Zehus S.p.A., with registeredoffice in Viale Don Luigi Sturzo 45, 20154, Milan (Italy) which can be contacted at the email address email@example.com,(the “Company” or “Zehus”) processes – in its capacity of data controller – personal dataprovided by the user (the “User”) of the website www.zehus.it(the “Website”), with regard to the use of the Website and the provision of therequested services available on the Website (the “Services”), incompliance with the terms of this privacy notice (the “Privacy Notice”).
2. Which categories of personal data does Zehus collect?
The Company processes personal datavoluntarily provided by the Users, in the context of their interactions withthe Website, and in particular:
a) data voluntarily provided byUsers, in connection with the forwarding of any requests for information orassistance or the sharing with Zehus of comments on the products and servicesoffered by the Company, by means of the Website ("Identification Data");
(collectively referred to as "PersonalData").
3. What are the purposes of the processing?
The Companyprocesses Personal Data to pursue the following purposes:
a) To provide the Services offeredthrough the Website, including the possibility of obtaining answers to the requestsfor information or assistance submitted by the User (hereinafter "ContractualPurposes");
b) To comply with the obligations setforth by applicable laws, including possible addressed to the competentauthorities and supervisory bodies as well as the response to possible requestssubmitted by such authorities to Zehus (hereinafter "Law Purposes");
c) To develop and improve the Servicesoffered through the Website;
d) To exercise or protect the rights ofZehus in court proceedings or in an administrative or out-of-court procedures; and
e) To carry out activities functional topossible mergers, acquisitions, sales of assets, or the transfer of itsbusiness, in whole or in part, and execute such operations;
(the purpose listed under lettersfrom c) to e) above are jointly referred to as “Legitimate Business Interest Purposes”).
4. On which legal basis does Zehus process the Personal Data?
The processing of Users’ Data for Contractual Purposes is necessary to allow Users to use the Services offered onthe Website and Zehus to respond to any requests for information or assistance submitted by Users, as well as to any comments that Users may upload on the Website. In particular:
· With regard to Browsing Data, thecomputer systems and software procedures used to operate this Website acquire,in the course of their normal operation, certain personal data whosetransmission is implicit in the use of the Internet communication protocols.This information is not collected to be associated with specific individuals,but given its nature, this information could allow the Users to be identified,by processing and associating it with data held by third parties. Therefore,the collection of Browsing Data is performed automatically, while Users browseon the Website, and their transmission to Zehus is mandatory in order to usethe Website;
· Identification Data arespontaneously provided to Zehus by the Users who wish to request information orassistance, as well as to share their comments with Zehus. Therefore, the provisionof Identification Data is entirely optional, but if the User chooses to provideIdentification Data to Zehus, their processing is mandatory, otherwise Zehuswould not be able to provide the information or assistance requested by Users norto take into account the comments voluntarily uploaded by Users.
The processing of Users’ Personal Datafor Law Purposes is mandatory, as it is necessary to enable Zehus to complywith applicable laws.
The processing of Users' Personal Datafor Legitimate Business Interest Purpose is carried out pursuant to Article6(f) of the Regulation (EU) 2016/679 (so called the "GDPR"),in pursuing the Company's legitimate interest (and, in the case referred to inparagraph 3(e), also the legitimate interest of the Company's contractualcounterparties) to:
· Develop and improve the Website andthe related Services;
· Protect their rights; and
· To carry out activities functional topossible mergers, acquisitions, sales of assets, or the transfer of itsbusiness, in whole or in part.
The processing of Users PersonalData for Legitimate Business Interest Purposes is not mandatory and Users mayobject to such processing in the manner set out in paragraph 9 below, unlessthe Company or its contractual counterparties (in the case referred to inparagraph 3, letter e)) have an interest which prevails over that of the Users,in performing the processing of the Personal Data or where the Companyprocesses Personal Data in order to protect its rights.
5. Who can have access to Personal Data ?
For the purposes referred to in paragraph 3 above, the Personal Dataprovided by Users may be disclosed or communicated to the following categoriesof entities, which are located within the European Union:
i. employees and/or workers of the Company, in theperformance of their duties or contractual obligations, inherent to therelationship with the Users;
ii. third party suppliers, providing assistance orconsultancy services to Zehus, including but not limited to to technological,accounting, administrative, legal and insurance services;
iii. companies of the group to which Zehus belongs;
iv. entities (including Public Authorities) that mayaccess to Personal Data under applicable laws; and
v. with specific reference of the Legitimate BusinessInterest Purposes set out in paragraph 3(e) above, to potential purchasers ofthe Company and entities resulting from the mergers or any other transformationaffecting the Company.
6. Are the Personal Data transferred abroad?
Personal Data will not be transferred to countries outside theEuropean Economic Area.
7. How does Zehus process the Personal Data?
Personal Data will be processed by means of electronical and telematictools as well as hard copies, in such a way as to guarantee the security,protection and confidentiality of Personal Data. Personal Data will beprocessed in such a way as to minimize the risks of destruction, loss, unauthorizedaccess to Personal Data or their unlawful processing as well as the processingof Personal Data for purposes other than the ones indicated above.
8. Which is the retention period applicable to the Personal Data?
Users’ Personal Data will be retained only for the time necessaryto pursue the specific purposes for which they were collected, as indicated withinthis Privacy Notice. In particular,
· Identification Data collected for Contractual Purposes andLegitimate Business Interest Purposes will be retained for a period equal tothe time necessary to provide the relevant Service (including any renewals) andfor 10 years after its termination, except in cases where the retention for alonger period is required for any litigation, requests from competentauthorities or pursuant to applicable legislation; while
· Identification Data collected for Law Purposes will be retainedas long as required under applicable laws.
9. Rights of the Users
Users can exercise the following rights, at any giventime and for free, by sending an email to firstname.lastname@example.org:
· Obtain from Zehus the confirmation of the existence ofPersonal Data and to be informed of its content and source, verify its accuracyand request its integration, update or rectification;
· Request the erasure, anonymization or restriction of theprocessing of Personal Data processed in breach of applicable laws;
· Request Zehus to limit the processing of the PersonalData where: (1) The User contests the accuracy of the Personal Data, untilZehus have taken sufficient steps to correct or verify its accuracy; (2) Theprocessing of Personal Data is unlawful but the User does not want PersonalData to be erased by Zehus; (3) Although Zehus no longer needs the PersonalData for the purposes of the processing, Personal Data are needed by the Usersto establish, exercise or protect rights; or (4) The User has objected toprocessing of Personal Data based on legitimate interests, as long as theassessment to verify whether Zehus has compelling legitimate grounds to keep onprocessing is pending;
· Object to the processing of Personal Data for LegitimateBusiness Interest Purposes, unless Zehus demonstrates the existence of prevailinglegitimate reasons or the processing is necessary to exercise or defend Zehus’rights, pursuant to Section 21 of the GDPR;
· Request the erasure of Personal Data, without unduedelay;
· Obtain Personal Data portability; and
· Lodge a complaint with the Italian Data ProtectionSupervisory Authority (https://www.garanteprivacy.it/).
10. Personal Data of Users under 18
The Website is not addressed to users under age of 18 and, in anycase, Zehus does not collect and otherwise intentionally process Personal Datareferred to users under age of 18. In case Zehus is aware of the collection andprocessing of such Personal Data, Zehus will delete it immediately.
This Privacy Notice might be subsequently updated or integrated,also as consequence of possible amendments to applicable laws. However, theupdated version of this Privacy Notice will always be available on this Website,to be consulted by Users.
What are cookies?
Cookies are small text strings that the Website sends to the User'sdevice (e.g., computer, smartphone, tablet), where they are stored and thentransmitted back to the Website, the next time the User's visit such Website.Cookies are useful because they allow the Website to recognize the User'sdevice and allow the User to browse on the pages of the Website, by rememberingthe preferences expressed and improving the User's browsing experience.
Cookies can be distinguished according to the following criteria:
(a) Based on the entity managing the cookies:
i. proprietary or first-party cookies: cookiesinstalled directly by the Company through the Website;
ii. third-party cookies: cookies that may be installedthrough the Website by third parties, other than the Company;
b) Based on the length of time they remain active:
i. session cookies: these cookies store the necessaryinformation during the browsing session and are deleted immediately after thesession expires, i.e. when the browser is closed;
ii. persistent cookies: these cookies are stored onthe User's hard drive and the Website reads them each time the User visits it.A persistent cookie has a fixed expiry date, after which it will stop working.
c) Depending on the purpose: these cookies are necessary to enable Usersto use the functionalities of the Site (so-called technical cookies). Othercookies may be used to obtain statistical information, aggregated or not, onthe number of Users accessing the Website and on how the Website is used(so-called analytical cookies). Lastly, other cookies may be used to trace theprofile of Users, so that they may be shown advertisements on the Website consistentwith Users’ interests, tastes and consumption habits (so-called profilingcookies).
Only technical cookies are installed on this Website, as better reportedat the following paragraph "Cookies on the Website".
Cookies can be stored on Users' devices only if they are essential forthe operation of the Website, otherwise the prior consent of the Users will berequired.
For further information on cookies, the User can click here.
Users may decide to make the installation of any typeof cookie subject to their prior consent or to prevent cookies from beinginstalled, by modifying the settings of their browser. Please note that theconfiguration of each browser is different and is described in the “Help” menuof each browser. In order to understand how to change cookies settings, Userscan consult the following links:
Users can also visit the website https://www.aboutcookies.org/, whichcontains comprehensive information on how to prevent the installation ofcookies on a wide range of desktop browsers.
Cookies installed on the Website
The Website uses technicalcookies which are strictly necessary to the functionality of the Website.
Name of the service/part that affixs the cookie
Name of the cookie
Purpose of the cookie
Allows WEB sites to store data about the state of serialization
Name of the cookie
Purpose of the cookie
A technical cookie used to track User’s consent and possibly not to re-propose the short information on cookies in the future pages or possibly the second User visit.
Users can turn off the technical cookies listed within the table, by changing their browser settings (please see par. Browser settings above). However, disabling these cookies might compromise the correct browsing and functionality of the Website.
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