Privacy Policy

We are constantly committed to protecting the online privacy of users of our sites and all related subdomains and domains registered in our name (hereinafter, unless otherwise indicated, collectively the “Site”).

This document (“Information”) has been drawn up in order to allow you to understand how your Personal Data, as defined below, will be processed when using the Site.

The Information is aimed at providing you with the necessary information so that you can express explicit and informed consent to the processing carried out through the Site, if you deem it appropriate.

In general, any information or Personal Data that you provide to us through the Site, or that is otherwise collected through the Site, as part of the use of the services offered by us (the “Services”), such as better defined below, will be processed according to the internationally recognized principles of lawfulness, correctness, transparency, purpose and storage limitation, data minimization, accuracy, integrity and confidentiality.

Data controller

Our company, as identified on the Legal Information page, is the Data Controller in relation to all Personal Data processed through the Site.

The personal data being processed

When you browse the Site you may communicate to us or we may collect some of your Personal Data, which – depending on the case – may consist of an identifier such as your name, an identification number, an online identifier or one or more elements characteristic of your physical identity , physiological, psychological, economic, cultural or social nature suitable for making you identified or identifiable (hereinafter only “Personal Data”).

Your Personal Data may be collected either because you voluntarily provide it (e.g. when you sign up for our newsletter or when you access your Reserved Area) or simply by analyzing your behavior on the Site.

The Personal Data processed through the Site are as follows:

Name, contact details and other Personal Data

In various sections of the Site, in particular the one relating to the pages contained in the Reserved Area, you will be asked to enter information such as your name, telephone number, email address, postal address, the company you work for, etc.
Furthermore, when you communicate with us via the email addresses or telephone numbers found on the Site, we may collect further information that you decide to freely provide.

Special categories of personal data

Some sections of the Site (e.g. the information request form) include free fields in which you can provide us with some information, which may contain Personal Data.
Since these fields are free, you may use them to communicate (voluntarily or otherwise) some sensitive categories of Personal Data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data relating to a natural person’s health or sex life or sexual orientation.
We invites you not to send such Personal Data unless strictly necessary. Indeed, these special categories of Personal Data may be processed only with your explicit consent and in compliance with the legislation in force at the time. We therefore underline the importance of expressing your explicit consent to the processing of special categories of Personal Data, should you decide to share such information.

Data provided voluntarily by the interested party

As already mentioned above, in some sections of the Site you are allowed to insert text messages, visible to us, which may contain Personal Data of other people.
With respect to these hypotheses, you act as an independent data controller, assuming all legal obligations and responsibilities. In this sense, you grant on this point the broadest indemnity with respect to any dispute, claim, request for compensation for damage caused by treatment, etc. that should reach us from third parties whose Personal Data has been processed through your use of the Site’s functions in violation of the applicable personal data protection regulations. In any case, if you provide or otherwise process the Personal Data of third parties when using the Site, you guarantee from now on – assuming all related responsibility – that this particular processing hypothesis is based on the consent of said third party or on another suitable legal basis that legitimizes the processing of the information in question.

Personal data collected automatically when we send emails or communications

When we send emails, messages, phone calls or more generally communications, we use tracking systems, subject to the user’s freely given consent, such as pixels or web bacons, to detect the opening of a message, the clicks made on the hyperlinks contained within the messages, from which IP address or with which type of browser the message is viewed and other similar details.

Browsing data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified.
This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site or third parties: except for this eventuality, data on web contacts currently do not persist for more than fifteen (15) days.

All information on the processing of Cookies can be found in the specific section accessible at the cookies address.

Purpose of the processing

Our company uses your Personal Data, collected through the Site, for the following purposes:

provide Services such as: allowing you to register on the Site in order to access the reserved access section and help you, in the event that you lose or forget the login details for registration on the Site (“Provision of the Service”);
respond to your requests for information sent through the Support section or resolve any problems you may have encountered and provide you with any other Services you request (“Support”);
send you marketing communications, promotions and advertising, market research and surveys, via email, SMS, by telephone, via banner, paper mail, instant messaging, via an operator, as well as for marketing activities in the broadest sense, including prize events , games and competitions, of products and/or services referable to us or to third parties (“Marketing”);
to create your profile through the use of profiling cookies, where accepted, therefore collecting and analyzing information on your general activities on the Site. This profile will be used to provide you with information on other products and/or services that we believe may be of interest to you. All the algorithms involved in this automated or semi-automated process are regularly tested and associated with the preferences freely indicated by you in the Reserved Area to ensure that you are not offered products that are not of interest to you (“Profiling”);
comply with legal obligations that require us to collect and/or further process certain types of Personal Data (“Compliance”);
control the methods of use of the Site, prevent or identify any abuse in the use of the Site, or any fraudulent activity and therefore allow us to protect itself in court (“Abuse/Fraud”);

Legal basis and nature of the processing

The legal bases used by our company to process your Data, according to the purposes indicated above, are the following:

Provision of the Service: processing for this purpose is necessary to be able to provide you with the Services and, therefore, for the execution of pre-contractual or contractual measures requested by you. It is not mandatory to provide us with your Personal Data for this purpose, but otherwise it will not be possible to provide you with any Service;
Assistance: processing for this purpose is necessary to be able to follow up on the request for assistance that arises from your free specific request by completing the form. It is not mandatory to provide us with your Personal Data for this purpose, but otherwise it will not be possible to provide you with any assistance;
Marketing: processing for this purpose is based on your consent. It is not mandatory to give your consent to us for this purpose and you are free to withdraw it at any time without any consequences (except for the fact that you will no longer receive marketing communications from us). You can revoke your consent previously given by following the instructions in the “Rights of the interested party” paragraph;
Profiling: the processing for this purpose is based on your consent collected through the cookie banner. It is not mandatory to give your consent to us for this purpose and you are free to withdraw it at any time without any consequences. You can revoke your consent previously given by following the instructions in the “Rights of the interested party” paragraph or, as regards cookies, the instructions in the specific Cookies section;
Compliance: processing for this purpose is necessary for us in order to fulfill any legal obligations. When you provide Personal Data to us, they must be processed in accordance with applicable legislation, which may involve their retention and communication to the Authorities for accounting, tax or other obligations;
Abuse/Fraud : the information collected for this purpose will be used exclusively to prevent and/or identify any fraudulent activities or abuses in the use of the Site and therefore allows our company to protect itself in court;

Recipients of personal data

Your Personal Data may be shared with the subjects indicated below:

subjects who typically act as data controllers, i.e.:
- people, companies or professional firms that provide assistance and consultancy to us in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services;
- subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communications networks);
subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers);
persons authorized by our company to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of our company);
company of the corporate group of which our company is part or will be part in the future, for internal administrative and marketing purposes;
subjects, bodies or authorities to whom it is mandatory to communicate your Personal Data for Compliance, Abuse or Fraud purposes, or by order of the authorities;

Transfers of personal data

Some of your Personal Data is shared with Recipients, both internal and external to the corporate group of which our company is part or will be part in the future, who may be located outside the European Economic Area. We ensure that the processing of your Personal Data by these Recipients takes place in compliance with the applicable legislation. Indeed, transfers are carried out through adequate guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate.

Storage of Personal Data

The Personal Data processed for the purpose of Provision of Services and Assistance, our company may retain them for a longer period, in particular as may be necessary in order to protect the interests of our company from possible complaints relating to the Services. For further information regarding the storage of Personal Data, they are available in the GDPR section.

The Personal Data processed for Marketing and Profiling purposes will be retained by us until you revoke your consent; you will however be asked to renew your consent periodically. Once your consent has been revoked, we will no longer use your Personal Data for these purposes, but may still retain them, in particular as may be necessary in order to protect the interests of our company from possible complaints based on such processing.

Personal Data processed for Compliance purposes will be retained by us for the period required by specific legal obligations or applicable legislation.

The Personal Data processed for the purpose of preventing Abuse/Fraud will be kept by our company for the time strictly necessary for the aforementioned purpose and therefore until the moment in which our company is required to keep them to protect itself in court and to communicate said data to the competent Authorities .

Rights of the interested party

You have the right to ask our company, at any time:

access to your Personal Data, (or a copy of such Personal Data), as well as further information on the processing in progress on them;
the rectification or updating of your Personal Data processed by our company, where they are incomplete or not updated;
the deletion of your Personal Data from our company databases;
the limitation of the processing of your Personal Data by our company;
to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format;

as well as you can:

object to the processing of your Personal Data by us;
revoke your consent for Marketing and Profiling purposes;

By accessing the Reserved Area you can at any time: access your Personal Data as well as view information on processing, rectify or update your Personal Data, limit processing or export Personal Data in a structured format.

You can revoke your consent to Marketing by using the appropriate link found at the bottom of each communication received, or by sending an email to privacy@erbemate.it.

Consent to Profiling through cookies can be revoked using the methods indicated in the section relating to Cookies.

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority if you believe that the processing of your Personal Data is contrary to the legislation in force. Below are the contact details of the Guarantor for the protection of personal data:

Piazza di Monte Citorio, 121 – 00186 Rome
Tel.: +39 06696771
Fax: +39 0669677785
email: garante@garanteprivacy.it
Website: http://www.garanteprivacy.it

Version

Rev-22.315 dated 15/03/2022