of the interested party, with which the same expresses his / her consent, by means of an unequivocal positive declaration or action, so that the personal data concerning him / her are subject to treatment.
For “marketing” we mean the performance of commercial, advertising and promotional activities, such as, for example, in a non-exhaustive manner, the sending of advertising material, direct sales, carrying out market research or commercial communication, or promotional activities carried out in the context of prize events and events promoted by CLP
The “profiling” is the treatment by computerized and automated means consisting in the use of such personal data to evaluate certain personal aspects or related to professional performance, the economic situation, personal preferences, interests, reliability in payments, behavior , location or movements of the natural person.
In relation to the single service requested, ETP will be able to process your personal data:
A ) Without express consent for the following Service Purposes:
- conclude the contracts for the services of the Data Controller;
- fulfill the pre-contractual, contractual and tax obligations deriving from existing relationships;
- fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as in the field of anti-money laundering);
- exercise the Data Controller’s right of defense in court;
- in credit reminder and recovery activities, also by transferring data to companies / professionals for credit recovery activities.
B ) Only subject to specific and distinct consent for marketing, market research and profiling purposes by EURO ETP Sas.
Methods of data retention
The processing of your personal data will be carried out in such a way as to ensure adequate security and confidentiality and to prevent unauthorized access or use of personal data. Therefore, your personal data will be processed and stored in full compliance with the principles of necessity, data minimization and limitation of the retention period, through the adoption of technical and organizational measures appropriate to the level of risk of the treatments and for a period of time. not exceeding the achievement of the purposes for which they are processed, in any case for the period required by law.
Access to data and categories of data recipients
Your data may be made accessible for the aforementioned purposes:
- to employees and collaborators of the Owner, authorized by the Owner, directly or through the delegates, subjects to whom the communication is necessary, functional and instrumental for the execution of the activities foreseen for the execution of the commercial relationship, subjects to whom the right to access for provisions of law or secondary legislation, or to parent companies, subsidiaries or associates, or in any case contractors of services on behalf of EURO ETP Sas in their capacity as delegates and / or appointees and / or system administrators.
- to third-party companies or other subjects (by way of example, companies specialized in credit reminder and recovery activities, consultants and freelancers also in associated form, marketing and market research companies, credit institutions, insurance companies for the provision of insurance services, etc.) that carry out outsourced activities on behalf of the Data Controller, in their capacity as external data processors.
- to third-party companies that collaborate in any capacity with ETP for the purpose of exercising contractual services, for example by way of example and not limited to: couriers, software companies, Poste Italiane and companies belonging to the Poste Italiane group.
EURO ETP Sas uses suitable security programs on all its information systems in order to guarantee the confidentiality of information. Our safety programs are periodically adapted to technological developments. For the performance of some activities instrumental to the execution of the requested service, or in relation to legal obligations and in any case in compliance with the legislation on the protection of personal data, ETP may appoint external data processors (third parties who carry out the processing of personal data on behalf of ETP).
Without the need for express consent, the Data Controller may communicate your data for the aforementioned purposes to Supervisory Bodies, Judicial Authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom communication is mandatory. By law. These subjects will process the data in their capacity as independent data controllers. Your information will not be disseminated.
Transfer of personal data to a third country
The transfer of personal data from EU countries to non-EU “third” countries is prohibited, in principle, unless the Data Controller or Data Processor guarantees an “adequate” level of protection. No data will be transferred to third countries, except for the services expressly requested by the customer or the specific cases for which the Data Controller will adopt adequate guarantees and will inform the interested party.
Rights of the interested party
In your capacity as an interested party, you have the rights referred to in art. 15 GDPR and precisely the rights of:
- obtain confirmation of the existence or not of personal data concerning you, and their communication in an intelligible form;
- obtain the indication: a) of the origin of personal data; b) the purposes and methods of the processing; c) the logic applied in case of processing carried out with the aid of electronic tools; d) the identity of the owner, manager and the representative appointed under Article 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents;
- obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment is proves impossible or involves the use of means that are manifestly disproportionate to the protected right;
- object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition also only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication.
- the existence of the right to withdraw consent if the interested party has given consent to the processing of their personal data for one or more specific purposes. Where applicable, it also has the rights referred to in Articles. 16-21 GDPR (Right of rectification, right to be forgotten, right to limitation of processing, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority or other Guarantors.
How to exercise the rights pursuant to Article 12 of the GDPR
You may at any time exercise the rights identified by art.
15 and, where applicable, by articles 16-21, by sending: – a registered letter with return receipt at the registered office of the company located in Via Donizetti, 9 – 59016 Poggio a Caiano (PO), or by writing to the certified e-mail address: firstname.lastname@example.org.
ed è lecito ove il minore abbia compiuto l’età minima prevista dalla legge applicabile.
Protection of minors
Minors may be less aware of the risks, consequences, as well as their rights in relation to the processing of personal data, therefore ETP addresses them specific protection, with particular regard to the use of personal data for marketing or profile creation purposes.
individuals and to the collection of personal data as part of the services provided directly to the minor. With regard to the direct offer of information society services (or any service provided electronically), the processing of personal data requires the explicit consent of the minor and is lawful where the minor has reached the minimum age required by law. applicable.
What are cookies?
Cookies are small text strings that are sent from a website to the browser used by the user for navigation, stored on the device (eg computer, tablet, smartphone, etc.) and retransmitted to the same site at the next visit of the ‘user.
Usually a cookie is presented as a string containing at least the name of the website from which the cookie itself comes, the “duration” of the cookie, and a value which, as a rule, is a unique number generated randomly.
Based on the subject in charge of managing the cookies sent by a website, two types of cookies are distinguished: “first party” when they are managed directly by the owner and / or publisher of the website (EURO ETP) “third party” when cookies are managed by parties unrelated to the website visited by the user.
What cookies do we use?
First party cookies
Third party cookies
While browsing the site, it is possible that some cookies that do not belong to our domains (so-called “Third Party cookies”) are sent when, for example, users visit a page that includes content from a third party website. Some Third Parties may send cookies that allow us to understand the habits and preferences expressed by users while browsing, in order to allow them to be able to adapt the advertisements shown on the site. Some types of cookies, managed by Third Parties, also allow us to obtain aggregate statistical information relating to visits received and browsing habits, in order to improve the usability and performance of our site. For greater clarity, EURO ETP reports below a list of the types of Third Party cookies that may send cookies while browsing the site and the related descriptions and pages / websites where it is possible to consult the information relating to the use of these cookies and deny consent to send them.
What third party cookies do we use?
EURO ETP partner websites may send Third Party cookies belonging to the following types:
These cookies are used by EURO ETP to collect and analyze aggregate and anonymous information for statistical analysis on accesses and visits to our website in order to improve its performance and design. They could also be used to limit the frequency with which an ad is proposed and therefore show advertising based on the interest of users as well as as an aid to measuring the effectiveness of a campaign.
They allow to obtain information on the navigation of users on the site and to recognize those who return to visit our website and / or a site that is part of the network of one of our promotional partners, allowing to build anonymous profiles aimed at making advertisements provided by our most engaging and targeted business partners. No personal information, enabling the identification of the individual user and the consequent association with the advertising profile created is shared with the Third Parties.
Below is a list of Third Parties that may send Analytics and / or Profiling cookies while browsing the site and the related links to the privacy policies and forms for revoking consent to their receipt: Google Analytics
Any revocation, however, will not remove advertising from web pages that are visited by users, but will make such advertisements not based on your interests.
How we acquire consent to receive cookies
In line with the provisions of current legislation, for the sending of third-party profiling and analytics cookies, prior consent is required during the user’s first visit to our sites, which can be expressed in the following ways:
• by clicking on any link within the page
• by clicking on the “Close and accept” button of the banner containing the brief information
However, we would like to remind you that restricting the ability of websites to send cookies can worsen the overall browsing experience of users.
Owner, Delegates and employees in charge
The Data Controller is EURO ETP Sas, with registered office in: Via Donizetti, 9 – 59016 Poggio a Caiano.
The updated list of data processors is kept at the registered office of the Data Controller.