Privacy Policy
1 – General information about this website
This section contains information about the processing of the data of users and visitors who connect to the website owned by NOVA SIRIA S.R.L., accessible at www.novasiria.it (the “Website”), to describe the methods of website management, with reference to the processing of the personal data of users who consult and/or use the services and to allow them to know the purposes and methods of processing their personal data.
This information is also provided for the purposes of Article 13 of EU Reg. 2016/679 (GDPR – General Data Protection Regulation), concerning the protection of individuals with regard to the processing of personal data and the free movement of such data, for individuals who interact with the Website, which can be accessed at the address corresponding to its homepage: www.novasiria.it
The present privacy policy and the information contained in it are made only for the Website and not for further websites that may be consulted by the user through links contained in it and conforms to Recommendation no. 2/2001 on the minimum requirements for the collection of data online in the European Union, adopted on 17 May 2001 by the Article 29 Working Group.
This privacy policy and the information contained in it have the purpose of providing information about the types of data processed, the processing methods, data retention periods, the nature of the information and any other relevant aspects that the data controller must make known to users connecting to the web pages of www.novasiria.it, regardless of the purposes of the connection itself, in accordance with Italian and European legislation.
Consultation of the Website by the user involves the release of personal data. Please note that for the purposes of the applicable legislation, ‘processing’ of personal data means any operation or set of operations, whether or not by automated means, which are performed upon personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Before disclosing any personal data, we therefore invite users to carefully read this privacy policy, as it contains important information on the protection of personal data and the security measures adopted to ensure their confidentiality in full compliance with the GDPR and the applicable national legislation on the protection of personal data.
Please note that the Website is aimed at users over the age of 14, pursuant to Art. 8, par. 1 GDPR and Art. 2-quinquies of the Privacy Code. By connecting to the Website and providing their data, the data subject, that is the person to whom the data refer, declares to be over 14 years old.
2 – Data controller
The data controller is the natural or legal person, the public authority, the service or other body which, individually or together with others, determines the purposes and means of the processing of personal data. This entity is also required to identify and take appropriate technical and organisational measures to ensure a level of security of the personal data processed by them that is appropriate to the risk generated by the processing operations performed.
With regard to this Website, in light of the applicable legislation, the data controller is the company NOVA SIRIA S.r.l., with registered office in Via Marconi 4-6 – 10060 Roletto (TO), Italy, which for any clarification or exercise of user rights can be contacted at the following e-mail address: privacy@novasiria.it
3 – Data processor
The processor is the natural or legal person, public authority, service or other body that processes personal data on behalf of the controller.
Pursuant to Article 28 of the GDPR, the controller may appoint one or more data processors for the Website from among the entities that may have access to the personal data of the data subjects, i.e. third party service providers such as, for example, connectivity providers, hosting, IT companies as well as the software provider dealing with newsletters. 3.3.
A list of all data processors is kept at the aforementioned premises of the data controller and is available to users of the Website upon request.
4 – Data processing location
4.1. The processing connected to the web services of the Website takes place at the data centre of the company NOVA SIRIA SRL, with registered office in ROLETTO (TO) – ITALY, as well as at the controller’s premises and on their devices.
4.2. In case of necessity, the data connected to the web services of the Website can be processed by the data processors – each for its specific field of competence – or by subjects they have entrusted to it pursuant to art. 4 no. 10, GDPR, to that end, at their respective offices.
5 – Types of data processed and data processing method
5.1. It should be noted that, pursuant to the applicable legislation, “personal data” means any information relating to an identified or identifiable natural person with particular reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more characteristic elements of that person’s physical, physiological, psychological, economic, cultural or social identity.
5.2. The personal data collected by the Website are as follows:
A) Browsing data
The information systems of the Website collect some personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected in order to be associated with you, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. These include the IP addresses or domain names of the devices used by users who connect to the Website, the URI (Uniform Resource Identifier) notation addresses 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 response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to your operating system and computer environment.
These data are used for the purpose of obtaining anonymous statistical information on the use of the Website and to check its correct functioning; in order to allow – given the architecture of the systems used – the correct provision of the various functions requested by you, for reasons of security and of ascertainment of responsibility in case of hypothetical computer crimes against the Website or third parties.
(B) Data provided voluntarily
Apart from what has been specified above for the browsing data required for computer and telematic protocols, the provision of personal data by the Website users is free and optional, although it is functional to the provision of certain services: in these cases, therefore, the non-provision of data could compromise or make the provision of the service impossible.
In particular, through the Website you have the opportunity to voluntarily provide personal data, such as, for example, name, surname, date and place of birth, address of residence, tax code and VAT number, company name, address of the registered office, landline and/or mobile telephone number, e-mail address, PEC address, bank and payment details, other data by filling in the “Contact us” form on the Website or by creating a Customer account on the Website for the purchase of products offered on the Website or in the event that the person concerned subscribes to the newsletter service by filling in the appropriate form or by sending, always optional and voluntary, e-mail messages containing contact requests, requests for quotes, spontaneous applications with a CV or by sending any type of communication to the addresses indicated on the Website. The sending of such communications will entail the acquisition of your e-mail address, necessary to respond to your requests and of any other personal data transmitted by you. Such data provided by users who voluntarily interact with the Website, are used only for the purpose of performing the requested service and are communicated to third parties only if this is strictly necessary for the performance of said service or required by law.
C) Content sharing via social networks
If the Website user decides to share certain content via social networks, for example through Facebook, Instagram, LinkedIn or YouTube, the Website may access some of their account information if the user has activated the sharing of their account data with third party applications.
We inform you that you can deactivate the sharing of your account data with third-party applications by accessing your account settings. For more information on the logic and methods of processing the data collected by social networks, users are invited to read the privacy notices of the entities providing the services in question; for example:
– LinkedIn
– Google, YouTube
– Facebook
– Instagram
(D) Cookies and similar technologies
(i) Type of cookies
The Website uses cookies that have the function of making the user’s browsing experience easier and more intuitive: they are small text strings used to store some information that may concern the user, their preferences or the device used to access the Internet. Cookies are used to ensure that a personalized browsing experience is offered, by storing the choices made by the user previously and adapting the operation of the Website to their expectations.
A cookie consists of a small set of data transferred to the user’s browser by a web server and can only be read by the server that transferred it. This is not an executable code and does not transmit viruses.
Cookies may record personal information and any data that allows the identification of the person concerned may be stored. If you wish, you can delete some or all cookies by following the instructions below.
The following describes the individual types of cookies that can be transmitted from a website, with an indication of which cookies are used by the Website.
(ii) Technical cookies
Technical cookies allow Website browsing and facilitate the access and safe use of the same by the user. They are necessary for the transmission of communications on electronic network or to the supplier to provide the service requested by the customer.
The settings for managing or disabling cookies may vary depending on the browser used by the user. The user, however, can manage or request the general deactivation or deletion of cookies by modifying the settings of the browser used. Disabling or deleting cookies may slow down or prevent access to certain parts of the Website.
Cookies that are inserted in the browser and retransmitted through the Google Analytics service (collected at the will of the Website Owner in a totally anonymous way) or others with similar functions are to be considered technical when used for the optimisation of the Website directly by the owner; in this case, they may only collect information in an aggregated and anonymous way about the number of users and how they visit the Website. Under these conditions, for cookies analytics, the same rules apply, in terms of information and consent, as for technical cookies.
From the point of view of duration, two types of cookies can be distinguished: temporary cookies, which are automatically deleted at the end of the browsing session and are used to identify the user, so as to avoid logging in on each page visited; permanent ones, which remain active in the browser used by the user until the pre-set expiry (by the third party supplying the cookie or by the owner of the Website that adopts it) or the cancellation by the user.
The Website may install session cookies in the browser used by the user, which allow the user to access and remain in the reserved area of the Website as an authenticated user.
(iii) Third party cookies
Depending on where they come from, cookies are distinguished between those directly sent to the browser used by the user from the website being visited and those set by third parties.
Most third-party cookies are tracking cookies used to identify users’ online behaviour, understand their interests, and then personalise their advertising proposals.
The use of these cookies is governed by the rules laid down by the third parties themselves, therefore, users are invited to look at the privacy statements and the indications to manage or disable the cookies published on the relevant web pages.
(iv) Profiling cookies
Profiling cookies are those that create user profiles that are then used to send advertisements that are in line with the preferences expressed by the user when browsing the web.
In case of use of this type of cookies by the owner, the user must give an explicit consent. Article 22 of EU Reg. 2016/679 and Article 122 of Legislative Decree no. 196/2003 (Privacy Code) will apply.
The Website uses profiling cookies.
v) Support in the configuration of the browser used by the user
The user can also manage cookies through the settings of the browser used. By deleting cookies from the browser used, the user may remove the preferences they have set for the Website or may experience delays, problems, or inability to access certain services.
For more information and support about this, please visit the specific page of the main available browsers:
– Internet Explorer, Edge
– Firefox
– Safari
– Chrome
More information on the use of cookies and similar technologies can be found here.
E) External links
The Website contains links to external websites of third-party producers/suppliers of goods and/or services with which NOVA SIRIA S.R.L. may cooperate. The Controller is not responsible in any way for the collection and processing of data by such third parties and invites users to read the privacy notices provided by them.
5.3. For security purposes (spam filters, firewalls, virus detection), the automatically recorded information and data referred to in paragraph 5.2 A) above may be used to block attempts to damage the Website or other harmful or criminal activity, based on the legitimate interests of the controller and pursuant to the applicable legislation.
5.4. In the event of sending a Curriculum Vitae for a possible work relationship or collaboration request, the data is understood to be voluntarily provided by the user at the time of the service request. The Curriculum Vitae will be examined and, should it be saved or in any case retained for future employment relationships, a summary notice will be provided to the user concerned in accordance with current legislation.
5.5. The information that the users of the Website consider making public through the services and the instruments made available to them is provided by the user consciously and voluntarily, exempting the Website as well as NOVA SIRIA S.R.L., its directors, members, employees, partners and collaborators, from any liability in respect of possible violations of the law. It is up to the user to verify that they have the permission to enter personal data of third parties obtained, published, or shared through this Website and the user guarantees that they have the right to communicate or disseminate them; it is also the responsibility of the user to verify that they have permission to enter any content protected by national and international standards.
5.6. The collection and processing of personal data is carried out in accordance with the principles of legality, correctness, and transparency and in order to guarantee an adequate security, including protection, by means of appropriate technical and organisational measures, from unauthorized or unlawful processing and from accidental loss, destruction or damage.
5.7. The processing connected to the web services of the Website are mainly carried out with automated and electronic instruments and handled by the NOVA SIRIA S.R.L. personnel authorised for this purpose to process personal data, as well as by third parties in their capacity as data processors specifically appointed and instructed by NOVA SIRIA S.R.L. as data controller and in relation to the specific activities performed, or by independent “data controllers” authorised to access the data by virtue of legal provisions, regulations and standards.
6 – Purpose of processing, legal basis and retention period
6.1. All personal data provided by users through the Website will be processed for purposes related to the purposes for which they have been collected and in particular:
A) execution of a contract for the supply/sale of products and/or services offered on the Website or fulfilment of pre-contractual information obligations;
B) for the purpose of statistical research/analysis on aggregated or anonymous data, without therefore the possibility of identifying the user, aimed at measuring the functioning of the Website, measuring traffic and evaluating usability and interest;
C) for marketing purposes; in particular, the controller may process your contact data for marketing and advertising purposes, aimed at informing you about the products and services offered, carried out by means of automated contact methods (e-mail, sending newsletters, etc.) and traditional contact methods (e.g., telephone calls with an operator) or for market research and statistical surveys, if you give your consent.
6.2. Please note that apart from what is specified for browsing data, the user is free to provide personal data to send communications to the addresses indicated on the Website, to make requests for information or for the purposes of sending commercial communications.
D) for purposes related to the fulfilment of a legal obligation to which NOVA SIRIA S.R.L. is subject;
E) for purposes necessary to establish, exercise or defend a right in court or whenever the judicial authorities exercise their jurisdictional functions;
6.3. The legal basis for the processing of personal data for the purposes referred to in paragraph 6.1 A) above is the provision of a service or the acknowledgement of a request that does not require consent under the applicable law. The purpose of paragraph 6.1 B) above does not involve the processing of personal data. The legal basis for the processing of personal data for marketing purposes and for sending commercial and informative communications referred to in paragraph 6.1 C) above is the consent of the user (data subject), given when a contract is entered into between NOVA SIRIA S.R.L. and the user or when the dedicated form on the Website is filled in. The purposes referred to in point 6.1 D) and E) represent legitimate processing of personal data within the meaning of the applicable legislation since, once the personal data has been provided, the processing is indeed necessary to fulfil a legal obligation to which the data controller is subject or to exercise their right of defence in court.
6.4. The information referred to in Art. 5.1 will be kept for the period of time strictly necessary to achieve the aforementioned purposes and in any case not longer than the termination of the aforementioned purposes, except where it is required to be kept by law. The data may also be kept for the period required by the data controller or by any designated data processors to ascertain, exercise or defend their rights in court, within the limitation period of any civil or criminal actions that may be brought against them.
6.5. In case of processing of personal data based on the consent of the user, the controller may retain the personal data until said consent is withdrawn.
7 – Compulsory or optional nature of providing data and consent
7.1. We inform you that, considering the purposes of the processing as described above, the provision of your personal data for the purposes mentioned in the previous art. 6.1 A), B), D), E) is mandatory. Any failure to provide data, partial or incorrect provision of data and/or any express refusal to provide such data will make it impossible for the data controller to respond to your requests, to process your purchase order, to fulfil its contractual obligations to supply products and/or services or to comply with a legal obligation to which the data controller is subject or with requests from the competent authorities.
7.2. The legal basis for the processing of personal data for the marketing purposes referred to in Section 6.1, point C) above is, on the other hand, consent. The provision of data for such purposes is optional, with the consequence that you may decide not to give your consent or to withdraw it at any time. Failure to consent to the processing does not have any consequences on contractual relations, but only entails the impossibility of receiving the other services described above.
8 – Recipient categories
8.1. The personal data of the Website users may be shared, for the purposes specified in point 6.1 above, with:
A) subjects that are necessary for the provision of the services offered by the Website, including by way of example the sending of e-mails and the maintenance and analysis of the operation of the Website and other external subjects, each for their specific field of competence, with whom the owner maintains relations necessary for the performance of its activities or by law, to whom a specific mandate has been entrusted and for the time necessary to achieve the purposes for which the data were collected, who act, where necessary, as data processors of NOVA SIRIA S. R.L.; these categories include, purely by way of example, system administrators, technical service providers, hosting providers, IT companies, communication agencies, etc, who are appointed, when necessary or appropriate, as external data processors.
B) individuals authorised by NOVA SIRIA S.R.L. for the processing of personal data who have committed themselves to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees and collaborators), by reason of and within the limits of the tasks and duties assigned to them
C) Group companies for the pursuit of legitimate interests related to the carrying out of organisational and technical activities related to the purposes set out in Art. 6.
C) judicial or supervisory authorities, administrations, public bodies, and organisations, in the performance of their duties, when required by law.
8.2. In any case, no data deriving from the web services of the Website, except in anonymous and aggregated form, is disseminated.
9 – Transfers
9.1. Some of your personal data may be transferred to recipients outside the European Economic Area. The controller shall ensure that the electronic and paper processing of such data takes place in accordance with the applicable law. In fact, transfers are based either on an adequacy decision or on Standard Model Clauses approved by the European Commission.
9.2. No data will ever be transferred to third countries that do not comply with the conditions laid down in Art. 45 et seq. of EU Reg. 2016/679.
10 – Copyright
10.1. All texts, graphics, possible sound files, videos, images, animations and more generally all the information contained in the Website are the property of NOVA SIRIA S.R.L. and are protected by international copyright laws and other laws in force on the protection of intellectual property.
10.2. None of the content referred to in the preceding paragraph may be copied, modified or resold, either wholly or in part, for profit or to derive benefit of any kind whatsoever.
10.3. Icons, trade logos and names of third parties and products on the pages of this Website are the property of the respective owners and are protected under copyright, patent and intellectual property laws.
11 – Appointment of the D.P.O.
11.1. The DPO is a professional with specialist knowledge of data protection legislation and practices, who must be mandatorily appointed by the data controller or processor in the cases indicated in Art. 37 EU Reg. 2016/679.
11.2. The DPO, pursuant to Art. 39 EU Reg. 2016/679 is responsible for at least the following tasks: (a) to inform and advise the data controller or processor and the employees performing the data processing on the obligations arising from this regulation and other provisions of the Union or Member States relating to data protection; (b) to monitor compliance with this regulation; other provisions of the Union or of the Member States relating to data protection and the policies of the data controller or data processor with regard to the protection of personal data, including the allocation of responsibilities, raising awareness and training of staff involved in the processing and related monitoring activities; (c) to provide, if required, an opinion on the impact assessment on data protection and to monitor the conduct of such an assessment in accordance with Art. 35 EU Reg. 2016/679; d) to cooperate with the supervisory authority; (e) to act as a point of contact for the supervisory authority for matters relating to processing, including prior consultation as referred to in Art. 36, and consult, where appropriate, on any other matter.
11.3. Since the data controller does not fall under the cases indicated in Art. 37 of the GDPR, nor under those indicated in the various interpretations of the Supervisory Authority, it did not deem it necessary to appoint a Data Protection Officer.
12– Rights of the data subject
12.1. NOVA SIRIA S.R.L. intends to inform you that, in accordance with the provisions of the GDPR, the user, as a data subject, may exercise the following rights:
a) right of access – obtain confirmation that your personal data is being processed or not and, in such a case, receive information relating, in particular, to: purpose of the processing, categories of personal data processed and period of retention, recipients to whom they can be communicated (art.15, GDPR);
b) right of rectification – to obtain, without undue delay, the correction of incorrect personal data concerning it and the integration of incomplete personal data (Article 16, GDPR);
c) right to erasure – to obtain, without undue delay, the erasure of personal data concerning you, in the cases provided for by the GDPR (Art. 17, GDPR);
d) right to restriction – to obtain from the Controller the restriction of processing, in the cases provided for by the GDPR (Art.18, GDPR);
e) right to portability – to receive, in a structured, commonly used, and machine-readable format, the personal data concerning you provided to the Controller, as well as to obtain that they be transmitted to another controller without hindrance, in the cases provided for by the GDPR (Art. 20, GDPR)
f) right to object – to object to the processing of personal data concerning you, unless there are legitimate grounds for the Controller to continue the processing (Art. 21, GDPR);
g) right to withdraw any consent given at any time, without prejudice to the lawfulness of the processing based on the consent given before the revocation;
h) right to lodge a complaint with the Data Protection Authority or other supervisory authority (Art. 77, GDPR).
12.2. Requests can be addressed to the data controller, without formalities or, alternatively, using the form provided by the Personal Data Protection Authority, or by sending an e-mail to: privacy@novasiria.it
13 – Personal data security measures taken
13.1. This Website processes user data in a lawful manner and in compliance with the GDPR as well as with current Italian legislation (Legislative Decree no. 196/2003 and subsequent amendments and additions), adopting security measures appropriate to the risk profiles mapped out, aimed at avoiding personal data breaches, in the form of unauthorised access, unauthorised disclosure, modification or destruction of data. Processing is carried out by means of computer and/or telematic tools, with organisational methods and according to logics strictly related to the purposes indicated in Art. 6 above.
13.2. In addition to the data controller, categories of individuals authorised to process personal data involved in the organisation and management of the website (administrative, sales, marketing, legal, system administrators, etc.) or external parties responsible for outsourcing services to the data controller (such as technical service providers, hosting providers, IT companies, communication agencies) may have access to the processed data and are appointed, when necessary or appropriate, as external data processors.
13.3. The list of external data processors on behalf of the data controller, as well as the list of individuals authorised to process data under the direct authority of the data controller, will be kept up-to-date and can be requested at any time by writing to: privacy@novasiria.it
14 – Changes to this document
14.1. NOVA SIRIA S.R.L. reserves the right to modify or simply update the content of this document, partly or completely, also due to variations in the applicable legislation. We therefore invite you to visit this section of the Website regularly to become aware of the latest version of the privacy policy so that you are always up to date on the data collected and on their use.