- Data Controller and Data Protection Officer
- The personal data subject to processing
- Purposes of data processing
- Legal basis and mandatory or voluntary nature of the processing
- Personal Data Recipients
- Transfers of Personal Data
- Retention of Personal Data
- Data subject’s rights
- Contact details
Data Controller and Data Protection Officer
The Controller is Morato Pane, as defined above. You may contact the Data Protection Officer (“DPO”) by writing to email@example.com for any information on the processing of personal data by Morato Pane.
The personal data subject to processing
When you visit the Site and when you communicate with us using the contact forms on the Site, we process your Personal Data (“Data”). More specifically, we process the following types of Data:
The computer systems and software procedures used to run the Site acquire, as part of their normal operations, certain Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected for the purposes of being associated with identified data subjects, but that, due to the nature of such data, could be used to identify users if subject to processing and associations with other data held by third parties. This category of Data includes the IP addresses or domain names of the computers used to visit the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to transmit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (successful, error, etc.) and other parameters of the user’s operating system and IT environment. These Data are used solely to gather anonymous statistical information on Site visits and to monitor that it is functioning properly, to identify any irregularities and/or misuse. These Data could be used to attribute responsibility in the event of potential cybercrimes against the Site or third parties: outside these circumstances, the Data on Site visits are not currently retained for more than one session
Data provided voluntarily by the data subject
Purposes of data processing
Morato Pane collects and processes your Data for the following purposes:
- to enable navigation of the Site and to provide the services you request from Morato Pane (contact request, information request, download of documentation on the Site, “Provision of the service”);
- to fulfil any obligations arising from current laws, regulations or EU legislation or any requests from the authorities (“Compliance”);
- for statistical purposes on an anonymous basis (“Statistics”).
Legal basis and mandatory or voluntary nature of the processing
Morato Pane processes your Data according to the purposes indicated in Section 3 on the following legal bases:
- Provision of the service: the processing of your Data for this purpose (Section 3.a.) is necessary to provide the services to you and fulfil your requests. The legal basis of this processing is established in Article 6(1)(b) of the Regulation (“[…] the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”). The provision of Data for this purpose is voluntary but it will not be possible to provide the services or fulfil your requests without your consent;
- Compliance: the processing of your Data for this purpose (Section 3.b.) is necessary so that Morato Pane can meet any legal obligations or requests from the authorities. The legal basis of this processing is established in Article 6(1)(c) of the Regulation (“[…]the processing is necessary for compliance with a legal obligation to which the controller is subject”). The processing of your Data for this purpose is necessary to meeting the legal obligations to which Morato Pane is subject. This processing could entail the retention and disclosure of your Data to the authorities should they request the Data in connection with accounting, tax or other obligations;
- Statistics: this processing is not performed on the Data and may therefore be carried out by Morato Pane.
Personal Data Recipients
Your Data may be shared, for the purposes described in Section 3, with the following (the “Recipients”):
- parties that typically act as processors, i.e.: i) people, companies or professional firms that provide assistance and consultancy to Morato Pane regarding accounting, administrative, legal, tax and financial matters in connection with the provision of the services; ii) parties with which Morato Pane must interact in order to provide the services (e.g., hosting providers); or iii) parties authorised to carry out technical maintenance (including the maintenance of network equipment and electronic communication networks);
- parties, bodies or authorities to which your Data must be disclosed under legal provisions, regulations or the orders of authorities;
- people authorised by Morato Pane to process the Data in order to perform activities strictly related to the provision of services, who have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality (e.g., employees of Morato Pane or other Morato Group companies);
- Morato Group companies, limited to the pursuit of administrative/accounting purposes related to the performance of organisational, administrative, financial and accounting activities.
Transfers of Personal Data
Some of your Data could be shared with recipients that are outside the European Economic Area. Morato Pane ensures that the processing of your Data by these recipients is carried out in compliance with the Regulation. Any such transfers may be based on an adequacy decision, standard contractual clauses approved by the European Commission or another suitable legal basis provided for by the Regulation. Additional information is available with the Controller.
Retention of Personal Data
The Data processed for the purpose of Provision of the service (Section 3.a.) shall be retained for the amount of time strictly necessary to achieve this purpose. As this processing is performed to provide services, Morato Pane could further retain your Data for the amount of time permitted by Italian legislation to protect its interests (Art. 2946 and subsequent articles of the Italian Civil Code).
The Data processed for Compliance purposes (Section 3.b.) shall be retained as long as required by the specific obligation or applicable law or regulation.
Data subject’s rights
Pursuant to Article 15 and subsequent articles of the Regulation, you may ask Morato Pane at any time for access to your Data or to have your Data rectified or erased or you may object to processing under Article 21 of the Regulation. Furthermore, in the cases provided for by Article 18 of the Regulation, you may request the restriction of processing and, in the cases provided for by Article 20 of the Regulation, you may obtain the personal data concerning you in a structured, commonly used and machine-readable format.
In any case, you always have the right to file a complaint with the competent data protection authority (Garante per la Protezione dei Dati Personali), pursuant to Article 77 of the Regulation if you believe that your data have been processed in violation of the law.
The response time provided for by the Regulation is one month of receipt of the request (which may be extended by two further months taking into account the complexity of the request). You may exercise any of the rights indicated above by writing to firstname.lastname@example.org.
You may contact the Controller to exercise the rights indicated above or for any other requests: Morato Pane S.p.A., with registered office in Altavilla Vicentina (Vicenza), Via D’Azeglio 49, or by email: email@example.com.
You may email the DPO at: firstname.lastname@example.org