Information on the protection of personal data, for consumer customers and other individuals who exercise professional or business activities.
Your privacy counts for us: so you can count on us!
We have compiled this privacy statement in compliance with the Regulation (EU) 2016/679 (GDPR), with current legislation and with the EU Directive on Cookies. We have drawn it up in a simple and understandable way, to help you understand who we are, what data we collect about you, and what we do with it. We want you to be aware that your personal data (hereinafter, simply "data" or "your data") consists of any information or set of information from which it is possible to identify you, directly or indirectly... in particular with reference to identifiers such as name and surname, e-mail address, telephone number, etc.
Please consider that since this is a general information sheet, you may find more specific information in relation to the different products and services we offer in other parts of the site, where we may also provide specific information in relation to specific data processes. Please take the time to read the entire statement, so that if you do not agree with how we process personal information, you can avoid providing it to us.
What is this privacy statement for?
It explains the way in which we collect and use (i.e. process) your data, for example:
- when you visit or use our website; when you buy or use our products
- when you register for our newsletter
- when you provide us with products or services;
- when you contact our customer service; or when in any other way you interact with us as buyer, customer, consumer, business partner, supplier, contractor, professional or as an employee of another company that has business relations with us or contacts us in any other capacity, or in any role you play in a commercial relationship with us.
Who we are
When this statement says "we" or "the company", it refers to the ‘owner’ of the personal data we are given, namely FMN Martinelli S.p.A., Loc. Piani di Mura, 2, 25070 - Casto (BS).
What types of data do we collect?
We collect data from you when you interact with us. You give us personal data when, for example, you conclude a contract with us, or contact us to buy our products. But we also collect your data automatically when, for example, you use our website, or by means of cookies.
What types of data do we collect about you?
Depending on who you are (customer, consumer, supplier, commercial partner, etc.) and how you interact with us (e.g. online, offline, by phone, etc.) we may process different data. For example, we may collect your information when you visit our site or subscribe to our newsletter, when you purchase our products, use our services, provide us with goods or services, contact our customer service, or interact with us in some other way.
Below you will find an overview of the categories of data we may handle and process:
Information you provide directly:
|Data categories||Examples of data types|
|Identification data||Name, surname, title, date of birth|
|Contact details||E-mail, telephone number, address, country|
|Banking data||Bank current accounts, data related to payments made with credit cards|
|Any other information that you decide to share with us in Feedback, opinions and reviews||Feedback, opinions, reviews, and any information you provide to us via any means|
Information we collect automatically:
When you visit or use our website, or interact with us through our digital channels, or when you register with our newsletter or in any other way, we may collect – in addition to the information you provide us directly – information that is automatically sent to us by your computer, your mobile phone or other devices that you use to access our channels.
|Data categories||Data types|
|Device information||Model, IMEI code and other specific identifiers of MAC address devices, IP addresses, operating system version, and device settings that you use to access various services|
|More information about your use of our digital channels or newsletters||The apps you use to send us data or express consent when you attend exhibitions or other event|
Cookies are text strings which become stored in your browser. They can be used for different purposes, both for technical reasons (they help you to navigate the site correctly) and to track users. We use only technical and functional cookies, and we use anonymised third-party analytical cookies. These cookies are similar to technical cookies and, since they are not used to send you profiled advertising, we do not need your consent to use them.
In particular we use:
- Shinyshat: anonymised cookies by Shinystat (find out more information here: https://www.shinystat.com/it/informativa_privacy_generale.html).
- Google Analytics: measures site performance (more / less views, more / less clicked items, number of visitors, most searched words, etc.). Please note that with Google Analytics, users’ IP address is rendered anonymous.
In particular, the following cookies are used:
- type: _ga – duration: 2 years - What's it used for? It is used to distinguish users who browse the website.
- type: _gid – duration: 24 hours - What's it used for? It is used to distinguish users who browse the website.
- type: _gat – duration: 1 minute - What's it used for? It is used to block the number of requests by analysis scripts, in order to consider each user's visits as unique.
On this page https://www.google.com/analytics/learn/privacy.html?hl=it you can find more information concerning the Google Analytics service.
Finally, to protect their rights, the user is informed about the possibility offered by Google (via the add-on at the following link https://tools.google.com/dlpage/gaoptout?hl=it)
Finally, to protect their rights, the user is informed about the possibility offered by Google (via the add-on at the following link https://cookiepedia.co.uk/cookies/has_js)
Do we transfer your data abroad?
We transfer your data abroad, but protect it through various legal, organisational and technical measures.
When do we transfer your data abroad?
Your data may be processed in countries where you do not live, if this is necessary for the purposes we have indicated in this statement. If you live in the European Economic Area, you should know that your data can be processed outside the EEA: this mostly consists of data that we process through the newsletter management service. All of this data may be processed in the United States, but only by companies adhering to the Privacy Shield, a protocol that provides a guarantee of protection for your data, and which has been validated as effective by the EU Commission.
How long do we process your data for?
We process your data until the purpose for which we have collected it has been accomplished, but sometimes we may need to use certain data beyond that limit, if the law requires this.
How long do we keep your data for?
We keep your data for the time necessary to implement the purposes for which it was collected, (for clarification on legal purposes, see the paragraph "How do we use your data?"). Please keep in mind that in some cases a longer data storage period may be permitted or required by law.
The criteria for determining the storage period include:
- How long do we need the data in order to provide you with a product or service, or to perform our activities?
- Have you revoked the consent you gave us (for the kinds of processing where consent is needed, such as those for marketing purposes)?
- Are we subject to a legal, contractual, administrative or similar obligation regarding the storage of your data? For example, when there are regulations that require data retention, or judicial orders to preserve relevant data in an investigation, or when data must be stored in order to enforce a right in court.
Why do we collect your data?
We use your data to provide you with the best possible experience, plus to improve our products and provide customer support.
How do we use your data?
We may use your data for various legitimate reasons and purposes related to our company’s activities. Here are the purposes for which we process your data:
|Conclusion and execution of contracts||Sales, invoicing, shipment of products, guarantees, communication services, pre-contractual activities|
|Providing you with assistance (at your request)||Providing you with assistance through our communication channels|
|Direct marketing||Sending you commercial and promotional communications|
|Security and protection of our interests or assets||Developing and maintaining technical and organisational security measures, conducting internal audits|
|Legal Obligations||Providing data and information to competent authorities or to data protection supervisory authorities, in accordance with current legislation – for example for tax or insurance obligations, or obligations to store records and reports – conducting regulatory compliance audits, complying with inspections and requests from governments or authorities, fulfilling procedural requests – for example regarding witness obligations – and managing internal complaints|
|Defence in court||Acting or defending ourselves in court|
If we ask you to provide us with your data, but you decide not to do so, we may not be able to guarantee that you can use our products or services. Or we may not be able to respond to your requests.
Do we use your data for marketing purposes?
We may regularly send you commercial communications about our products, services, events and promotions. These communications could reach you through different channels: email, telephone, text messages, paper mail or social networks run by third parties. In order to provide you with the best personalised experience, some of these communications may be modelled on your preferences (for example, if you have indicated them to us, or if we found them from your visits to our sites, or based on clicks to links in emails that we sent you).
Note that we request your consent before starting the activities indicated above. The consent that you provide on accepting commercial communications related to our products or services (direct marketing) through automated methods (SMS, emails, MMS, calls without operator) also extends to traditional methods (paper mail and operator calls). You always have the option of revoking the consent that you have given us, in whole or in part, and without any costs. If you do not specify that the revocation refers only to certain contact modalities, it will be considered as extending to both automated and traditional modes. Finally, even if you do not consent to receive communications via the automated methods mentioned above, you can always ask us to send you traditional commercial communications.
If we acquire your e-mail address while selling something to you, we can use it to send you commercial or promotional communications for products similar or identical to those you already purchased, unless you object to this. In this case we do not need your consent, because direct marketing within these strict limits is considered a legitimate interest, being a faculty that the law grants us (article 130 paragraph 4 Privacy Code s.m.i.) In any case, you can always object to receiving marketing messages of any kind: in particular for e-mails, just follow the unsubscribe instructions provided at the bottom of each e-mail.
You can always contact us (you will find our contact details in the section "What are your rights?) if you wish to avoid receiving marketing communications, or to request that they are sent to you only in traditional ways.
Please note that even if you decide not to receive marketing communications, you will continue to receive our administrative communications, and that if you do not consent to marketing uses (or do not give us the relevant data), this will not affect your ability to purchase our products or receive the information you ask for (you only need to provide the data necessary to complete the purchase or send your feedback).
What is the legal basis for us processing your personal details?
To treat your data lawfully, we can cite various different legal justifications:
- Your consent (only when required or permitted by law, for example for commercial communications). If we use consent as a legal basis to process your data, you can withdraw it easily and without cost at any time;
- The need to conclude a contract with you and fulfill the obligations arising from it;
- The need to comply with obligations imposed on us by law, or to exercise a right or defend ourselves in court; The need to pursue a legitimate interest, such as:
- making sure that our network and our information are secure;
- enabling our administrative and accounting needs;
- preventing suspected violations of the law or investigating violations of the law that have taken place, likewise contract violations with business customers or non-compliance with policies or principles that we adhere to and impose on our suppliers and business partners (e.g. Ethical Codes and quality standards);
- direct marketing needs, by making use of our right to send you commercial information pursuant to article 130 paragraph 4 of the Privacy Code s.m.i;
- to provide you with the newsletter you freely registered for;
- to respond to a request from you.
How do we protect your data?
We protect your data with appropriate technical and organisational procedures.
To protect your data, we take suitable measures in compliance with applicable legislation, including insisting that our service providers use effective measures to keep your personal information confidential and to keep your data secure. Depending on technological updates, implementation costs and the nature of the data to be protected, we carry out technical and organisational procedures to prevent your data being destroyed, lost, modified, disclosed or accessed without authorisation.
Do we share your data?
We will only share your information when required by law, or when you have expressly agreed to it, or else to offer the services you have requested.
When do we share your data?
We share your personal details with others only in the cases indicated below. If it is necessary for the pursuit of the purposes set out in this statement, we may communicate your data to the recipients indicated below.
- Suppliers: we may outsource certain services to third parties whom we trust to provide us with features and services, such as providing ICT services, shipping or consultancy;
- In particular, our website, is hosted by Dexanet SRL 2018 - P.le Europa, 43 - 25068 Sarezzo (Brescia), which we have specifically appointed as our data controller;
- Business partners: we can share your data with reliable business partners, so that they can provide you with the service you require, for example to reply to an email you send us we need to use an email provider;
- Public and government authorities: when required by law, or when it is necessary to protect our rights, we can share data with the competent bodies;
- Companies, professionals and consultants: we can share your data with professionals and consultants such as banks, insurance companies, lawyers or accountants;
- Other parties, during corporate transactions: in the case of corporate transactions or sales of company branches, we may share your data with other companies or groups of companies... depending on the different kinds of transaction taking place, whether purchase or sale of the company or a company branch, whether corporate restructuring, mergers, takeovers, joint ventures, or any other company or corporate transaction (including bankruptcy or settlement or similar bankruptcy proceedings);
We encourage you to keep control of your data: please keep your information updated and accurate.
What should you do or not do?
What are your rights?
We provide you with access to your data. You can check your data by asking us to update it, modify it or – if the law permits –, delete it. We advice you to check your data regularly. You can still always contact us if you want to...
- access, revise, modify or delete the data you have provided (if we are no longer allowed to keep it or are not obliged to keep it);
- oppose certain data uses;
- receive a copy of your data (in a readable format in common use)
- ask us to limit the use of your data (if applicable) and any other information regarding the protection of your data.
Our contact details are:
- Paper mail: FMN Martinelli S.p.A., Loc. Piani di Mura, 2, 25070 - Casto (BS)
- Online e-mail: firstname.lastname@example.org
Law of Opposition: you can always oppose data processing if your opposition is based on legitimate interest. We will follow up on your request by evaluating the possible prevalence of our legitimate interest over your interests or fundamental rights and freedoms.
We do our best to respond to requests on time and without cost, except when this requires a disproportionate effort. In some cases we may ask you to prove your identity before carrying out your request. If you are not satisfied with our response, you can make a complaint to the competent supervisory authority in your country.
Do we treat the data of minors?
We do not treat the data of children aged under 16. We do not offer services involving data processing of adolescents under the age of 16 based on consent, for which parental permission is required.
When will this information statement be updated?
Over time, data processing activities can evolve and change, and the information statement that reflects this may be changed.