1. Purposes and principles of data processing. In compliance with the obligations set out in Art. 13 of the Legislative Decree no. 196/03, this document describes how to manage the website with regard to the processing of personal data of users who surf and interact with the web services accessible via Internet from the address: www.FPTINDUSTRIE.com.
We inform you that FPT INDUSTRIE will use your personal data to manage access to the portal and the services included therein, manage technical practices, carry out all the activities necessary or useful for the constant improvement of the provided service, and for determining the liability in the event of offences against the Site and/or offences committed through the Site. Further specific purposes relating to individual processing can be identified in detail, through additional information notices, within the various services included in the portal.
The consultation of the Site may involve the processing of data relating to identified or identifiable persons. The personal data provided by users who consult the Site are processed by the recipient of the communication in order to follow up the requests received.
Web surfing data
IT systems and software procedures for the operation of this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.
Information is not collected to be associated with identified data subjects but, by its nature, could allow users to be identified through processing and associations with data held by third parties. This category of data includes IP addresses or domain names of computers of users who connect to the site, addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the number code indicating the status of the response from the server (successful, error, etc..) and other parameters relating to the user's operating system and IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site, making the features of the site technically possible, checking its correct operation and ensure the maintenance of its database. In these cases, the web surfing data do not allow the users concerned to be identified and are deleted immediately after being processed anonymously.
The web surfing data can also be used to determine the liability in the event of offences against the Site or carried out through the Site.
Data supplied by the user
• information sent by users on an optional and voluntary basis to the addresses indicated on the Site (e.g. e-mail address, subject of e-mail, name or business name, name and surname, etc.);
• personal data supplied by users to use services accessible on the Site or to take part in initiatives promoted through the Site;
• personal data supplied by the users who forward requests for sending information and/or informative material;
• personal data supplied by the users submitting proposals for applications (“curriculum vitae”, etc.).
The processing involves data acquisition (e.g. the collection of the e-mail address of the sender, necessary to respond to his/her requests, and any other personal data entered) and other operations.
The processing will be carried out, with or without the help of electronic instruments, according to the principles of fairness, lawfulness and transparency so as to protect at all times the confidentiality and rights of the data subject, in accordance with the regulations in force.
The purposes of the processing are to respond to any requests from the user relating to the sending of information material (bulletins, newsletters, mailing lists, replies to questions, notices, acts and measures, other documents, etc.) or to perform the service requested by the user, and are communicated to third parties only in the event that this is necessary for the fulfilment of the aforementioned requests or for the fulfilment of obligations envisaged by the regulation in force in relation to the Controller of the Site. After the termination of any contractual relation established between the Controller and the data subject, personal data will also be processed to fulfil all legal obligations related to or arising from the terminated relation. In such cases, consent to the processing is optional and failure to consent may therefore make it impossible for the user to obtain the requested information from the Controller of the site or the requested service.
2. With the specific consent of the customer (please refer to a special online and/or paper form), the data collected will also be used by us for commercial and promotional purposes, for marketing activities, for sending promotional material and for carrying out market surveys through all means of communication (mail, e-mail, telephone, SMS, mms, social networks, etc.). Such consent is always optional, and any failure to consent will not result in the user being unable to use any of the requested services, but simply the impossibility for the Site provider to use the data for these particular purposes.
3. Subjects who process data. The data collected are processed by persons in charge within FPT INDUSTRIE who need to know them in order to carry out their activities (e.g. commercial office, marketing office, administrative office, call center, technical staff for the maintenance of the company IT system, etc.).
In compliance with the provisions in force, data may be communicated to factoring companies, debt collection companies, credit insurance companies, commercial information companies, distribution companies for the performance of their activities (e.g.: order management, activation of contracts, after-sales service), transport companies, credit institutions for the management of takings and payments, third parties responsible for carrying out activities related to and instrumental to this processing (such as debt collection companies, credit insurance companies, lawyers and law firms, chartered accountants, accountants, auditors and auditing firms, members of the supervisory body pursuant to former Legislative Decree 231/2001, mayors, or third parties appointed to carry out maintenance services for IT systems and/or electronic files related to the site). In the sole case of any processing carried out for direct marketing, profiling or retention purposes, the data - prior to your consent (on which see the specific different section of this information notice) - may also be communicated to advertising agencies, web marketing companies, consultants and professionals to whom FPT INDUSTRIE entrusts activities functional to the pursuit of these purposes. The data are also communicated to authorities and public administrations in fulfilment of legal obligations. These third parties will process the data as external data processors or autonomous data controllers.
The data will not be disseminated.
4. Logic and forms of processing organization will be strictly related respectively to the individual above-mentioned purposes. Processing will take place electronically, telematically and/or on paper. Data during processing are subject to protective measures activated by FPT INDUSTRIE to protect the data against the risk of unauthorized access or processing, for example personal data managed electronically are accessible only by accessing various processing or data entry programs, through the input of mandatory personal passwords only by staff authorized by FPT INDUSTRIE, which anyway has to comply with predetermined limits of use.
5. Personal data are usually processed for the whole duration of the contractual relation established with the data subject and, subsequently, for the only period of time necessary to fulfil our legal obligations (10 years). After the termination of the contractual relation that may have been established between the Controller and the data subject, personal data will also be processed to fulfil all legal obligations related to the termination of the contractual relation. The data will be kept no longer than is necessary to fulfil the aforementioned obligations, tasks or purposes and to prove their fulfilment to the supervisory authorities (normally for 10 years after the termination of the contract), and will then be destroyed. Some data (e.g. name and surname, company name, VAT number, tax code, e-mail, telephone number, mobile phone, fax number, certified e-mail, address of registered office, names of internal contact persons, etc.) are kept even after the aforementioned ten-year term, as long as they are useful to satisfy the legitimate interest of the Controller in rationalizing selection and commercial contacts with users, customers and/or suppliers. Conversely, if personal data are processed for purposes of IT security (e.g. logs), the data will be retained for a period of time sufficient to complete the relevant security checks and evaluate their results; normally a maximum of 1 year from the time of collection. In case of out-of-court or in court proceedings with the data subject and/or with third parties, the data will be processed for all the time strictly necessary to exercise the full protection of the rights of the Controller.
6. The legal basis for the processing is, depending on cases, Article 6, letter a), of EU Regulation no. 679/2016 or “GDPR” (the data subject has expressed his/her free and informed consent to the processing for a given purpose and has not subsequently revoked it), Article 6, letter b) GDPR (is necessary for the execution of a contract which the data subject is a party to or for the performance of pre-contractual measures taken at the data subject's request, for example requests for information or commercial offers), Article 6, letter c) GDPR (is necessary for the compliance with a legal obligation to which the controller is subject) and/or Article 6, letter f) GDPR (is necessary for the legitimate interest of the data controller or third parties to be pursued, overriding the interests or fundamental rights of the data subject). In particular, the legitimate interest of the controller is to i) be able to process the data in order to effectively and efficiently manage the relation with its users, customers and/or suppliers and organize the related internal organizational and management processes and ii) in the case of processing for profiling, direct marketing and retention purposes, to promote its products and/or services to target customers through offline and online methods. On the other hand, the legitimate interest of third parties is to receive personal data from the Controller and process them for the purposes of verifying the correct fulfilment of legal and contractual obligations with regard to the data subject or to third parties (e.g. verification by the public authority of compliance with tax obligations, verification by the board of statutory auditors or auditors of compliance with legal obligations, etc.) or to receive personal data from the Controller and processing them in turn, in order to be able to manage the activities related to the Controller's request for support in managing the activities towards the data subjects.
What cookies are and how they are used
Cookies are short strings of information (text files) concerning the activity of the user on the website, which are saved, during the first navigation on the website, on the device (computer, smartphone or tablet) of the user surfing the Internet, and then transmitted to the same sites at the next visit of the same user, allowing our site to automatically recognize the user (or other users employing the same device) after the first visit and improve his/her experience of use.
Their operation is completely dependent on the navigation browser that the user is using, which can be enabled or disable by the user.
In order to always ensure the best navigation possible, our site offers the best performance with cookies enabled. By default almost all web browsers are set to automatically accept cookies.
Cookies can be:
• “first party” cookies when they are directly managed by the manager of the website
• “third party” cookies when they are set and managed by a website other than the one the user is visiting.
Third party cookies are under the direct and exclusive responsibility of the provider and, in relation to their installation, the provider of the first-party site assumes the role of technical intermediary.
Which cookies we use and for which purposes
The Site uses or can use, even in combination, the following categories of cookies:
• Permanent or “persistent” cookies: these cookies are stored on the device even after you leave the website or close the browser: in particular, they are stored until their foreseen expiry date or until they are manually deleted by the user. Persistent cookies satisfy many functions in the interest of web surfers (such as for example storing the password), anyway, in some cases they can also be used for promotional purposes.
• Session cookies (or temporary cookies): they have a duration limited to the visit and are deleted once the browser is closed, when the “session” of access to the website ends. As a rule, they allow users to access personalized services and fully use the functions of the site, avoiding the use of other information techniques that could potentially compromise the confidentiality of user’s surfing.
• Technical/functional cookies, for example for the transmission of session identifiers necessary for the safe and efficient exploration of the site. These cookies avoid using other information techniques that could potentially compromise the confidentiality of user’s surfing.
For the use of technical cookies the law requires the mere release of the information notice to the data subject, as is the case with this communication and i.e. even without the creation of specific banners on the Site.
For all non-technical cookies, on the contrary, the regulation in force makes their installation conditional on prior consent being given in the simplified forms provided for by the Measure of 8/5/2014 of the Data Protection Authority and i.e. through the publication of synthetic banners viewable by the user on the first “landing” on the site and which makes it possible to generate a further action of use of the Site (based on “scroll”, or on the continuation of surfing within the same web page) with which the user can implicitly communicate his/her consent, or, alternatively, to access an analytics cookie information (i.e. this information notice), within which the user can express his/her required consent or non-consent. This consent or non-consent may be given by the user not in reference to individual cookies installed but in relation to broader categories of cookies, or to specific producers and/or intermediaries with which the Site has established business relations.
• Analysis cookies (“analytics” cookies): these cookies can be both temporary and permanent and make it possible to collect and analyze in an aggregate and/or disaggregate manner statistical information on accesses (for example geographical area of origin of the user, device used for the access, age, etc.) and, in general, on the behaviour of users on the site and therefore to improve their experience and the contents provided. These analytics cookies can be considered technical cookies only if they are directly created and used by the first-party site (thus without the intervention of third parties). For example, the site uses log files (i.e. it records the history of operations as they are performed) and registry files (which include IP addresses, type of browser, operating system used by the user’s device, Internet Service Provider (ISP), date, time, page of entry and exit and the number of clicks, but also the pages visited on the site, third-party sites from which the user comes). All in order to analyze the trends of user’s behaviour and administer and optimize the site. Information collected in this way is not personal since data are collected and analyzed anonymously. If analytics cookies are created and/or used by third parties (other than the controller of the first-party site), they cannot be considered technical cookies and have a different legal treatment.
• “Profiling” cookies (or advertising cookies) (always permanent) are used for obtaining information, aggregated or not, useful to evaluate the use of the website and the activities carried out by the visitor (choice of displaying specific pages, specific products and/or services, etc.), used by the controller for the formulation of commercial advertising of targeted products and/or services, i.e. based on previous activities of the user (instead of general advertising offered indistinctly to all).
List of cookies actually present on the website
The introduction above does not automatically imply that the website currently uses all the categories of cookies indicated above. The list of cookies actually used by FPT INDUSTRIE is the one indicated below.
|Cookie||Dominio||Scadenza||Cookie terze parti||Cookie permanente||Cookie di sessione|
|IDE||.doubleclick.net||23 Giugno 2019 alle 10:24||Cookie terze parti||Cookie permanente|
|_gat||.fptindustrie.com||Cookie di sessione|
|_gid||.fptindustrie.com||30 Maggio 2018 alle 10:24|
|_ga||.fptindustrie.com||28 Maggio 2020 alle 10:24||Cookie permanente|
|GPS||.youtube.com||Cookie terze parti||Cookie di sessione|
|PREF||.youtube.com||27 Gennaio 2019||Cookie terze parti||Cookie permanente|
|YSC||.youtube.com||27 Gennaio 2019||Cookie terze parti||Cookie permanente|
|VISITOR_INFO_1_LIVE||.youtube.com||25 Novembre 2018 alle 09:24||Cookie terze parti||Cookie permanente|
|PHPSESSID||www.fptindustrie.com||25 Novembre 2018 alle 09:24||Cookie permanente|
The Site also uses the cookies of Google Analytics (cookies of Google Inc., which is an American society, third party). We would like to point out that no strictly personal information is collected through Google Analytics features, but we collect in aggregate statistical form data about age, gender, and preferences of our visitors (in order to better evaluate the use of our website and the activities performed by the visitor and better target the services provided). These cookies are stored on servers that may be located in the United States or in other countries. Google reserves the right to transfer information collected with its cookies to third parties if required by law or if the third party processes information on its behalf.
However, the “Analytics” function is configured by FPT INDUSTRIE by default, so as to significantly mask portions of the IP address of the user/visitor, and therefore the data of the IP address thus collected are already anonymized at source, and therefore the analytic cookie does not allow to trace even indirectly -and in particular through further processing- the identity of the user/visitor. For this reason FPT INDUSTRIE, which is the provider of the site, is not obliged by law to comply with the obligations and fulfilments envisaged by the regulation on cookies (e.g. notification of the processing of cookies to the Data Protection Authority).
In the future, if FPT INDUSTRIE should decide to modify at any time the configuration of the “Analytics” function so as to allow the collection of the data relating to the user consisting of the last three numbers that make up the user’s IP address, this choice shall be notified in advance to the Data Protection Authority by the data controller carried out through the portal or site, to protect the user.
Please note that Google also guarantees that it will not associate the user's IP address with any other data held by Google in order to obtain a more detailed user profile.
This site does not use personal profiling cookies, i.e. cookies based on personal identification data.
Our site does not use remarketing lists and display network advertisements, i.e. online advertisements based on categories of general interest expressed by categories of users through previous web surfing.
Without prejudice to the generality of the foregoing, our site does not use the special advertising functions of Google Analytics, which allow you to activate additional functions not available through the standard implementations of Google Analytics and related cookies.
These advertising functions, if any, allow the collection of traffic data (through Google advertising cookies and anonymous identifiers) in addition to data that we already collect through a standard implementation of Google Analytics. The advertising functions of Google Analytics are as follows:
• Remarketing with Google Analytics
• Reports on Google Display Network impressions (if used through AdWords)
• Integrations with DoubleClick platform
• Reports on demographic data and Google Analytics interests
For more information on online behavioural advertising and some suggestions on possible measures, in particular to disable the display of advertisements based on online interests: www.youronlinechoiches.eu/it.
• Social cookies: these cookies are third-party cookies, i.e. provided directly by the domains of the most common social media networks that are linked to our Site through links to official pages, content sharing buttons and links. The use of these buttons and functions implies the exchange of information (e.g. texts, photographs, videos, etc.) with such sites.
The management of information and the ways to delete such social cookies is, therefore, regulated by the social media sites themselves: we invite the user to consult their privacy policies, at the following links:
• Linkedin: https://www.linkedin.com/legal/privacy-policy?trk=uno-reg-guest-home-privacy-policy
• Facebook: https://www.facebook.com/policies/cookies/
• Twitter: https://help.twitter.com/it/rules-and-policies/twitter-cookies
• YouTube: https://www.google.com/policies/technologies/types/
The use of such cookies is purely anonymous, no personal information is collected unless the user intends to provide it explicitly by sending contact forms and/or forms requesting information.
Further information on privacy and the use of social cookies can be found directly on the sites of the respective third-party providers.
How cookies operate and how to disable them
Accepting or refusing cookies is your right
Below there are the links for the configuration of the most popular browsers that describe the ways to manage cookies:
• Chrome: https://support.google.com/accounts/answer/61416?hl=it
• Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
• Internet Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
• Opera: http://help.opera.com/Windows/10.00/it/cookies.html
• Safari: https://support.apple.com/it-it/HT201265
In order to modify the settings of cookies on browsers other than those listed, please refer to the help documentation provided by the producer of your browser.
Furthermore, the user can selectively disable the action of Google Analytics by downloading and installing on your browser the additional opt-out component specifically supplied by Google for your browser at the following link:
Remember to set cookie preferences for each device and browser used for surfing the Internet.
In order to delete cookies from the Internet browser of your smartphone/tablet, you shall refer to the user manual of the device.
For more information on cookies and privacy, please consult the special document prepared by the Data Protection Authority at the following link:
7. The personal data processing controller is FPT INDUSTRIE, with head office in Via Antonio Vivaldi, 1 Camposampiero 35012 Padua, email: firstname.lastname@example.org
FPT INDUSTRIE has appointed one or more authorized persons responsible for processing data. These data processors may be internal or external to the Company. The internal data processors pertain to the homogeneous functional areas of the company which require data to be processed for the reasons indicated in this policy, such as the administrative department, the human resources department, the IT maintenance department, the marketing department, etc. The external processors are all the categories of third party recipients to whom the Company communicates data for the said purposes (where these external processors do not directly act as autonomous controller for the managerial autonomy accruing to them with reference to the processing entrusted to them). A complete updated list of processors is available for consultation at the Company under written request by the data subject.
8. With regard to personal data processing, you can exercise the rights envisaged by Legislative Decree 196/2003 described hereunder:
1. Obtain the confirmation of the existence or non-existence of data regarding you, even if not registered yet, and the communication in an intelligible form of these data;
2. Obtain information on a) the origin of personal data; b) the purposes and the ways of treatment; c) the logic applied in case of processing through electronic devices; d) the identity of the controller, of the persons in charge of processing; of the recipients or categories of recipients to whom personal data can be communicated or those who can become acquainted with them as appointed representatives in the territory or State, or as delegates or persons in charge.
3. Obtain a) the update, correction or integration of data if you have interest into it; b) the cancellation, transformation in anonymous form or block of data processed in breach of the law, included data whose storage is not necessary for the purposes for which they were collected and subsequently processed; c) confirmation that the operations described in letters a) and b), as well as their content, have been notified to the parties to whom data was communicated or disclosed, apart from the cases where such fulfilment becomes impossible or implies the use of means overtly disporportionate to the protected right;
4. Oppose in full or in part a) the processing of personal data for legitimate reasons, even if it is relevant to the purpose of collection; b) the processing of personal data whose purpose is sending advertising or direct sale material, or performing market research or commercial communication.
The above rights are exercised with a request to the controller or processor (for whose identification see below), also through a designated person, to whom appropriate feedback is provided without delay. The request:
a) can be sent also via e-mail to the address email@example.com
b) if related to the exercise of the rights listed in points 1 and 2, it can also be transmitted orally and in this case it is synthetically noted by the processor or appointed person.
For the exercise of the above mentioned rights, the data subject can confer power of attorney, in writing, to natural persons, entities, associations or organisms. The person concerned may also be assisted by a trusted person. The rights referred to personal data concerning deceased individual can be exercised by someone with a personal interest, or who acts to protect the interested party or for family reasons worthy of protection. The request specified in points 1 and 2 can be renewed by the interested party, unless there are justified reasons, within a lapse of time not inferior to ninety days.
From 25 May 2018, the data subject has the right to ask the processing controller to access his/her personal data and to rectify or delete them without undue delay or to limit or oppose their treatment; he/she has also the right to revoke at any time the consent to ordinary and/or sensitive personal data processing for one or more specific purposes, it being understood that this will not affect the lawfulness of the processing based on the consent given prior to revocation.
Furthermore, in compliance with Art. 20 of EU Data Protection Regulation no. 679/2016, from 25 May 2018 the data subject has the right to receive from the processing Controller his/her personal data in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller without impediment from the processing Controller to which the personal data have been provided, if the following (cumulative) condition is met:
a) the processing must be based on the consent of the data subject for one or more specific purposes (Art. 6 par. 1 lett. a) of EU Reg.), or on the data subject’s consent to sensitive data processing and i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a natural person's sex (Art. 9 par. 2 lett. a) of EU Reg.), or on a contract which the data subject is a party to and for the performance of which the processing is required (Art. 6 par. 1 lett. b) of EU Reg.); and
b) the processing must be carried out by automated means (software).
In exercising his/her rights in relation to data portability in compliance with what written above, the data subject has the right to obtain the direct transmission of personal data from one processing controller to another, if technically feasible.
The exercise of the so-called right to portability is without prejudice to the right of cancellation (“right to be forgotten”) envisaged by Art. 17 of EU Data Protection Regulation no. 679/2016.
For a complete analysis of the rights attributable to the data subject from 25 May 2018, please consult the Articles 15, 16, 17, 18, 19, 20, 21, 22 of EU Data Protection Regulation no. 679/2016.
Complaint. At any time, the data subject has the right to propose complaint to the European Data Protection Supervisor by using the link: http://www.edps.europa.eu , or to the Italian Data Protection Authority.