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English Privacy Policy
Information on the Protection of Personal Data for Data Subjects
Dear User, through this Privacy Policy we provide information on how personal data provided by users is processed and protected in compliance with applicable data protection regulations.
1. Joint Data Controllers
The processing of personal data is carried out under a joint controllership arrangement, pursuant to Article 26 of EU Regulation 2016/679, by:
- CONSORZIO ARMEC (VAT/Tax Code: 07741500727), with registered office at 70033 – CORATO (BARI), VIA RUVO KM 1.9, represented by its legal representative pro tempore MR. GIUSEPPE ARBORE;
- TUBO ARMEC SRL (VAT/Tax Code: 07715170721), with registered office at 70033 – CORATO (BA), VIA RUVO 145, represented by its legal representative pro tempore MR. ANTONIO ARBORE;
- TURBO SRL (VAT/Tax Code: 06886100723), with registered office at 70033 – CORATO (BA), VIA RUVO 145, represented by its legal representative pro tempore MR. GIUSEPPE ARBORE;
- ARMEC SNC DI GIUSEPPE ARBORE E C. (VAT/Tax Code: 01170570723), with registered office at 70033 – CORATO (BA), VIA RUVO KM 2, represented by its legal representative pro tempore MR. GIUSEPPE ARBORE;
- TURBO FLO SRL (VAT/Tax Code: 08711380727), with registered office at 70033 – CORATO (BA), VIA RUVO 145, represented by its legal representative pro tempore MR. LUIGI ARBORE;
Hereinafter jointly referred to as the “Joint Data Controllers”.
The Joint Data Controllers have jointly determined the purposes and means of processing.
For any request or to exercise your rights, you may contact the Joint Data Controllers at the following address:
2. Contact Details of the Data Protection Officer (DPO)
The Joint Data Controllers have appointed a Data Protection Officer (DPO), who can be contacted at the following email address:
3. Types of Personal Data
Browsing Data
The IT systems and software procedures used to operate this Website acquire certain personal data transmitted through secure protocols. Such collection is not intended to identify users, although identification could occur through processing and association with data held by third parties.
This category of data includes IP addresses, browser identifiers, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the numerical code indicating the status of the server response (e.g., success or error), and other parameters relating to the user’s operating system and IT environment.
These data are used solely to obtain anonymous statistical information and to ensure the proper functioning of the website.
Personal Data Voluntarily Provided by the User
Except for browsing data, the provision of personal data by users is optional. These are data voluntarily provided by website visitors, for example by filling in forms, and they will be processed solely for the purpose of providing the requested service.
4. Purposes and Legal Bases for the Processing of Personal Data for User Interaction and Website Functionalities
Purpose: easy navigation of website pages, use of website services, responses to messages and requests for documents and/or catalogs, and proper management of obligations imposed by applicable regulations.
Legal basis: processing is necessary for the performance of pre-contractual measures or contractual obligations; providing data is mandatory for establishing the relationship and delivering the service.
4a. Purposes and Legal Bases for User Interaction Through Messaging Systems
Purpose: facilitating assistance through messaging systems (e.g., WhatsApp, Telegram, and Signal), such as responding to messages and requests.
Legal basis: processing is based on the legitimate interest of the Data Controller in communicating with users more effectively and conveniently, balanced against the interests, rights, and fundamental freedoms of the data subject.
At the time of data collection and during each communication sent for the purposes referred to in this section, users are informed of their right to object to the processing at any time, easily and free of charge, by sending a communication to:
4b. Purposes and Legal Bases for Marketing/Newsletter Processing
Purpose: sending promotional communications regarding products and services through the newsletter.
Legal basis: processing is based on consent until revoked.
4c. Purposes and Legal Bases for Information Activities and Direct Marketing Processing
Purpose: receiving occasional information and communications via email, including newsletters, related to services and/or products already purchased. Receiving informative, promotional, and commercial communications via email regarding services offered by the Data Controller, including newsletters, updates, and offers on products and/or services already purchased by the Customer.
Legal basis: processing is based on the legitimate interest of the Joint Data Controllers, balanced against the interests, rights, and fundamental freedoms of the data subject.
At the time of data collection and during each communication sent for the purposes referred to in this section, users are informed of their right to object to the processing at any time in a simple and easy manner by writing to:
5. Disclosure and Recipients of Personal Data
The communication of data is a contractual obligation and, as a contractual requirement, is necessary for the conclusion of the contract and the consequent provision of the requested services. Therefore, failure to provide data, or providing incomplete or inaccurate data, will prevent the establishment of the contractual relationship and consequently make it impossible to provide the service.
Categories of recipients of personal data may include: digital consulting companies, communication agencies, and IT service providers. The provision of data is not mandatory, but without it additional services (e.g., marketing services) cannot be provided.
6. Data Retention Period and Criteria Used to Determine It
Users’ personal data will be retained in compliance with applicable regulations for a period not exceeding what is necessary for the purposes for which they were collected and processed, taking into account: the need to continue retaining personal data to provide the services agreed with the Data Subject or to protect the legitimate interests of the Joint Data Controllers, as described in the purposes above, and the existence of specific legal or contractual obligations requiring data processing and retention for certain periods.
7. Rights of the Data Subject and Right to Lodge a Complaint with the Supervisory Authority
The Data Subject may, at any time, by sending a communication to the Joint Data Controllers at:
- withdraw consent, where previously given;
- access personal data;
- request correction of personal data;
- request deletion (“right to be forgotten”) of personal data;
- request restriction of the processing of personal data;
- object to the processing of personal data;
- object to automated processing, including profiling, such as virtual assistance activities;
- request portability of personal data;
- lodge a complaint with the Italian Data Protection Authority (GPDP) and/or another supervisory authority if they believe their rights have been violated by the Data Controller and/or a third party.
Obtain a copy of the essential elements of the Joint Controllership Agreement pursuant to Article 26 GDPR.
8. Methods and Location of Personal Data Processing
Personal data are processed using both paper and electronic tools, recorded and stored in digital databases, and processed at the company’s premises and by authorized data processors located in Italy and Europe.
9. Intention to Transfer Data to a Third Country
Processing will mainly take place in Italy or other EU countries, but may also occur in non-EU countries where considered functional to the efficient fulfillment of the pursued purposes, while respecting the guarantees and rights of the Data Subjects.
In most cases, data will be shared with Data Processors established in Third Countries that are subject to an Adequacy Decision (Switzerland), which the Joint Data Controllers use for functional activities (Cybersecurity). Users may at any time request information on the methods of such processing by contacting the Joint Data Controllers.
10. Processing Based on Special Categories of Data
The data provided for the proper performance of the activity may also include sensitive/special category data. The processing of sensitive/special category data may only take place in specific cases, including where the data subject has given explicit consent for one or more specified purposes, which may be withdrawn at any time.
Sensitive/special category data are personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, health data, or data concerning a person’s sex life or sexual orientation.
11. Information to Be Provided Where Data Are Obtained from Other Data Controllers Pursuant to Article 14 GDPR
Where personal data have been provided by the data subject to a Data Controller other than the present Joint Data Controllers, the latter, in addition to the information above, must communicate, upon simple request by the data subject to the indicated email address, the source from which the personal data originate.
