The data controller is Peck S.p.A., having its registered office in Milan (Italy), Via Spadari, 9, Fiscal Code/VAT No. 09828820150 (hereinafter, the "Company").
a) Surfing data
b) Data provided by the Visitor voluntarily
The optional, express and voluntary sending of electronic mail to the addresses specified in this Website or the completion of personal data collection forms imply the following acquisition of the sender’s address, necessary in order to answer to the relevant requests, and of the other personal data (if any) sent/inserted.
Modalities of processing
The personal data are processed by means of manual and data processing instruments, for the period strictly necessary in order to achieve the purposes of the collection thereof.
Purposes of processing
The surfing data will be processed only in order to allow the Visitor to surf the Website and avail himself/herself of the contents of the same, as well as to originate statistics related to the use of the Website. The personal data voluntarily granted by the Visitor are processed exclusively in order to execute the requests made by the Visitor.
Scope of communication and dissemination
Any subjects appointed from time to time by the Company as data controllers or data processors may become aware of the Visitors’ personal data. The personal data will not be communicated to third party data controller nor disseminated.
Data subjects rights
The Company hereby informs that, pursuant to Article 7 of the Legislative Decree 30 June 2003 No. 196, applicants have specific rights that can be exercised at any time whatsoever. The data subjects have the right to be informed of the existence or non-existence, as the case may be, of the source and contents of the personal data, to verify the correctness of the same, to request updating, rectification or integration of the data (Article 7 of Legislative Decree No. 196/2003). Pursuant to the same Article, furthermore, data subjects have the right to request erasure, anonymization or blocking of data that have been processed unlawfully and to object, on legitimate grounds, to the processing of personal data concerning the same. The requests shall be addressed to the data controller, even through the contacts area of the Website.
1. 1. Purposes of processing
The Users’ personal data will be processed by Peck for the sole purpose to comply with the User’s request to receive the Website newsletter.
Consent for the processing of personal data for the above purposes is not mandatory, but it is necessary since, in the event that such consent is not granted, the User will be prevented from receiving the Website newsletter.
Even if the consent has been granted, an User may withdraw the same at any time whatsoever, upon request to Peck by means of the modalities set forth under the following paragraph 5. An User may also easily object to further sending of the newsletter also exercising the so called opt-out right by the modalities specified in each kind of communication. Once the consent has been withdrawn, Peck will send to the User an electronic mail message to confirm the occurred withdrawal of the consent.
2. Tracking system
Peck hereby informs Users that MailUp, i.e. the company managing the sending platform of the newsletters, uses a transparent image of a pixel that turns on the opening counter of the newsletter once downloaded. Such system is of use for calculating the number of newsletters actually opened by the Users in aggregate and anonymized form.
3. Modalities of processing
The Users’ personal data processing will be made by means of manual and data processing instruments, applying logics strictly related to the purposes of processing and, in any case, so to guarantee the safety and privacy of such data.
4. Scope of communication and dissemination of data
Employees and/or workers of Peck entrusted with the management of the Website and/or of the newsletter may become aware of Users’ personal data. Such subjects, formally appointed by Peck as “persons in charge for the processing”, shall process the User’s data exclusively for the purposes specified hereunder and in compliance with the Privacy Code.
Furthermore, third subjects that may process the personal data for the account of Peck in their capacity as “third party data processors”, such as, including but not limited to, data processing and logistic functioning services providers for the Website operations, outsourcing or cloud computing services providers, professionals and advisors, companies appointed for sending the newsletters for the account of Peck, may become aware of Users’ personal data. Users have the right to obtain a list of the data processors appointed by Peck (if any), upon request to Peck by means of the modalities specified under the following paragraph 5.
The Users’ personal data will not be disseminated in any manner whatsoever.
5. Data subjects’ rights
Pursuant to Article 7 of the Privacy Code, Peck hereby informs the Users that they have the right to be informed of (i) the source of the personal data; (ii) of the purposes and methods of the processing; (iii) of the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) of the identification data concerning data controller and data processors; (v) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated data processor(s) or person(s) in charge of the processing. Furthermore, Users have the right to obtain a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. Users shall have the right to object, in whole or in part, on legitimate grounds, to the processing of personal data concerning the same, even though they are relevant to the purpose of the collection. Users may exercise the foregoing rights contacting Peck by means of: (i) a registered letter with return receipt addressed to the registered office of Peck, (ii) sending an e-mail in the contacts area of the Website or by fax to the following fax No.: +39 02 860408.
This is an English working translation of the original Italian version. In event of any discrepancies, the original Italian version will prevail.