INFORMATION DOCUMENT ON PERSONAL DATA PROCESSING
(pursuant to articles 13 and 14 of the European Regulation no. 679/16)

Since it was originally designed, the website of the company Brazzale S.p.A. has always aimed at guaranteeing compliance with the principles established by the EU Regulation no. 2016/679 regarding the protection of all individuals, with particular attention to Personal Data Processing, as well as the free movement of such data in the public interest and in line with the right to transparency.

Brazzale S.p.A. guarantees its visitors the possibility to interact with its web portal and to freely make use of the services required, such as the receipt of newsletters or information documents, for which the user has knowingly expressed his/her consent to data processing.

The personal data processed – that have been collected or provided by the visitor in the dedicated forms – and any other type of pertinent information, are accessible through the web address www.brazzale.com that corresponds to the Brazzale S.p.A official website.

Brazzale S.p.A. has issued this information document to describe the methods of free access to the website, as well as to inform site users and visitors about personal data processing and the relevant guarantees recognized by the law, pursuant to art. 13 of the above-mentioned “Regulation”.

This information document refers only to the personal data contained or acquired during the use of the Brazzale S.p.A. website, not for other websites (for which the Company is not responsible or of which it is not a joint holder) that could be consulted by the user through the link.

Data controller
The Data controller is Brazzale S.p.A., in the person of its Legal representative in charge, who, for this purpose, is domiciled in his/her office at company’s main headquarters and can be contacted at the following address: Brazzale S.p.A., Via Pasubio 2, 36010, Zane (Vicenza, Italy) – Phone: 0445.313900 E-mail address: privacy@brazzale.com, Certified e-mail address: privacy@pec.brazzale.com.

Purposes of data processing and legal basis
The personal data are processed for purposes in line with the services offered by Brazzale S.p.A. through its web portal to ensure the supply of goods and services indicated in the Corporate statute, as well as to enable direct marketing (a commercial activity for which the Company has a dedicated Data Processing Register containing the categories of the data subjects).
Within the scope of these purposes, the processing also concerns the data deriving from registrations to the portal, that are necessary to manage relationships with Brazzale S.p.A., as well as to enable an effective institutional communication and to fulfil possible legal, regulatory or contractual obligations.

Place and methods of data processing
The data are processed exclusively in Italy by trained personnel that have been authorised to process the data according to the principles of fairness, lawfulness, transparency, pertinence, not exceeding the purposes for which the data was originally collected.
The data related to the services offered by the Brazzale S.p.A. website are processed for the time strictly necessary to achieve the purposes established by the user, who is guaranteed all the minimum safety (and confidentiality) measures required to prevent data loss, its improper or illegal use or unauthorised access to such data.
The personal data provided by the users who register themselves or use the services of the Brazzale S.p.A. website – i.e. first name, surname, e-mail address, phone number, company and website – may be used for other processing operations in line with the purposes for which they were collected, such as sending communications, via e-mail, about the service offered and requested.
The personal data of those users who request documents or information material (newsletters, answers to questions, acts and provisions, etc.) are only used to supply the requested service and will not be transferred or disclosed.
The use of automated processing or decision-making processes aimed at profiling the visitor of the Brazzale S.p.A. official website is not envisaged.

Type of data processed and recipients
Navigation data: during their normal operation, the computer systems and the software procedures for running this website acquire some personal data, whose transmission is implicit in the use of Internet communication protocols. This information is not purposefully collected to be associated with identified users, but the nature of the information itself may enable the identification of the users. This data category includes IP addresses, domain names of the users’ computers, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in reply to the request, the code of the server’s reply and other parameters (user’s operating system and IT environment). These data are used for the sole purpose of obtaining statistical information in an aggregate and anonymous form on the use of the website, to check that it is operating correctly, and these data are immediately deleted after having been processed. However, the data may be used to ascertain responsibility in case of hypothetical computer crimes against the site;
Data provided voluntarily by the user: the submission of optional, explicit and voluntary personal data by the User to the contacts given in this site, or in available forms, entails the subsequent acquisition of the sender’s data. Such data will be processed by the Data controller mostly using electronic means, in order to fulfil the user’s request;
The categories of data processed, as well as the categories of recipients to whom the data refer, are specified in the Data Processing Register, which is available at the Brazzale S.p.A headquarters.

COOKIES
The above-mentioned navigation data include the COOKIES (small text files that the visited websites store in the user’s computers). They are mainly used to make the websites work and operate more efficiently, as well as to provide the website’s owners with relevant information.
This website uses third-party analytical cookies (reducing the power of identification and displaying the results in an anonymous and aggregate form) and technical cookies (to the extent strictly necessary for the use and navigation of its website). In particular, the use of technical session cookies is limited to the transmission of session identifiers (made up of random numbers generated by the server) that are necessary to enable the safe and efficient exploration of the site. These cookies avoid having to use other IT techniques that may compromise the confidentiality of the users’ navigation and do not enable the acquisition of personal identification data regarding the user. No personal user data is intentionally acquired by the site simply for the sake of doing so, and this is not our will. No cookies are used for the transmission of personal information and no persistent cookies are used for tracking the user. Should the user not wish to receive any type of cookie on his/her device, he/she can raise the privacy protection level of the browser by selecting the dedicated function, or pressing the key “Refuse cookies” on the website’s main page. Below is a list of the cookies used by this website:

_ga Third-party2 yearsTechnical (anonymised)It is required by the third-party service Google Analytics. It is a persistent cookie that is used to identify users.Google Analytics
_gatThird-party10 minutesTechnical (anonymised)It is required by the third-party service Google Analytics. It is a persistent cookie that is used to limit the request rate and the data collection in high-traffic websites.Google Analytics
_gidThird-party24 hoursTechnical (anonymised)This cookie is used to identify the sessionGoogle Analytics
_icl_current_languageThird-partySessionTechnical -functionalThis operation cookie is used by WordPress to save the selected languageWordPress
wpca_cc, wpca_consentThird-party30 daysTechnical -functionalThey are used to save the user’s preferences regarding cookiesWordPress

Data retention period
The data will be kept strictly for the time period necessary to fulfil the above-mentioned purposes (“storage limitation principle”, art. 5 of the EU Regulation,) or for the time period prescribed by the laws in force.

Transfer of personal data abroad
The transfer of personal data to third countries outside the European Economic Area can only occur in the following cases:
• Campaign Monitor (Campaign Monitor Pty Ltd): this is an address management service (first name, surname, e-mail address and phone number) for sending messages used to communicate with the User. The place where the data is processed is New South Wales (Australia): see the dedicated Privacy Policy.

RIGHTS OF THE DATA SUBJECT
The following rights of the data subject (ref. articles 15÷21 of the EU Regulation) may be exercised at any time:
• The right to obtain confirmation that his/her personal data is being processed and to access said data;
• The right to obtain the data rectification without undue delay, including data integration;
• The right to obtain the data deletion;
• The right to obtain the restriction of the data processing and to revoke it, if required;
• The right to data portability;
• The right to lodge a complaint with a supervisory authority.

The above shall apply, unless any legitimate reasons are raised by the Data controller.