ZEHUS | Privacy Policy
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Website Privacy Notice

1. Introduction

Zehus S.p.A. (“Zehus”), with registered office in Corso Italia 8, Milan (Italy) which can be contacted at the email address privacy@zehus.it, process – in its capacity of data controller – personal data provided by the user (the “User”) of the website www.zehus.it (the “Site”) with regard to the use of the Site and the provision of the requested services available on the Site (the “Services”).



2. What and who do this Privacy Notice cover?

Zehus is the data controller of the Personal Data (as defined below) that is processed in compliance with the terms of this privacy notice (the “Privacy Notice“) and the relevant provisions of law. Accordingly, this Privacy Notice applies to all Users.



3. What kind of personal data does Zehus Italy collects about the user?

Zehus collects the following categories of personal data:

  • browsing data related to Services offered through the Site and collected through cookies, according to  the Cookie Policy available at this link http://www.zehus.it/cookie-policy/;
  • data provided in case of request of information or assistance on the part of the User

(jointly defined “Personal Data“).


4. How does Zehus use Personal Data?


Zehus processes Personal Data for the following purposes:

 

a)     the provision of the Services offered through the Site, including the provision of responses to the User’s requests of information or assistance;

b)     compliance with the applicable national/EU laws and/or respond to requests from public and government authorities;

 

(the purposes from letters a) to b) are jointly referred to as “Contractual Purposes“)

 

c)     development and improvement of the Services offered through the Site;

d)     to exercise or defend legal claims in court proceedings or in an administrative or out-of-court procedures; and

e)     to complete a potential merger, sale of assets or transfer of all or a material part of its business, by disclosing and transferring the Personal Data to the third party or parties involved in the transaction as part of the transaction;

 

(the purpose as per letters from c) to e) above are jointly referred to as “Legitimate Interest Purposes“).



5. On what legal basis does Zehus process the Personal Data?

The processing of the Personal Data is necessary with regard to the Contractual Purposes as it is essential:

 

  • for the provision of the requested Services with regard to the cases as per Section 4 letter a);
  • in order to comply with provisions as provided by the applicable laws as per Section 4 letter b).

 

Should the User not provide its Personal Data with regard to the Contractual Purposes, Zehus will not be able to provide the User with the Services.

 

The processing of the Personal Data with regard to the Legitimate Interest Purposes as per Section 4 letters c) to e) is carried out pursuant to article 6, letter f) of the EU General Data Protection Regulation No. 679/2016 (the “Privacy Regulation”), for the pursuit of Zehus legitimate interest, which is adequately balanced with the User’s interest since the data processing is performed within the limits strictly necessary to perform such economic activities. This data processing activity with regard to the Legitimate Interest Purposes is not mandatory and the User can object to the data processing at any time through the modalities as per Section 10 of this Privacy Policy. In such case no data processing will be carried out by Zehus, except in case where Zehus demonstrates the existence of legitimate prevailing arguments or the processing is necessary to exercise or defend Zehus’ rights pursuant to Section 21 of the Privacy Regulation.

 


6. How does Zehus process the Personal Data?

Personal Data will be processed both electronically and/or manually, in any case in such a way as to guarantee the security, protection and confidentiality of the data, thanks to appropriate administrative, technical, personnel and physical measures against loss, theft and unauthorized use, disclosure or modification.



7. Who can have access to the Personal Data?

For the Contractual Purposes, the Personal Data may be transferred to the following categories of recipients located both within the EU and, within the limits as per Section 8 below, outside of the EU:

a)     third parties service providers entrusted with processing activities that provide services or assistance and advice to Zehus, with special – but not exclusive – reference to technology, accounting, administrative, legal, insurance, IT matters;

b)     companies of the Zehus group; and

c)     persons and authorities whose right to access Personal Data is recognized by law, regulations or provisions issued by legally empowered authorities.

For the Legitimate Interest Purposes, Personal Data may be transferred to the following categories of recipients located both within the EU and, within the limits as per Section 8 below, outside of the EU:

a)     third parties service providers entrusted with processing activities,

b)     companies of the Zehus Group,

c)     potential purchaser of Zehus and the entities resulting from mergers or any other transformation involving Zehus,

d)     competent authorities.

A complete list of the data processor appointed by Zehus is available upon request through the modalities as per Section 10 below.



8. Is the Personal Data transferred abroad?

The Personal Data will not be transferred to countries outside the European Economic Area.



9. Which is the retention period applying to the Personal Data?

Personal data of the User will be stored for the period necessary to fulfil the purposes for which the data was collected as outlined in this Privacy Notice. In any case the following retention periods will apply to the processing of the Personal Data for Contractual Purposes and for Legitimate Interest Purposes is retained during the provision of the Services plus a period of 10 years after the termination of the Services, except when the detention of the data is necessary to respond or to file a legal actions, upon request of the competent authorities or in compliance with the applicable laws.



10. What are the user’s rights with regard to Personal Data?

The User, at any given time, can exercise the following rights, by sending an email to the following address privacy@zehus.it:

a)     to obtain from Zehus confirmation of the existence of Personal Data and to be informed of its content and source, verify its accuracy and request its integration, update or amendment;

b)     request the erasure, anonymisation or restriction of the processing of Personal Data processed in breach of the applicable laws;

c)     to withdraw the consent to the processing of the data (if and to the extent such a consent is necessary);

d)     request Zehus to limit the processing of the Personal Data where:

  • the User contests the accuracy of the Personal Data until Zehus have taken sufficient steps to correct or verify its accuracy;
  • the processing is unlawful but you do not want us to erase the Personal Data;
  • Zehus no longer needs the Personal Data for the purposes of the processing, but the User requires them for the establishment, exercise or defence of legal claims; or
  • The User has objected to processing justified on legitimate interests, pending verification as to whether Zehus has compelling legitimate grounds to continue processing.

e)     object to the processing of the Personal Data, except in case where Zehus demonstrates the existence of legitimate prevailing arguments or the processing is necessary to exercise or defend Zehus’ rights pursuant to Section 21 of the Privacy Regulation;

f)      request the erasure of the Personal Data without undue delay;

g)     receive an electronic copy of the Personal Data, if the User would like to port its Personal Data to itself or a different provider, when Zehus is relying upon the User’s consent or the fact that the processing is necessary for the provision of the Services and the Personal Data is processed by automatic means; and

h)     lodge a complaint with the relevant data protection supervisory authority.



11. Data of users under 18

The Site is not addressed to users under age of 18 and, in any case, Zehus does not collect and process wittingly Personal Data referred to users under age of 18. In case Zehus is aware of the collection and processing of such Personal Data, Zehus will delete it immediately.



12. Updates

This privacy information notice might be subsequently updated or integrated, also as consequence of the adoption of local legislations implementing the Privacy Regulation. Changes will be notified in advance and in any case Users will be able to review the updated version of the privacy information notice on the website www.zehus.it.



Date Last Modified:
This Privacy Policy was last modified August, 7th, 2018

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