- Who processes your data
- Which data we use
- Where we collect your data
- Why and for how long we process your data
- Where are your data processed
- With whom we share your data
- Your rights
- What do we do if we change this policy
INFORMATION PURSUANT TO ART. 13 OF THE EU REGULATION N. 679/2016 (“GDPR”)
This Policy explains which of your personal data are collected by Armando Testa S.p.A. (hereinafter “we” or "Armando Testa"), for which purposes and how they are processed. You can also find below the necessary information to enforce your rights provided for by GDPR.
Generally, we collect your personal data if you create an account, when you use our services and products, when you email or call us or send us a message, when you use our websites, apps and social media. We inform you that the personal data collected during such processes will be used in order to reply to your queries, to allow you to use the services and products provided by Armando Testa, to carry out marketing activities, to provide customer support and to carry out analyses in order to ensure you have a customized user experience on the website, as specified below.
1. Who processes your data – Data Controller
Armando Testa S.p.A., with registered office in via Luisa del Carretto n. 58, 10131 - Torino, Italy, is the Data Controller of the processing of your personal data, necessary to provide you with the services and products of Armando Testa and, upon your consent, for marketing purposes, consistently with the purposes and modalities indicated below.
Armando Testa’s Data Protection Officer (“DPO”) can be contacted via email or at the above address.
2. Which data we use – type of processed data
During normal use, the electronic systems and software procedures enabling this Site to operate, acquire certain personal data; transmission of same is implicit in the use of internet communication protocols.
The category of data could be listed as follow: (i) IP addresses of computers used by users connecting to the Site, (ii) addresses in URI (uniform resource identifier) notation for resources requested, (iii) the time of request, (iv) the method used to submit the request to the server, (v) the dimension of the file obtained in response, (vi) the numerical code indicating the status of the response given by the server (success, error etc) and (vii) other parameters regarding the user's operating system and the IT environment.
These data are recorded in special log and could only be communicated to the Judicial Authority, in case of relevant information security events.
Otherwise are deleted from the system no later than one working week.
3. Where we collect your data – Data collection methods
4. Why and for how long we process your data – Purpose and legal basis of processing – Data retention period
To prevent or assess unlawful conducts, to protect and enforce our rights. For example, we may use your data to prevent or prosecute infringements, including of our - and third parties’ - intellectual/industrial property rights, or to prevent or prosecute cybercrimes or crimes committed through the internet. The legal basis of such processing is the legitimate interest of Armando Testa to protect its rights and to prevent criminal offences. The retention period of your data is equal to the time reasonably necessary to enforce our rights from the moment we become aware of the offence or of its potential commission.
To obtain information on the use of the website. When you browse our website, even when you do so without being registered or having logged in, the software procedures and the computer system controlling the functioning of the web applications acquire, during their normal operation, some data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified data subjects, but due to their very nature they could, through processing and associations with data held by the Data Controller or by third parties, allow users to be identified.
In case of unregistered users, geographical location data and data related to how the website is used will only be used in an anonymous form that does not in any way allow, even in combination with the Unique Device Identifier (UDID), the MAC address, the IMEI or IMSI codes or other customer codes, to trace, directly or indirectly to your identity, unless you allow us to use your data at the moment of registration with explicit consent. In such case, we shall connect your browsing data used in an anonymous form in the previous 30 days to your identity.
This category of data includes IP addresses or domain names of the devices used by users connecting to the application, the addresses in URI (Uniform Resource Identifier) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code given by the server indicating the status of the response (successful, error, etc.), the visited sections of the website, the type of device used, the country from which you connect and other parameters related to the operating system and the user's computer environment. Armando Testa uses this information solely to allow navigation on its websites and to process the operations normally related to the use of the website. The legal basis of this processing is the legitimate interest of Armando Testa to communicate with the public through telematic networks. The retention period of the information that could potentially allow the identification is 30 days from access to the website.
What are cookies. Cookies are small text files that the websites visited by users send to their terminals, where they are stored before being re-transmitted to the same websites during subsequent visits.
Cookies used by Armando Testa’s website and their purpose.
The first time you will visit the website, you will be asked to accept (or not accept) the cookies through a banner. You may refuse to accept all or some of the cookies or you may modify, also in the future, your computer settings in order to know when you receive cookies or to be able to deactivate the function of automatic acceptance of the cookies.
The website uses the following cookies categories:
• Technical cookies (or browsing cookies), which contribute to the functioning of the website, for example to allow to browse through the pages and access the reserved area of the website; the legal basis of the processing underlying the use of these cookies is Armando Testa’s legitimate interest in providing efficient and well-functioning services to its customers; the retention period of these cookies starts from the date of the first access to the website until they are disabled.
• Profiling cookies, which allow us to customize advertising messages according to your interests and your preferences, in order to only send you advertisements that you may consider relevant or interesting. The legal basis of the processing underlying the use of these cookies is the consent of the data subject; the retention period of these cookies starts from the date they are enabled to the website until they are disabled, and in any case no more than 12 months.
|JSESSIONID, __canI_TH||Technical||Improve navigation||www.armandotesta.it/en/privacy.jsp|
|GATCookieLaw||Technical||Register the acceptance of cookie management and prevent the informative banner appearing after the first time||www.armandotesta.it/en/privacy.jsp|
|_ga, _gat, _gid||Technical / Google Analytics||Navigation statistics||https://support.google.com/analytics/answer/2763052?hl=it|
|_TA, _TA_TRACKING||Profiling / Thron||Register users’ preferences in video reproduction on website||https://www.thron.com/it/privacy-policy/|
|__utma, __utmb, __utmc, __utmt_UA_44338784_17, __utmv, __utmz||Profiling / Google Analytics||Statistics on video visualizations||https://www.google.com/analytics/terms/it.html|
How to deactivate technical cookies.
Here below you will find the links that explain how to deactivate the cookies from the most common browsers (for other browsers, if used, we suggest you to search for this option in the help section of the software, normally available through the F1 key): Internet Explorer: click on the Settings button, then on Internet Option. Click on the Privacy tab and, in the settings, if you move the settings bar to the very top all the cookies will be blocked.
Google Chrome: click on the menu in the toolbar of the browser. Select Settings, click on advanced settings. In the “Privacy” tab, click on the Content Settings button. Deselect the button “Allow sites to save and read cookie data”.
Mozilla Firefox: click on the menu button and select Options. Select the Privacy tab. In History Settings: select “use personal settings”. To activate the cookies, mark “accept cookies from sites”; to deactivate the cookies, remove such mark.
Safari: click on the menu toolbar on “Safari”, then in “”Preferences”. Now click on “Privacy”, then on “Details” to select the website, then select “Remove”.
Alternatively, you can disable ony the cookies of Google Analytics, by using the opt out extension provided by Google for the main browsers https://tools.google.com/dlpage/gaoptout?hl=it
6. Where are your data processed – Transfer of data
The data will be processed and stored at our offices in via Luisa del Carretto n. 58, 10131 - Torino, Italy.
As anticipated, for internal administrative and organizational purposes and to provide you with customer assistance, we may communicate your data to companies belonging to the Armando Testa’s group, operating in the United States and which have entered into with Armando Testa agreements in compliance with art. 28 GDPR with standard data protection clauses approved by the European Commission.
7. With whom we share your data – recipients of the personal data
With service providers. Armando Testa uses third-party services (clouds, customer care, analysis, profiling, research, hosting, browsing functionalities, use of the app and of the website and components of Armando Testa’s products and services) that operate as data processors pursuant to agreements in compliance with art. 28 GDPR. When such providers operate from a third country, they do it on the basis of standard contractual clauses in compliance with the decision of the European Commission relating to the data protection clauses or by virtue of an adequacy decision of the European Commission on the level of data protection (Privacy Shield). These subjects acquire only the personal data necessary to fulfil their functions and may use them only for the purpose of performing these services on our behalf or to comply with the law. The updated list of third-party suppliers, operating as data processors pursuant to art. 28 GDPR, is available by sending a request to email@example.com.
With other companies belonging to the Armando Testa’s Group. Your data may be shared with other companies belonging to Armando Testa’s group either for internal administrative and organizational purposes or to provide you with the services you have requested or with customer assistance. Up-to-date data on Armando Testa companies recipients of your data are available by sending a request to firstname.lastname@example.org.
With judicial or administrative authorities. Where we believe we have to do so to comply with an order from the judge or from an authority, or to comply with legal obligations or in order to protect us or third parties judicially, we may disclose your data to the Judicial Authority or to a Governmental Agency in Italy or the European Union.
Armando Testa does not process the personal data of minors under the age of 16. In the event that Armando Testa becomes aware that it has collected personal data from users under the age of 16, it will take the necessary steps to delete such information as soon as possible.
9. Your rights
In addition to managing your preferences on processing of your personal data in accordance with the previous paragraphs, you can contact Armando Testa to request access to your personal data, rectification, erasure of the same or restriction of the processing, to object to the processing and ask for the portability or the copy of your data; you can also revoke the consent at any time (this will not affect the lawfulness of the processing based on the consent given before the revocation).
You have the right to lodge a complaint with the Authority for the Protection of Personal Data and to ask to the data controllers, at any time, information about the data processors and the persons authorized by the data controllers to process your data.
You can exercise your rights by contacting Armando Testa via email at email@example.com or at firstname.lastname@example.org or by writing to the address indicated above.
Version updated as of December 13 2018.