PRIVACY POLICY
Pursuant to Legislative Decree 196/2003, as amended by Legislative Decree 101/2018, and pursuant to art. 13 of the EU Regulation n. 679/2016 («GDPR»).
| DATA CONTROLLER | Sitael S.p.A. Via San Sabino n. 21 Mola di Bari, 70042 Italy +39 080 53 21 796 info@sitael.com |
| DATA PROTECTION OFFICER «DPO» | +39 080 53 21 796 dpo@sitael.com |
| PERSONAL DATA PROCESSED |
| 1. Processed personal data for Site functional purposes During their normal operation, computer systems and procedures involved in the functioning of www.sitael.com website acquire some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected with the aim of identifying users: however, this information could allow user identification through processing and association with data held by Sitael or third parties because of its nature. This category of data includes also IP addresses or computers’ and terminals’ domain names used by data subjects connecting to the site, requested resources’ addresses in URI / URL notation, requested time, method used in submitting the request to the server, file size obtained in response and other parameters relating to the operating system and user’sbject’s computer environment.
2. Personal data provided by the data subject The optional, explicit and voluntary transmission of personal data – as requested by various sections of this site – is aimed at processing the data subject’s requests (for example, filling in the newsletter subscription or sending requests to the e-mail addresses present there) and implicate the sender’s personal data acquisition necessary to respond, as well as all the data included in the communications. Specific information will be reported in the Website pages prepared for the services on request, in such a way to draw the data subjects’ attention to their personal data processing. 3. Cookie The Site uses cookies in order to ensure Site normal navigation and use and to improve the users browsing experience. For further information about the use of cookies, please note the full disclosure at the following address [insert URL address]. |
| PURPOSE OF PROCESSING | LEGAL BASIS FOR PROCESSING | DATA RETENTION PERIOD |
| Functioning of the website Personal data collected during navigation are used to obtain anonymous and statistical information on the website use and to check its correct functioning. | Processing brought about for this purpose is based on a legitimate interest of the Data Controller in the correct website management. | For the period for which this is strctly necessary in order to obtain valid statistical information and effectively check the website correct functioning. |
| Commercial and informative communications transfer Personal data provided directly by the data subject are used in order to process the data subject’s requests (e.g. Newsletter or contact request). | Processing brought about for this purpose is carried out with the specific consent provided by the data subject.
| Until the data subject has revoked the consent given. |
| Contractual purposes Data provided directly by the data subject are used in order to prepare and execute contracts with data subjects. | Processing used for this purpose is based on the execution of a contract to which the data subject is a party. | 10 years from the contract termination.
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| NATURE OF THE PROVISION OF THE DATA |
| With the exception of navigation data, which are necessary to implement IT and electronic protocols, personal data provision by data subjects is free and optional. However, failure to provide the personal data themselves will make it impossible to proceed with requests forwarded or those the data subject intends to forward. |
| DATA RECIPIENTS |
| We inform you that your data may be made accessible for the aforementioned purposes at: • Data Controller’s employees and collaborators, expressly instructed and authorized for processing; • Data Processors identified through a specific agreement; • Service providers who carry out outsourced activities on behalf of the Data Controller (e.g. Website management, Newsletter sending management), in the capacity of Data Processors, within the limits of the purposes indicated in this statement. The Data Processors list can be requested through a specific request to our DPO. |
| METHOD OF PROCESSING |
| Personal data processing provided by the data subject is accomplished by means of the operations indicated in art. 4, n. 2) of the GDPR, by personnel expressly authorized to process it and appropriately instructed in order to guarantee the data processed confidentiality and to avoid the loss, destruction, unauthorized access or unauthorized processing of the same data, as well as from the units to which they belong within their competence. Data provided will be collected using suitable electronic and/or paper instruments, with logics strictly related to the same purposes and, in any case, capable of guaranteeing their security, secrecy and confidentiality. |
| DATA TRANSFER |
| The aforementioned data are stored mainly on servers located within the European Union. However, data provided for sending communications for purposes of marketing (e.g. “Newsletter”) are stored on servers located in non-EU countries at the following companies: • MailChimp – the Rocket Science Group, LLC, 512 Means St., Suite 404, Atlanta, Georgia 30318 – which guarantees its compliance to the Privacy Shield. We guarantee that the extra-EU data transfer takes place in compliance with the applicable legal provisions and that your data will never be used directly by MailChimp or sold by them to third parties. |
| LINK AD OTHER WEBSITES |
| From this website, it is possible to connect, via specific links, to other websites belonging to third parties. The Data Controller declines any responsibility regarding the possible request and/or release of personal data to third party sites. |
| DATA SUBJECT RIGHTS |
| In the spirit of absolute transparency and correctness with which Sitael S.p.A. intends to manage the topic, we assure you our complete availability for any necessary clarification and our collaboration for the appropriate fulfilments. We inform you that the Regulation gives data subjects the opportunity to exercise specific rights. In the capacity of data subject, you have the right to obtain confirmation from the Data Controller that your personal data is being processed. In this case, pursuant to art. 15 of the GDPR, data subject will be entitled to obtain access to its personal data and to verify the purposes and methods of processing. You may also exercise your rights to update, rectify, integrate, oppose, limit, and erase your personal data. Furthermore, the data subject can deactivate and cancel the subscription to the Newsletter service by clicking on the deactivation link in the Newsletter received. According to the art. 7 of the GDPR, the data subject has the right to withdraw, where applicable, the consent given. In order to exercise these rights, please write to Sitael to the attention of the Data Protection Officer, domiciled for the office at the Company’s headquarters or contact us at the email dpo@sitael.com Data subjects who believe that their personal data processing is in violation of the GDPR’s provisions have the right both to lodge a complaint with the Privacy Authority, as provided by art. 77 of the Regulation, and to commence legal proceedings according to art. 79 of the Regulation. |
| POLICY MODIFICATIONS |
| Any entry into force of new regulations in this field, as well as the constant updating of data subject services, could lead to the need to modify methods and terms described in this policy. We therefore invite you to consult this page periodically. |
COOKIES POLICY
What are cookies?
According to General Measure of the Italian Data Protection Authority of 8th May 2014, “cookies” are defined as “small text strings that the sites visited by the user send his terminal, where they are stored before being re-transmitted to the same sites at the next visit by the same user “. While browsing on Sitael corporate website, the Company may collect information relating to the traffic flow and visits to the page of its domain. Please note that this information are obtained by using cookies and will be processed by Sitael in compliance with the aforementioned legislation and the principles of confidentiality adopted by the Company.
The use of cookies is aimed at making the user experience more efficient by personalizing access to the website, optimizing the navigation and functioning of the website, improving our services and providing content and/or advertising related to preferences user.
Please also note that cookies can be transmitted by two distinct entities. The “first party cookies” are set and transmitted by the website domain, which the user is visiting, identified by the domain name displayed in the address bar while the “third party cookies” are set by domains different from the one displayed in the address bar and third parties transmit them. For example, they can be advertising banners, images and videos that reside on servers other than the one that issues the page you requested.
Depending on their duration, cookies are divided into “session cookies” and “persistent cookies”. The “session cookies” are kept in memory exclusively for the period of navigation on the website and, therefore, they are deleted when the browser is closed. On the other hand, the “persistent cookies” are stored in the user’s navigation browser for a defined period, regardless of the current session (until the expiry date set or the cancellation date by the user). The use of persistent cookies is regulated by the rules established by third parties. Therefore, user must read the privacy notices published on such third parties’ website in order to manage or disable these cookies.
Depending on the function and purpose of use, cookies can be divided into two categories:
- Technical Cookies.
Technical cookies are necessary, for example, to identify the user and to guarantee the normal navigation and the website use. Based on the provisions of the Measure of the Italian Data Protection Authority of 8th May 2014, the prior consent of the user is not required for the installation or use of these cookies. However, pursuant to art. 13 of the GDPR, the obligation to provide users with information remains necessary.
This category also includes “analytics cookies” – that is to say cookies used directly by the website operator to collect information in aggregate form about how users use the website in order to improve its functioning. For example, these cookies show which are the pages most frequently visited by the user, which are the most common patterns of use and which are the difficulties that users have encountered using the website.
- Profiling Cookies.
Profiling cookies are used to track users’ browsing on the website and to create profiles based on their habits (e.g., what they buy, what they read, etc.). Through these cookies it is possible to transmit advertising messages in line with the user’s preferences expressed in the context of web browsing. According to the art. 7 of the GDPR, the use of these cookies requires the prior acquisition of the user’s free informed consent.
Types of cookies used by the website of Sitael S.p.A.
The main functions of the cookies installed on the www.sitael.com site are technical in nature and are used to constantly improve the services offered by the Company, for user authentication, for statistical purposes and for counting visits to the site. Therefore, the use of these cookies is strictly aimed at facilitating and improving the browsing experience on the Company’s website. Below technical cookies used by Sitael on its corporate website are listed:
| Cookie Name | Provider | Description | Expiry | Type |
| CookieConsent | sitael.com | Stores the user’s cookie consent state for the current domain | 1 year | HTTP |
| ollect | google-analytics.com | Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels. | Session | Pixel |
| _ga | sitael.com | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 2 years | HTTP |
| _gat | sitael.com | Used by Google Analytics to throttle request rate | 1 day | HTTP |
| _gid | sitael.com | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 1 day | HTTP |
Furthermore, the Company has entered into agreements for the installation of third-party cookies on its company website. These cookies are not instruments of ownership of the Company, so for further information, it is possible to access to the information and the forms of acquisition of the consent of the following third parties:
| Cookie Name | Provider | Description | Expiry | Type |
| IDE | doubleclick.net | Used by Google DoubleClick to register and report the website user’s actions after viewing or clicking one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user. | 1 year | HTTP |
| r/collect | doubleclick.net | This cookie is used to send data to Google Analytics about the visitor’s device and behavior. It tracks the visitor across devices and marketing channels. | Session | Pixel |
| test_cookie | doubleclick.net | Used to check if the user’s browser supports cookies. | 1 day | HTTP |
| NID | google.com | Registers a unique ID that identifies a returning user’s device. The ID is used for targeted ads. | 6 months | HTTP |
| rc::c | google.com | This cookie is used to distinguish between humans and bots. | Session | HTML |
| vuid | vimeo.com | Collects data on the user’s visits to the website, such as which pages have been read. | 2 years | HTTP |
| GPS | youtube.com | Registers a unique ID on mobile devices to enable tracking based on geographical GPS location. | 1 day | HTTP |
| PREF | youtube.com | Registers a unique ID that is used by Google to keep statistics of how the visitor uses YouTube videos across different websites. | 8 months | HTTP |
| VISITOR_INFO1_LIVE | youtube.com | Tries to estimate the users’ bandwidth on pages with integrated YouTube videos. | 179 days | HTTP |
| YSC | youtube.com | Registers a unique ID to keep statistics of what videos from YouTube the user has seen. | Session | HTTP |
| yt-remote-cast-installed | youtube.com | Stores the user’s video player preferences using embedded YouTube video | Session | HTML |
| yt-remote-connected-devices | youtube.com | Stores the user’s video player preferences using embedded YouTube video | Persistent | HTML |
| yt-remote-device-id | youtube.com | Stores the user’s video player preferences using embedded YouTube video | Persistent | HTML |
| yt-remote-fast-check-period | youtube.com | Stores the user’s video player preferences using embedded YouTube video | Session | HTML |
| yt-remote-session-app | youtube.com | Stores the user’s video player preferences using embedded YouTube video | Session | HTML |
| yt-remote-session-name | youtube.com | Stores the user’s video player preferences using embedded YouTube video | Session | HTML |
In order to improve the company website and understand which parts or elements are most appreciated by users, the Company uses analytical Google Analytics cookies as an anonymous and aggregate analysis tool. Like third party cookies, Google’s analytical cookies are not instruments of ownership of the Company, hence it is possible consult the information provided by Google indicated below in order to obtain more information.
According to current the terms of service, Google will use this information, as an independent data controller, for the purpose of tracking and examining the website use, compiling reports on site activity for site operators and providing others services relating to the activities of the website, to the connection methods (mobile, PC, browser used etc.) and to the methods of searching and reaching the portal pages. Google may also transfer this information to third parties where required by law or where such third parties process the information on Google’s behalf. Please note that Google will not associate IP addresses with any other data held by Google.
To consult the privacy policy of Google, relating to the Google Analytics service, please visit the website https://policies.google.com/privacy.
Plugin Social Network
In order to permit easy sharing of our company website’s contents on your favorite social networks, the www.sitael.com site also incorporates plugins and/or commands for the major social networks (e.g., Facebook, Twitter, YouTube, etc.). With a view to safeguard user privacy, these plugins are programmed so as not to install any cookies on the users’ devices who visit this company website. Eventually cookies plugins could be set, if so provided by social networks, only when the user makes actual and voluntary use of these plugins. We inform you that if the user browses being logged in his social network, then he has already consented to the use of cookies conveyed through this site when he registered with the social network.
The collection and use of information obtained through the plugins are regulated by the respective social networks’ privacy notices, to which please refer.
- Facebook: https://www.facebook.com/policies/cookies/
- Twitter: https://help.twitter.com/it/rules-and-policies/twitter-cookies
- LinkedIn: https://www.linkedin.com/legal/privacy-policy?_l=it_IT
- Instagram: https://help.instagram.com/196883487377501
- YouTube: https://policies.google.com/technologies/cookies
E-mail and cookie
Sitael emails contain cookies, which monitor if the user has opened emails from the Company and if he has clicked on any link contained in them. The cookies used in Sitael’s emails, monitoring the aforementioned behaviours, are unique to each email and are not stored on your computer or mobile device.
Provisions of data
With the exception of technical cookies, which are strictly necessary for the company website regular operation, the provision of data is left to the user will (as an interested party). The user consents to the processing of his/her data when, after having read the short information contained in the specific banner, he/she decides to continue browsing the company website.
Please note that, in order to avoid the installation of cookies on your device, it is possible to uninstall this function through the special functions available on your navigation browser (see below, the “Cookies management”).
Acceptance and consent to the processing of data
Please note that the acceptance and consent to the processing of data obtained through cookies is done by viewing the banner on the site (below).
Cookies Management
Please note that you can set your cookie preferences through the functionalities present in common browsers, which permit to delete cookies or change your browser settings so you can block or limit cookies. Therefore, it is possible to deny the cookies use, following the disabling procedure provided by your browser.
Methods proposed by the main browsers are reported below:
- Google Chrome
https://support.google.com/chrome/answer/95647?hl=it&hlrm=it - Mozilla Firefox
https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
- Internet Explorer
https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies
Considering the objective complexity involved in identifying the cookies technologies, if you wish to receive any further information on this cookie policy or on the cookies use on Sitael’s corporate website, we invite you to contact the Company.
Updates to this Cookie Policy
This policy may be updated by Sitael S.p.A, in order to comply with national and European legislation on the personal data processing and/or to adjust to new systems adoption(technological innovations). Any future modification to this policy will be reported on this page. Please read regularly this policy to check for updates or changes.
