All user data, whether directly or indirectly related to natural persons, is processed in a lawful, fair and transparent manner in relation to the data subject, in accordance with the general principles set out in Article 5 of the GDPR.
We have adopted specific security measures to prevent data loss, illicit or incorrect use, and unauthorised access.
Our privacy policy does not involve the processing of personal data of individuals under the age of 18. Therefore, this website and the services connected to it are not intended to intentionally collect personal information relating to minors. In the event that information on minors is unintentionally recorded, the Data Controller will delete it promptly, directly and/or at the request of users.
The Data Controller is responsible for the processing of personal data of individuals under the age of 18.
Data Controller
INDEVO s.r.l.
Via Goffredo Mameli, 14 – 21013
Gallarate (VA) – VAT number 03894240120
Email address of the Data Controller: info@indevo.it
Certified email address of the Data Controller: indevo@pec-legal.it
Types of Data collected
Among the Personal Data collected by this website, either independently or through third parties, are: Cookies, Usage Data, First Name, Last Name, Company Name, Email Address, Phone Number, IP Address, and other data provided voluntarily by the user.
Full details on each type of data collected are provided in the dedicated sections of this Privacy Policy or through specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this website.
Unless otherwise specified, all data requested by this website is mandatory. If the User refuses to provide it, it may be impossible for this website to provide the Service. In cases where this website indicates that certain data is optional, Users are free to refrain from providing such data, without this
having any impact on the availability of the Service or its operation.
Users who have doubts about which data is mandatory are encouraged to contact the Data Controller.
The use of cookies – or other tracking tools – by this website or by the owners of third-party services used by this website, unless otherwise specified, is for the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this website and guarantees that they have the right to communicate or disseminate it, releasing the Data Controller from any liability towards third parties.
Methods and location of processing of collected data
Treatment methods
The Data Controller shall take appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and/or telematic tools, with organisational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organisation of this website (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Data Controller.
The updated list of Data Processors can always be requested from the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.
Legal basis for processing
The Data Controller processes the User’s Personal Data if one of the following conditions exists:
- the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Data Controller may be authorised to process Personal Data without the User’s consent or any of the other legal bases specified below, until the User objects (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
- the processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;
- processing is necessary for compliance with a legal obligation to which the Controller is subject;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
- the processing is necessary for the pursuit of the legitimate interests of the Data Controller or of third parties.
However, it is always possible to ask the Data Controller to clarify the specific legal basis for each processing operation and, in particular, to specify whether the processing is based on the law, provided for in a contract or necessary for the conclusion of a contract.
Location
The Data is processed at the Data Controller’s operational headquarters and in any other place where the parties involved with the Data Controller are located.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. For further information on the place of processing, the User may refer to the section on the details of the processing of Personal Data.
In the event of superior protection, the User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organisation governed by public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
Should any of the transfers described above take place, the User may refer to the relevant sections of this document or request information from the Data Controller by contacting them at the details provided at the beginning of this document.
Retention period
The Data is processed and stored for the time required for the purposes for which it was collected.
Therefore:
- Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of that contract is completed.
- Personal Data collected for purposes related to the legitimate interests of the Data Controller will be retained until such interests are satisfied. The User may obtain further information regarding the legitimate interests pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
When the processing is based on the User’s consent, the Data Controller may store the Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to store Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, Personal Data will be deleted. Therefore, upon expiry of this period, the right of access, deletion, rectification and the right to data portability can no longer be exercised.
Purpose of the processing of collected data
User Data is collected to enable the Data Controller to provide its Services and Products, as well as for the following purposes: Contacting the User, Marketing Statistics.
For further detailed information on the purposes of the processing and on the Personal Data specifically relevant to each purpose, the User may refer to the relevant sections of this document.
Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Contact the User
Contact form for this website.
By filling in the contact form with their personal details, users consent to their use for the purpose of responding to requests for information, quotations or any other matter indicated in the form header.
Personal Data collected: Name, Surname, Company Name, Email Address, Telephone Number.
Statistics
The services contained in this section allow the Data Controller to monitor and analyse traffic data and are used to track User behaviour.
Google Analytics (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this website, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualise and personalise the advertisements of its advertising network.
Personal Data collected: Cookies, Usage Data and IP Address.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Marketing
Personal data collected by this website may be processed for marketing and promotional activities relating to the products and services featured on this website, in full compliance with GDPR guidelines, by sending commercial information and, in particular, by:
- Sending newsletters relating to the products and services of this website;
- Sending commercial information about the products and services offered by this website;
- telephone contacts.
Personal Data collected: Name, Surname, Company Name, Email Address, Telephone Number.
Other data provided voluntarily by the user
The optional, explicit and voluntary sending of e-mails and/or ordinary mail to the addresses indicated on this website, as well as the completion of information request forms, entails the subsequent acquisition of the sender’s address, which is necessary to respond to user requests, as well as any other personal data included in the message. The sender must in any case refrain from sending information falling within the “special categories of data” provided for in Article 9 of the GDPR; if received, such information will be deleted and will not be processed in any way by the Data Controller.
User Rights
Users may exercise certain rights with regard to the Data processed by the Data Controller.
In the event of superior protection, the User may exercise all of the rights listed below. In any other case, the User may contact the data controller to find out what rights they have in their case and how to exercise them.
In particular, the User has the right to:
- Withdraw consent at any time. The User may withdraw their previously given consent to the processing of their Personal Data.
- Object to the processing of your Data. You may object to the processing of your Data when it is based on a legal basis other than consent. Further details on the right to object are provided in the section below.
- Accessing your Data. You have the right to obtain information about the Data processed by the Data Controller, about certain aspects of the processing and to receive a copy of the Data processed.
- Verify and request rectification. The User may verify the accuracy of their Data and request that it be updated or corrected.
- Obtain restriction of processing. Under certain conditions, the User may request that the processing of their Data be restricted. In this case, the Data Controller will not process the Data for any purpose other than storage.
- Obtain the deletion or removal of your Personal Data. Under certain conditions, you may request that the Data Controller delete your Data.
- Receiving your Data or having it transferred to another data controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred to another data controller without hindrance. This provision is applicable when the Data is processed by automated tools and the processing is based on the User’s consent, on a contract to which the User is party or on contractual measures related to it.
- Lodge a complaint. The User may lodge a complaint with the competent personal data protection supervisory authority or take legal action.
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users are advised that, if their Data is processed for direct marketing purposes, they may object to the processing without providing any reason. To find out whether the Data Controller processes data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise your rights
To exercise their rights, Users may send a request to the contact details of the Data Controller indicated in this document. Requests are submitted free of charge and processed by the Data Controller as quickly as possible, and in any case within one month.
Applicability of the higher level of protection
While most of the provisions of this document apply to all Users, some are expressly subject to the applicability of a higher level of protection for the processing of Personal Data.
This higher level of protection is always guaranteed when the processing:
- is carried out by a Data Controller based in the EU; or
- concerns Personal Data of Users located in the EU and is functional to the provision of goods or services, whether paid or free of charge, to such
Users; or - concerns Personal Data of Users located in the EU and allows the Data Controller to monitor the behaviour of such Users to the extent that such behaviour takes place within the Union.
Cookie Policy
This website uses cookies. To learn more and to view the detailed information,
the User may consult the Cookie Policy.
Further information on processing
Legal defence
The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages of any legal proceedings to defend against abuse
in the use of this website or the related Services by the User.
The User acknowledges that the Data Controller may be required to disclose the Data by order of public authorities.
Specific information
Upon request by the User, in addition to the information contained in this privacy policy, this website may provide the User with additional and contextual information concerning specific Services, or the collection and processing of Personal Data.
System logs and maintenance
For operational and maintenance purposes, this website and any third-party services it uses may collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the User’s IP address.
Information not contained in this policy
Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details provided.
Response to “Do Not Track” requests
This website does not support “Do Not Track” requests.
To find out whether any third-party services used support them, the User is invited to consult the respective privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this website, as well as, where technically and legally feasible, by sending a notification to Users via one of the contact details held by the Data Controller. Please therefore consult this page regularly, referring to the date of the last modification indicated at the bottom.
If the changes affect processing operations whose legal basis is consent, the Data Controller will obtain the User’s consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, identifies or makes identifiable a natural person.
Usage Data
This is information collected automatically through this website (including from third-party applications integrated into this website), including: the IP addresses or domain names of the computers used by the User connecting to this website, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various time characteristics of the visit (e.g. the time spent on each page) and details of the route taken within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.
User
The individual who uses this Website, who, unless otherwise specified, is the Data Subject.
Interested
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural person, legal entity, public administration, and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.
Data Controller (or Controller)
The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of personal data processing and the tools adopted, including the security measures relating to the operation and use of this website. Unless otherwise specified, the Data Controller is the owner of this website.
This website (or this Application)
The hardware or software tool through which Users’ Personal Data is collected and processed.
Service
The Service provided by this Website as defined in the relevant terms (if any) on this website/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document shall be understood to extend to all current member states of the European Union and the European Economic Area.
Cookies
A small portion of data stored within the User’s device.
Legal references
This privacy policy has been drafted on the basis of multiple legislative provisions, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy applies exclusively to this website.
Last modified: 15 January 2020