The Data Controller, in accordance with the principles of legality, purpose limitation and data minimisation, pursuant to art. 5 of GDPR, stores and processes personal data for the time strictly necessary to fulfil the purposes identified above and until the Data Subjects parties to revoke the consent given. For the purpose of determining the appropriate retention period, the Data Controller shall consider the quantity, nature and sensitivity of the Personal Data, the purposes for which they are processed and if the same purposes can be achieved by means of other instruments. In particular, for the purposes of marketing, personal data may be kept for a period of 24 months from the granting of consent for this purposes, unless renewal thereof (expect the opposition to receive further communications). The Data Controller every two years shall request renewal of consent. The processing and retention of digital material, such as pictures or video, will be performed until the data subjects communicate the withdrawal of consent to data processing. 6. Access to personal data and to whom these can be communicated Pursuant to art. 6 of GDPR, without the express consent of the Data Subjects the Data Controller can disclose the personal data to the supervisory bodies, judicial authorities and all other persons to whom that kind of communication is required by law and to the accomplishment of the purposes of art. 3. These subjects will process personal data as autonomous Data Controllers. Personal data will not be disclosed, sold or exchanged with any third party without the express consent of the Data Subjects. The management and conservation of personal data will happen on server (located within the European Union) of the Data Controller and/or of third parties appointed as data processors. Personal Data may be brought to the attention of::

1. Data Controller’s employees or collaborators, that are formally appointed and authorized to process and their receive opportune operational instructions in this regards;
2. External companies and third parties which Data Controller may make use of in relation to the management of the contractual relationship with customers or for its own organisational needs and its activities (e.g. IT service suppliers, consultants, agents, etc.)
3. Other companies of the El.En. Group.

7. Rights of the Data Subject Pursuant to articles 15-22 of the GDPR,, the Data Subject is entitled:

1. To be inform of:
   • source of the Personal Data;
   • processing purposes and methods;
   • logic applied when data are processed using electronic equipment;
   • identity of the Data Controller, data processors and designated representative pursuant to article 5;
   • parties or categories of parties to whom the personal data may be communicated;
2. To obtain:
   • the updating, rectification or, where he/she wishes, the integration of the data;
   • the cancellation, anonymization, or blocking of data processed unlawfully, including data that does not need to be retained for the purposes for which it was collected or subsequently processed;
   • certification that the activities mentioned above, including their content, have been notified to those to whom the data was disclosed, unless this requirement proves impossible or implies manifestly disproportionate measures with respect to the protected right;
   • data portability: the right to receive personal data in a structured, commonly used and automatically readable format, and to transmit such data to another data controller, only for cases where the processing is based on consent and for only data processed by electronic means;
3. To oppose, in whole or in part:
   • for legitimate reasons, to the processing of his/her personal data, even if it is pertinent for collection purposes;
   • for the purposes of this article, the Data Subject is entitled to request the cancellation, transformation into an anonymous form or blocking of data processed in violation of the law and, in any case, to abject, for legitimate reason, to their processing.

All requests must be addressed to the DPO at the following address: dpo@elen.it. Before responding the request, the DPO may ask for confirmation of the Data Subject’s identity and for information to substantiate its interaction with the Data Controller, so that he can identify the relevant Personal Data. Insofar as the Data Subjects are provided with tools that allow the self-management of Personal Data, including the withdrawal of consent to the processing of the same, we expect such tools to be used.
8. Data transfer

1. Depending on the circumstances Deka M.E.L.A. S.r.l. could transfer Personal Data collected through the Site to other companies of the El.En. Group or to third parties located in other countries, even outside the European Union, which does not offer the same level of protection of personal data. The European Commission puts the countries deemed “adequate”, namely those that preparing an adequate protection, in a separate list, which can be viewed at: https://www.garanteprivacy.it/temi/trasferimento-di-dati-all-estero.Transfers of Personal Data outside the European Union and to countries not belonging to the above list, will be carried out exclusively under specific agreements between Deka M.E.L.A. S.r.l. and the companies involved, through the use of tools accepted by the European Commission.

9. Cookies

1. DEFINITION AND PURPOSE OF COOKIES

   A “cookie” is a small text file created by certain websites on the user’s computer when he or she accesses a particular site, whose purpose is to store and transmit information. Cookies are sent from a web server (which is the computer that runs the website visited) to the user’s browser (Internet Explorer, Mozilla Firefox, Google Chrome, etc.) and are stored on the user’s computer; they are then re-sent to the website when the user subsequently visits that site.

   Some operations cannot be performed without the use of cookies, which thus makes them technically necessary in certain cases. In other cases, the site uses cookies to facilitate and assist navigation by the user or to allow him or her to access services that are specifically requested.

   Cookies may also remain in the system for long periods of time and may also contain a unique identification code. This enables sites that use them to keep track of the user’s navigation inside the site, for statistical or advertising purposes i.e. in order to create a customised profile of the user based on the pages that user has visited and, hence, to show and/or send the site visitor targeted ads (so-called Behavioural Advertising).

2. WHICH COOKIES ARE USED BY THE WEBSITE AND FOR WHICH PURPOSES

   This Site uses various types of technical cookies: navigation cookies, analytics cookies and profiling cookies.

   The Data Controller – following the directions provided by the Italian Data Protection Commissioner in the general Ruling of 8 May 2014 – details below the specific categories of cookies used, as well as the purpose thereof and the results of their deselection:

    

   TYPE OF COOKIES	PURPOSES	DURATION OF RETENTION	EFFECTS OF  DESELECTION
   Navigation cookies	These allow normal navigation and use of the website	Valid for the browsing session	Browsing would not be possible  if these were deactivated, which makes these cookies necessary
   Analytics cookies	These gather information in aggregate form on navigation by users to optimise the experience of navigation and the services themselves.	Established by third parties, reference is made to the privacy notice referred to below	It would not be possible for the Data Controller to obtain the information in aggregate form
   Functionality cookies	These facilitate navigation and the service rendered to the user based on a series of criteria selected by the latter	Retained to preserve functionality for 30 days	It would not be possible to retain the selections made by users during navigation

3. THIRD PARTY COOKIES

   Third party cookies also operate on this website i.e. cookies created by a website other than the one that the user is currently visiting.
   Based on the provisions of the Ruling of the Italian Data Protection Commissioner of 8 May 2014, the Data Controller is bound to provide the updated link to the privacy notices and consent forms of third parties with whom special agreements have been stipulated for the installation of cookies through its own website.

   Third party cookies are:

   • Anonymous third party cookies: The use of anonymous third party cookies is provided for; these cookies facilitate the anonymous gathering and recording of information on pages of the website that have been accessed, without allowing the visitor to be identified, and they are not combined in any way with other information. Such data are used exclusively to track and examine the use of the sites by users, to compile statistics based on information gathered anonymously and by using data in aggregate form. In particular, users are informed that the web analytics service that issues cookies used by the Data Controller is “Google Analytics”, described below. Google Analytics is a web analytics service provided by Google, Inc. (“Google”) that uses “cookies” placed on the user’s computer to enable the website visited to analyze how it is used by users. The information generated by the cookie about the use of the website visited (including the IP address) will be sent to Google and stored on Google servers in the United States. Google will use this information in order to track and examine the user’s use of the website, compile reports on the website’s activity for website operators and provide other services relating to the website’s activity and to internet usage. Google may also transfer this information to third parties if legally required to do so, or where the third parties process the aforementioned information on Google’s behalf. Google will not associate the user’s IP address with any other data held by Google. The user may at any time refuse the use of cookies by selecting the appropriate setting on his or her browser. To consult Google’s privacy policy in relation to the Google Analytics service, see the website https://policies.google.com/privacy?hl=en.
   • This Site uses also the Facebook Pixel, a cookie that allows advertisements consistent with previously visited pages and with the user’s navigation on the Site, to be shown on social media or when the user carries out a search using a search engine. This technology means that the Data Controller only sends the user advertisements that are tailored to his/her tastes rather than standard advertisements. For further information about the Facebook Pixel please see: https://en-gb.facebook.com/business/help/651294705016616.
     
      
4. RETENTION PERIOD

   By accessing the Site and going beyond the introductory banner containing the short privacy no-tice, the Users consents to the use of the technical cookies specified in this document. This consent may be revoked at any time by pressing the button “I do not consent” at the end of this privacy and cookies policy.

   Individual cookies may be freely selected/deselected using this system, but this may also be done by using one’s web browser (selecting the settings menu, clicking on internet options, opening up the privacy tab and selecting the desired level for blocking cookies).

   By failing to accept functional cookies certain pages of the Site will not be visible.

Last amendment 12.4.2024