PRIVACY E COOKIES INFORMATION
according to art. 13 Reg. (EU) 2016/679
INTRODUCTION
According to art. 13 of the Regulation EU 2016/679 on the protection of personal data (“GDPR”), this Privacy Policy describes the personal data collected or generated (processed) when you use www.velumprotection.com website (“Site”). It also explains how your personal data is used, shared and protected, what choices you have relating to your personal data and how you can contact us. This Privacy Policy, therefore, concerns only this Site and does not apply to other websites that may be visited by the user through hyperlinks accessed on the Site.
INDEX
SECTION 1 – PRIVACY POLICY
- Which data? For how long? Why? Which is the legal base?
- Who is the Controller?
- Who are the recipients?
- Where are the data?
- What are the data subjects’ rights?
SECTION 2 – COOKIE POLICY
- Cookies information?
- What are they use for?
- Which kind of Cookies do you use?
- How to disable cookies?
SECTION 1 – PRIVACY POLICY
1. WHICH DATA? FOR HOW LONG? WHY? WHICH IS THE LEGAL BASE?
1. Navigation data
The information systems and software procedures used to the operation of this web site acquire personal data as part of their standard functioning. Such information is not collected in order to relate it to identifiable data subjects, however, it may allow User identification after being processed and matched with data held by third parties.
This data category includes the: IP addresses or names of computer domains used by visitors who access the website; URI (Uniform Resource Identifier) addresses of the requested resources; time of request; method used to submit the request to the server; size of the file obtained in response; numerical code indicating the status of the response from the server and other details relating to the operating system and the information environment of Users.
Purposes
This data is used only to obtain anonymous statistical information about the website and to check its correct functioning.
Legal base
Our legitimate interests in running a business through the Site which do not impact on your rights or interests.
Retain period
Navigation data are deleted immediately after processing. This data may also be used to ascertain responsibility in the case of possible computer crimes against the website. Besides that, data on web contacts is not stored for more than seven days.
2. Data supplied voluntarily by the User
The voluntary and explicit sending of communications by e-mail to the contact addresses or using the contact forms you may find on this website will entail the subsequent acquisition of the sender’s data, including his e-mail address, and the consent to receive replies to his request.
Purposes
Responding to the submitted requests.
Legal base
Perform a contract and provide the service you ask for.
Retain period
The data will be stored for the times required to properly answer to your questions and for the times prescribed by law.
3. Cookies
See Section 2 below (“Cookie policy”).
Legal base
The Controller’s legitimate interest in the proper functioning of the Site for technical and anonymized analytical cookies and the user’s consent through the appropriate banner for any other analytical and profiling cookies.
4. Newsletter
We send our newsletter by e-mail to those who explicitly request it, by filling out the appropriate form the Website and authorizing us to process their personal data for the aforementioned purpose. The data collected will be processed with IT tools and/or automated means; specific security measures are adopted to prevent loss, unlawful use or to prevent unauthorized access to the Site. In order to stop receiving the newsletter, you simply have to select the link for removal at the end of each e-mail or send a specific request to our e-mail address. Please contact us if you have any technical problem with the service.
Purposes
Sending you periodical communication and news about us.
Legal base
User’s express consent.
Retain Period
You can always revoke your consent. When you stop the service, we retain only your subscription’s data for the times required by the law.
5. Download the Velum Free guide / Download the brochure
The user can download the free “Velum Free” guide and brochures with information relating to the products offered by providing his e-mail address in the appropriate contact forms on the Site. To this end, he must have declared that he has read this Privacy Policy. The downloaded content is in any case material owned by Nitty-Gritty and, therefore, the user is asked to fill in a form and to release the data necessary for his identification (name, surname) and to satisfy the request (e-mail address) and, if necessary, contact him, for example in the event of the introduction of new similar services or changes.
Purposes
Responding to the submitted requests.
Legal base
Perform a contract and provide the service you ask for and the legitimate interest of the Controller in sending communications regarding products or services similar to those already requested.
Retain period
The data will be stored for the times required to properly answer to your questions and for the times prescribed by law.
6. Try our Velum for free
The user can request a free sample of Velum through the “Try our Velum for free” form. So, he shall provide Nitty-Gritty with his name and contact details (telephone and e-mail): this will entail the subsequent acquisition of the data communicated and the consent to be contacted in response to his request and, for example, in the event of introduction of new similar services or modifications to them.
Purposes
Responding to the submitted requests.
Legal base
Perform a contract and provide the service you ask for.
Retain period
The data will be stored for the times required to properly answer to your questions and for the times prescribed by law.
7. Become a Distributor
The user can request to become a Velum distributor by filling in the appropriate section on the Site. To this end, he shall provide the following data: Name, Surname, Email, Company and Country and declare that he has read the Privacy Policy. This will involve the acquisition of the data provided, which may be processed to respond to the user’s request.
Purposes
Responding to the submitted requests.
Legal base
Perform a contract and provide the service you ask for.
Retain period
The data will be stored for the times required to properly answer to your questions and for the times prescribed by law.
8. Soft-spam communication
The personal data (in particular, e-mail address) provided by the User when purchasing products or services may also be used to send e-mail communications relating to products similar to those already requested by the user, pursuant to of the art. 130, paragraph 4, legislative decree 196/2003 and art. 6, lett. F), GDPR, without the need for express and prior consent (so-called soft spam). In any communication, however, the user is reminded that he can revoke the consent at any time and without formalities. The data is deleted in case of data subject request.
Purposes
Sending you periodical communication for marketing and/or sales promotion purpose.
Legal base
The legitimate interest of the Data Controller in sending communications regarding products or services similar to those already requested.
Retain period
The data will be stored for the times permitted by law or till the user revokes the consent
2. WHO IS THE CONTROLLER?
The Controller is NITTY-GRITTY S.R.L., P.IVA. 02316620364, with registered office in Via Mazzini n. 182/F, 41049, Sassuolo (MO) – Italy, e-mail: info@nitty-gritty.it; PEC: nitty-gritty@pec.confartigianato.it (“Controller”).
3. WHO ARE THE RECIPIENTS?
Personal data is accessed by our duly authorized and trained personnel.
Other subjects who have access to personal data have been appointed as Data Processors. A list of the subjects to whom the Data Controller discloses the personal data collected can be requested at the contact points shown at Par. 2 above.
Users’ data will not be transferred to third parties except if the nature of the services requires it, or if, by virtue of a legal obligation or in the presence of its legitimate interest, Nitty-Gritty has the need to communicate them to judicial or supervisory authorities.
Nitty-Gritty uses the following suppliers:
- Google Ireland Limited , with registered office in Dublin – Gordon House, Barrow St, Dublin 4 – Ireland: for further information, please visit the following page: https://policies.google.com/privacy
- ActiveCampaign , with registered office in Chicago – 1 North Dearborn St 5th Floor, 60602 IL – USA: for further information, please visit the following pages: https://www.activecampaign.com/legal/privacy-policy and https://www.activecampaign.com/legal
- TruConversion , brand by Digital Marketers Inc. with registered office in TEXAS USA: for further information, please visit: https://www.truconversion.com/privacy-policy/ and https://www.truconversion.com/term-of-use/
- NitroPack LLC, with registered office in Sofia – 3 “Professor Georgi Bradistilov”, Studentski Kompleks, Sofia, postcode 1756 – Bulgaria: for further information, please visit: https://nitropack.io/page/privacy and https://nitropack.io/page/terms
- LinkedIn Corporation , with registered office in Sunnyvale, CA – USA: for further information, please visit: https://www.linkedin.com/legal/privacy-policy and https://www.linkedin.com/legal/user-agreement
- Facebook Ireland Ltd. with registered office in Dublin – 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland: for further information, please visit: https://www.facebook.com/about/privacy
- Vimeo.com, Inc. with registered office in New York – 555 West 18th Street New York, New York 10011 – USA: for further information, please visit: https://vimeo.com/privacy
- Leadfeeder brand by Liidio Oy, with registered office in Helsinki – Mikonkatu 17 C 00100 Helsinki – Finland: for further information, please visit: https://www.leadfeeder.com/privacy/
4. WHERE ARE THE DATA?
The data processed by Nitty-Gritty reside on servers located within the territory of the European Union. Some cookie service providers are based in non-European countries, particularly in the United States. In these cases, personal data may also reside on servers located in third countries, but always in compliance with the provisions of articles 45 and following of the GDPR. All the necessary precautions will therefore be taken in order to guarantee the most complete protection of personal data, basing this transfer: a) on adequacy decisions of the recipient third countries expressed by the European Commission; b) on adequate guarantees expressed by the third party recipient pursuant to art. 46 of the Regulation; c) on the adoption of binding corporate rules, so-called Corporate binding rules. These requirements are always guaranteed by Nitty-Gritty’s service providers. Further information in this regard can be requested from the Data Controller using the contact details indicated at par. 2.
5. WHAT ARE THE DATA SUBJECTS’ RIGHTS?
In any moment, as stated by the GDPR, the data subject has the right to obtain from Nitty-Gritty S.r.l.:
- confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data (art. 15 GDPR);
- correction of his or her personal data if it is incomplete or inaccurate (art. 16 GDPR);
- obtain the erasure of personal data (right to be forgotten) (art. 17 GDPR);
- deletion or restriction of personal data in certain circumstances provided by applicable law (art. 18 GDPR);
- an electronic copy of personal data (portability) (art. 20 GDPR);
- the right to withdraw his or her consent at any time (art. 21 GDPR).
To exercise your rights, you can contact the Controller at the addresses write above (Par. 2).
Furthermore, if data subjects believe that the processing of personal data referring to them carried out through this Site is violating the Regulation, they have the right to lodge a complaint with the supervisory authority (for Italy, Garante della Protezione dei dati personali: www.garanteprivacy.it), as required by art. 77 GDPR, or to act before the judicial authority (Article 79 GDPR).
SECTION 2 – COOKIES POLICY
1. WHAT’S A COOKIE?
Cookies are information stored by the browser when you visit a Web Site using a PC, smartphone, or tablet. Each cookie contains several pieces of data (e.g. the name of the server from which it originates, a numeric identifier, etc.). Cookies can remain in the system for the duration of a session (until the closing of the browser), or for long periods, and may contain a unique identifier.
2. WHAT ARE THEY USE FOR?
Cookies are used for different purposes, depending on their type: some are strictly necessary for the correct function of the Web Site (technical cookies), whereas others optimize performance in order to provide the User with a better experience while they are visiting the Web Site. In addition, cookies allow Web Site usage statistics to be obtained, such as cookies analytics; others are for the purpose of displaying advertisements (in some cases advertisements are targeted based on cookie profiling).
Technical and analytic cookies: our legitimate interests in running this Site properly and getting better performances.
Profiling cookies: your express consent.
The retain period changes referring to different type of cookies and their purposes
3. WHICH KIND OF COOKIES DO YOU USE?
a. Technical cookies (which DO NOT require your consent):
These cookies are necessary for the functioning of the Site and allow you to access its functions (so-called navigation cookies) or to authenticate yourself in the session.
The use of functional cookies is also envisaged, which allow you to store your preferences and settings, thus improving your browsing experience within the site.
To ensure their functionality, these cookies are not usually deleted when the browser is closed; however, they have a predefined duration (generally up to a maximum of 2 years) and after this period they are automatically deactivated. These cookies and the data they collect will in no way be used for other purposes.
The installation of technical cookies takes place automatically following access to the site or to activate certain features (eg by selecting the “remember me” option). At any time you can always decide to disable them by changing the settings of your browser: in this case, however, you may encounter some problems in viewing the site.
b. Analytical cookies (which may require your CONSENT):
These cookies keep track of the choices made on the site and data relating to navigation, in order to perform statistical analysis, in an anonymous and aggregate form. These tools can be used only after expressing the user’s consent. An exception to this rule is only the case in which the following circumstances occur:
– the IP address has been duly anonymized;
– the information obtained with analytical cookies refer to a single IT resource (site, app, etc.) and are used only in anonymous and aggregate form;
– the cookie provider does not combine the information with other processing and does not pass it on to third parties.
c. Profiling cookies (which require your CONSENT):
This site also uses profiling and third-party cookies, whose installation is subject to your prior consent.
Profiling cookies can include different categories, including advertising profiling, retargeting or Social cookies.
- Advertising profiling cookies: create a user profile that allows you to view advertising content in line with the preferences shown while browsing the site;
- Retargeting cookies: they are created in order to send you advertising content relating to the products in which you have expressed interest;
- Social cookies: this site provides for the installation of cookies relating to social network plug-ins. These cookies are managed directly by third parties and allow the display of advertising messages in line with your preferences.
When you access the site, through a special banner you will be informed of the presence of profiling and retargeting cookies and, through it, you can consent or not to their installation.
Of course, at any time you can revoke the consent previously given, without prejudice to the possibility of visiting the site and using its contents.
d. Cookies in detail
4. HOW TO DISABLE COOKIES?
Control via browser: The browsers commonly used (e.g. Internet Explorer, Firefox, Chrome, Safari) accept cookies by default, but this setting can be changed by the User at any time. This applies to both PCs and mobile devices like tablets and smartphones, and it is a function generally and widely supported.
Therefore, cookies can easily be disabled or turned off by accessing the browser’s options or preferences, and in general third-party cookies can also be blocked. As a general rule, these options will only have an impact on that browser and on that device, unless there are active options to synchronize the preferences on different devices. Specific instructions can be found on the Options page or Help page of the browser itself. Disabling technical cookies, however, may affect the full and/ or proper functioning of different sites, including this one.
Normally, browsers used today:
- offer the “Do not track” option, which is supported by some websites (but not all). Thus, these websites are no longer able to collect certain navigation data;
- offer the option of anonymous surfing or incognito mode: in this way, data will not be collected in the browser and browsing history will not be saved, but the navigation data may still be acquired by the operator of the Web Site that was visited;
- allow the deletion of cookies stored in whole or in part, but after visiting a Web Site again they are usually installed, where such possibility is not blocked.
Below are links to the support pages for the most popular browser (with instructions on how to disable cookies on these browsers):
– Firefox: (https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie);
– Internet Explorer e Microsoft Edge: (https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies );
– Safari: (iOS) on Mac (https://support.apple.com/it-it/guide/safari/sfri11471/mac) and portable (https://support.apple.com/it-it/HT201265#:~:text=Per%20cancellare%20i%20cookie%20senza,o%20disattiva%20la%20navigazione%20privata);
– Chrome: (https://support.google.com/chrome/answer/95647?hl=it).
Third-party cookies: When you access the site, through a special banner you will be informed of the presence of profiling and retargeting cookies and, through it, you can consent or not to their installation. At any time, you can revoke the consent previously given, without prejudice to the possibility of visiting the site and using its contents. The installation of profiling, retargeting, analytical and social cookies, including any other activity connected to them, is managed through third-party services. For more information and to enable or disable these cookies, you can access the information provided directly by third-party or using the methods described above (following the links listed in the previous paragraph).
On-line tools: You may note that from http://www.youronlinechoices.com/ you can not only learn more about cookies, but also check the installation of numerous cookies on your browser and/or device and, if supported, also disable them.