Privacy Policy

INFORMATION ON THE PROCESSING OF PERSONAL DATA PURSUANT TO ARTICLE 13 OF EU REGULATION 2016/679

 

HOLDER

 

SOFT N.W. società appartenente al gruppo Verzoletto S.p.A

 

PURPOSE

 

  1. Contractual or execution of pre-contractual measures;
  2. Direct marketing;
  3. Indirect marketing;
  4. Traffic analysis while browsing the site;
  5. Detection of customer satisfaction level and improvement of the site.

 

LEGAL BASIS

 

  1. Execution of a contract or pre-contractual measures;
  2. Consent;
  3. Legitimate interest.

 

RECIPIENTS OR CATEGORIES OF RECIPIENTS

 

  1. Hosting service providers;
  2. Providers of statistical analysis, web traffic analysis, marketing and advertising services;
  3. Third parties indicated in the extended information.

 

CATEGORIES OF PERSONAL DATA PROCESSED

 

Common data collected automatically by the site;

Common data collected through the site forms.

 

TRANSFER OF DATA TO THIRD COUNTRIES

 

United States

 

CRITERIA FOR THE RETENTION OF DATA

 

Criteria used to establish the data retention period.

 

RIGHTS OF THE INTERESTED PARTY

 

Access, rectification, cancellation of data and other rights indicated in detail in the Extended Information and provided for by EU Regulation 2016/679.

 

EXTENDED INFORMATION

 

NAME AND CONTACT DATA OF THE HOLDER

 

Name: Soft N.W.

Address: Via Piave 5, Quaregna Cerreto (BI) 13845 – Italy

E-mail address: softnw@softnw.com

 

PURPOSE OF THE TREATMENT

 

  1. Contractual purpose or execution of pre-contractual measures

We will process your personal data for the execution of pre-contractual, contractual and service execution measures. The data processing will therefore be necessary to provide useful information for the stipulation of the service contract, for the use of the digital platform https://sofynw.com in accordance with the terms of use and within the limits of what is necessary for the provision of the requested service. Personal data will be collected through the contact and registration forms available on the website. In particular, personal data will be processed in order to:

  1. Allow you to use the website and services;
  2. Allow you to contact us in order to receive information about our services and the contracts to be entered into
  3. Provide answers and information on the characteristics of the site and platform

 

  1. Direct marketing purposes also through user segmentation activities
    If it is not possible to use the legitimate interest as a legal basis for the processing, we will ask for your consent to the processing of data for direct marketing purposes and in particular for the sending of advertising material, direct sales, carrying out market research and commercial communication, with automated systems such as e-mail, telephone, sms, mms. In order to plan an adequate service offer, we can use automated tools that allow segmenting users based on the analysis of traffic data, in order to align advertising with the preferences shown by visitors during online browsing. The provision of data for marketing purposes is optional and failure to provide it will not have any consequence on the provision of the service.

  2. Purpose of analyzing traffic and user behavior while browsing the site.
    We reserve the right to monitor the use of the site by visitors, record information such as mouse movements and clicks, page scrolling activities, browser information (type, version, screen size, etc.), user base (country, language, time zone), to improve the quality of the site and services.

  3. Purpose to check the level of customer satisfaction and improve the site.
    We may contact you to infer your degree of satisfaction in relation to the service rendered by the Owner and / or Partner companies. We may also use online interviews to infer the degree of satisfaction in using the site, collecting visitor feedback. To protect your privacy, the information entered in the online forms is anonymous.

 

LEGAL BASIS OF THE PROCESSING

 

  1. Data processing necessary for the execution of a contract that the interested party is a part of, or for the execution of pre-contractual measures adopted at their request, including the provision of a service.
    Pursuant to EU Regulation 2016/679, the data processing carried out by us must always have a legal basis. The processing of your data is necessary for the execution of your contract, for the execution of pre-contractual measures taken at your request, for the provision of a service in the context of a contractual relationship and for responding to your request.

    Your personal data will therefore be kept for the time strictly necessary for the provision of services and subsequently deleted, as better specified in the chapter “Criteria for data retention”. Failure to provide it will make it impossible for us to provide the requested services and respond to your requests.

 

  1. Consent
    If it is not possible to make use of the legitimate interest, we will ask for your consent to process your personal data for direct marketing purposes and in particular for the sending of advertising material, direct sales, carrying out market research and commercial communication, also through the use of automated remarketing systems aimed at sending you communications in line with the preferences you have expressed while browsing online.

    You can object to this procedure immediately and at any time by communicating to us via sotnw@softnw.com. Compared to commercial communications, you will always have the possibility to oppose this procedure by asking not to receive such communications, by sending an e-mail to sotnw@softnw.com or by clicking directly on the unsubscribe link (“unsubscribe”) that you will find at the bottom of each e-mail received.

 

  1. Legitimate interest
    We will use the legitimate interest for the purposes referred to in letters (d) and (e) of the paragraph “PURPOSE OF THE PROCESSING” included to detect your level of satisfaction with the services provided by the Owner, the Partners or with the use of the Site. You can therefore be contacted by phone or e-mail, without prejudice to your right to object to such treatment at any time by sending us a communication to sotnw@softnw.com

    We will analyze the traffic and user behavior while browsing the site in order to improve our service and the browsing experience of visitors.

    In accordance with article 13 paragraph 2 of Directive 2009/136 / EC, as well as with reference to Recital (27) of REGULATION 2016/679 we may use your e-mail address acquired in the context of a customer relationship between you and the Owner (for example because you have used our services and concluded a transaction through the site) to send you electronic communications concerning products or services similar to those previously offered. You have the right, right now, to refuse such communications for free by communicating to us via isotnw@softnw.com as well as to object to such processing in the future by requesting a cancellation of your e-mail.

 

RECIPIENTS OR CATEGORIES OF RECIPIENTS

 

Hosting service providers.

 

The site-hosting service is managed by WordPress Inc, (“Data Processor”). Pursuant to EU Regulation 2016/679 General Data Protection Regulation (“the GDPR”) (Article 28, paragraph 3), the Data Controller is required to enter into a written agreement between the Data Controller and any organization that processes personal data for his account. We have therefore electronically signed an addendum on data processing or DPA (Data Processing Agreement) to ensure compliance with the obligations under the regulation. To know how the data is processed by the controller, please visit the privacy policy accessible at the following link: https://automattic.com/privacy/

 

Providers of web traffic tracking and analysis services, automated user segmentation and marketing systems.

 

  1. Google Inc. with registered office at 1600 Amphitheater Parkway, Mountain View, CA 94043 (“Data Processor”). Pursuant to EU Regulation 2016/679 General Data Protection Regulation (“GDPR”), article 28, paragraph 3, the Data Controller is required to enter into a written agreement between the Data Controller itself and any organization that processes personal data on its behalf. Therefore, we have entered into a data processing agreement with Google Inc. to ensure compliance with the aforementioned provisions of the GDPR in relation to all processing of personal data carried out by the Data Controller. The agreement can be found at the following link https://privacy.google.com/businesses/processorterms/. To find out how the data controller processes the data, please visit the privacy policy available at the following link: https://policies.google.com/privacy?hl=policies

    You can ask not to be tracked by Google Inc by deactivating the Analytics functions by following the instructions and installing the add-on available here https://tools.google.com/dlpage/gaoptout.

    You will also be able to manage your ad settings via your Google account by following the instructions given here: https://bit.ly/2nsCU7z

 

CATEGORIES OF PERSONAL DATA PROCESSED

 

  1. The computer systems and software procedures used to operate this website may automatically collect some information such as IP addresses and other data whose transmission is implicit in the use of Internet communication protocols. These data, although not used to identify users, could well be used because of their characteristics, which if associated with other data, identifies users, (e.g. IP address, domain names of the computers used by users who connect to the site, etc.). This data can be used both to obtain statistical information in aggregate form, and to check the correct functioning of the site.
  2. In order to proceed with the provision of the service, the user must provide a series of personal data, such as, but not limited to: name, surname, age, e-mail address, residential address.
  3. Through third parties we may collect geographical location, type of browser used, number of page views, IP address, information on clicks made on the pages of the Site. These data can be used both to obtain statistical information in aggregate form, and for improvements in user experience while browsing the site.

 

TRANSFER OF DATA TO THIRD COUNTRIES

 

The personal data of the interested parties may be transferred to the United States of America. All recipients of data established in the United States who will receive personal data have confirmed compliance with the EU-U.S. Privacy Shield regulatory framework. The transfer is authorized by the following adequacy decision approved by the European Commission: “Privacy Shield”.

 

CRITERIA FOR THE RETENTION OF DATA

 

Your personal data will be kept for the time necessary to achieve the purposes indicated in this statement and therefore only for the time strictly necessary to provide the service provided by the contract or to provide you with the information requested. The data will therefore be used until the purposes are achieved and subsequently deleted. The data will also be deleted as soon as you ask us to do so or when the treatment based on your consent, as soon as you decide to revoke it either through the opt-out links present in the commercial communications received, or by sending us a communication to the following address sotnw@softnw.com

 

RIGHTS OF THE INTERESTED PARTY

 

As an interested party, you have the right to:

 

  1. Be informed about the existence, or lack of, personal data concerning you;
  2. Access personal data that are being processed;
  3. Request the correction in the event that the data we have collected are incorrect or request the integration of the data in the event that they are incomplete;
  4. Ask the Data Controller to delete the data in the cases provided for by article 17 of Regulation 2016/679, including in the case of withdrawal of consent or if the personal data processed are no longer necessary with respect to the purposes for which they were collected or otherwise processed;
  5. Obtain the limitation of treatment pursuant to article 18 of Regulation 2016/679;
  6. Request the Holder of the portability of your personal data and receive it in a structured, commonly used and readable format or obtain direct transmission of your personal data to another holder;
  7. To object at any time to the processing of your data;
  8. Not be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or which similarly significantly affects you.
  9. To lodge a complaint with the Guarantor for the protection of personal data.

 

HOW TO EXERCISE YOUR RIGHTS?

 

You can exercise your rights at any time by sending us an email to the following address: sotnw@softnw.com. We have a duty to respond to your requests within one month of receiving them. This deadline can be extended by two months, if necessary, considering the complexity and the number of requests received. In case of extension you will be informed of the delay and the reasons.

In the event that we believe we cannot respond to your requests, we will communicate the reasons for the refusal. In this case, you will still have the opportunity to lodge a complaint with the Guarantor Authority for the protection of personal data.

 

This information may be subject to changes. Visitors are invited to regularly check the text of the privacy policy.

 

COOKIES INFORMATION

 

What are cookies?

 

Cookies are small text files that the sites visited by users send to their terminals, where they are stored and then retransmitted to the same sites on the next visit. Cookies can be used for different purposes: execution of IT authentication, session monitoring, storage of information on specific configurations regarding users accessing the server, storage of preferences. The site uses technical, analytical and profiling cookies.

 

Technical cookies

 

The site uses cookies necessary to allow users to correctly navigate the site, allow the use of interactive services, facilitate and improve the user experience on our site. Some functions of our site depend on technical cookies in order to function properly. This category also includes functionality cookies, which allow the user to navigate according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service. that is returned to you. For this category of cookies, you will not be asked for consent, it being understood that you can still disable them at any time via your browser settings. By disabling the technical cookies, we cannot guarantee an error-free use of the site.

 

Analytics cookies

 

The site also uses Google Analytics cookies to collect information in an aggregate form on the number of users and how users use the site. It is a web analysis service provided by Google. The information generated is used to indicate user trends on this website without identifying individual visitors and to report on the use of the site itself. The data generated by Google Analytics are stored by Google as indicated in the information available at the following link https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. To consult the privacy policy of the company Google Inc., please refer to the website http://www.google.com/intl/en/analytics/privacyoverview.html. The Data Controller has accepted the “Contractual Terms for the processing of Google Ad data” made available by Google Inc in compliance with Regulation 2016/679 and which define certain aspects of the processing and security of users’ personal data in accordance with the data protection legislation. Users who do not want their data to be used by Google Analytics can install the browser add-on for deactivating Google Analytics. This add-on tells Google Analytics JavaScript (ga.js, analytics.js, and dc.js) on websites not to use Google Analytics data.

 

Profiling, marketing, advertising and tracking cookies

 

Profiling cookies are used to receive offers built on the purchase preferences and tastes expressed by users while browsing online and thus display advertising messages consistent with his profile. In this way the advertising messages that you will see on the site will be more in line with your preferences. Profiling cookies also include those suitable for tracking the user’s choices while browsing. The user must consent to the installation of tracking cookies and will still be free to block the installation of profiling cookies at any time, without this having any consequence on the possibility of visiting the site and using its contents. If the user decides to disable profiling cookies, the advertising banners and advertisements that may be displayed on the sites may not reflect the interests or preferences of the user.

 

Below is a list of the remarketing, analytics and tracking cookies installed through the site:

 

How do you enable or disable cookies through the browser?

 

If the user decides not to allow the installation of navigation or technical cookies on the computer, some functions and services may not be available. Technical cookies do not record any personal information about a user and any identifiable data will not be stored. If the user decides to opt for the blocking of the storage of technical cookies, the Owner will no longer be able to guarantee the correct functioning of the site. Without prejudice to what is indicated with regard to the cookies necessary for navigation, the user can prevent the installation of analytics, marketing and tracking cookies through the banner settings or subsequently delete them through his browser. Each web browser allows you to limit and eliminate cookies through the settings. For more information on cookie management, see the relevant link below.

 

Internet Explorer

Firefox

Chrome

Safari