Personal Data Protection Code under Art. 13 of Regulation No. 679/2016 GDPR.
via Pra Vicc 2
Data Protection Officer (DPO)
The Data Protection Officer (DPO), who has been designated to receive requests from data subjects to exercise their rights, is Atty. Barbara Anzani in Erba, who may be contacted by email: DPO-GDPR@metaltex.com.
General information on data processing
1. Scope of personal data processing
In general, we process our users’ personal data only to the extent necessary to provide a functional website and to ensure our content and services. Our users’ personal data are duly processed only after obtaining their consent, unless prior consent cannot be obtained for factual reasons and data processing is authorised by law.
2. Erasure of data and storage period
Personal data are erased or blocked when the purpose for which they are stored no longer applies. In addition, they can be stored where this is established by European or domestic regulations, laws or other provisions of the European Union which apply to the controller. Furthermore, data are blocked or erased at the end of the storage period established by the said provisions, unless they need to be additionally stored to enter into or perform a contract.
Supply of data to the website and creation of log files
1. Description and scope of data processing by the provider
When the user visits our website, the system automatically collects data and information from the IT system of the user’s computer.
The following data are collected:
- information on the type of browser and its version
- the user’s operating system
- the user’s IP address
- date and time of access
- websites from which the user visits our website
- visited pages, bandwidth consumption and date of last visit
- number of downloads relating to every document that can be downloaded from the website
2. Legal basis for data processing
The legal basis for the provisional storage of data and log files is represented by point f) of Article 6(1) GDPR.
3. Purposes of data processing
Our system’s temporary storage of the user’s IP address is necessary to ensure that the user’s computer can have access to our website. For this reason, the user’s IP address shall be saved throughout the session. Personal data are saved in log files to ensure website operation. In addition, these data are used to optimise our website and ensure the safety of our IT systems. In this context, data are not analysed for marketing purposes.
Our legitimate interests in processing data also fall within the scope of the said purposes within the meaning of point f) of Article 6(1) GDPR.
4. Storage period
Personal data are erased as soon as they are no longer necessary to achieve the purposes for which they were collected. If personal data are collected to be made available to the website, they are erased upon conclusion of the session. If data are stored in log files, they are erased within no later than seven days. A longer storage period may be possible. In this case, the user’s IP addresses are erased or distorted so that no reference can be made to the relevant client.
5. Possibility to object and eliminate data
The collection of data for their provision to the website and the storage of data in log files are essential to website operation. Therefore, the user may not object thereto.
1. Description and scope of data processing
You may contact us by email. In this case, your personal data provided by email will be saved.
In this context, your data will not be transmitted to third parties. Your data will be used solely to manage our conversation.
Encrypted communications are a possibility. Please contact us in this respect.
2. Legal basis for data processing
The legal basis for the processing of data sent by email is represented by point f) of Article 6(1) GDPR.
If the email communication is necessary for contract conclusion, a further legal basis for processing is represented by point b) of Article 6(1) GDPR.
3. Purposes of data processing
Also in case of email communications, processing is necessary for the purposes of the legitimate interests pursued.
4. Storage period
Personal data are erased as soon as they are no longer necessary to achieve the purposes for which they were collected, except where their storage is required on legal grounds or there is a mandate relationship. Personal data supplied by email are erased upon conclusion of the conversation with the user. The conversation comes to an end when it is inferred from the circumstances of the case that the facts in question have been definitely clarified.
5. Possibility to object and eliminate data
The user may withdraw his/her consent to the processing of personal data concerning him/her at any time. If the user contacts us by email, s/he may object at any time to the storage of personal data concerning him/her. In this case, the conversation comes to an end. Should you wish to exercise your rights in this respect, please contact us by using the contact details reported in the legal notes at the address firstname.lastname@example.org.
In this case, all personal data that have been saved during our communications will be erased.
Rights of the data subject
Where your personal data are processed, you are the data subject within the meaning of the GDPR and have the following rights vis-à-vis the controller:
1. Right of access
You shall have the right to obtain from the controller confirmation as to whether or not personal data concerning you are being processed.
Where that is the case, you may obtain from the controller access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed;
- the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and – at least in those cases – meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where personal data concerning you are transferred to a third country or to an international organisation, you shall have the right to be informed thereof. In this respect, you may ask to be informed of the existence of appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.
2. Right to rectification
You shall have the right to obtain from the controller the rectification of inaccurate personal data concerning you or to have incomplete data completed. The controller will provide for the rectification without undue delay.
3. Right to restriction of processing
You shall have the right to obtain from the controller restriction of processing of your personal data where one of the following applies:
- where you contest the accuracy of personal data concerning you, for a period enabling the controller to verify the accuracy of the said personal data;
- the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
- the controller no longer needs the personal data for the purposes of the processing, but they are required by yourself for the establishment, exercise or defence of legal claims, or
- you have objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override yours.
Where processing has been restricted under paragraph 1, your personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
If you have obtained restriction of processing in the aforesaid cases, you shall be informed by the controller before the restriction of processing is lifted.
4. Right to erasure
a) Obligation to erase data
You shall have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
- the personal data concerning you are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw consent on which the processing is based according to point a) of Article 6(1), or point a) of Article 9(2) GDPR, and where there is no other legal ground for the processing;
- you object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR;
- the personal data concerning you have been unlawfully processed;
- the personal data concerning you have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
- the personal data concerning you have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
b) Information to third parties
Where the processor has made the personal data concerning you public and is obliged pursuant to Article 17(1) GDPR to erase them, the processor, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data, that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
The right to erasure shall not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health in accordance with points h) and i) of Article 9(2) as well as Article 9(3) GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) GDPR in so far as the right referred to in paragraph a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defence of legal claims.
5. Right to notification
If you have exercised your right to rectification, the controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
The controller shall inform you about those recipients if you request it.
6. Right to data portability
You shall have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. You shall also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
- the processing is based on consent pursuant to point a) of Article 6(1) or point a) of Article 9(2) GDPR or on a contract pursuant to point b) of Article 6(1) GDPR; and
- the processing is carried out by automated means.
In exercising this right, you shall also have the right to have the personal data transmitted directly from one controller to another, where technically feasible. This right shall not adversely affect the rights and freedoms of others.
The right to data portability shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7. Right to object
You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point e) or f) of Article 6(1) GDPR, including profiling based on those provisions.
The controller shall no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Where personal data concerning you are processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
8. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 GDPR.