This Informative Notice contains the policy, practice and liability undertaken in accordance with the provisions of Legislative Decree 30 June 2003, n. 196 (Personal Data Protection Act hereinafter referred to as the “Privacy Act”), and in compliance with the applicable European Community rules regarding the subject, and applies to the persons (hereinafter referred to as the “Users”) who choose to access the Website inimdns.biz (hereinafter referred to as the “Site”), property of INIM Electronics S.r.l. (hereinafter referred to as “INIM”), as well as the navigation of the same and use of the services existing therein, irrespective of the purchase of products.
1. The data holder, controllers and processors.
The data holder is INIM Electronics S.r.l., single-member company with registered office in Via dei Lavoratori 10, 63076 Monteprandone (AP), Tax Code and VAT no. 01855460448, share capital of € 1,000,000.00 (one million); INIM independently establishes the purposes and methods of processing, as well as security procedures to be applied to ensure the confidentiality, integrity and availability of data.
In compliance with the provisions of the Privacy Act, INIM may designate one or more persons, such as controllers within the meaning and effect of art. 29 of the Privacy Act.
In the event of appointment, the list of personal data controllers will be available at the Registered Office of INIM; for further details please send an e-mail to the following address: firstname.lastname@example.org.
The “data processors” conduct their activities in accordance with the instructions given them by INIM and under INIM's control; INIM periodically verifies that the “data processors” have fulfilled their tasks and continue to offer sufficient guarantees in full compliance with the provisions on the protection of personal data.
It should be noted, however, that the processing operations relative to the User's personal data are carried out by appointed persons, who perform such activities under the direct authority of INIM or data processors, in accordance with the instructions given to them.
2. Type of data processed and optionality/obligatoriness of providing data.
The simple navigation of the Site involves the collection by INIM of so-called “navigation data”, the transmission of which is implicit in the use of Internet communication protocols.
This technical data is collected and used only in an aggregated and non-identifiable way, but may be used to ascertain responsibility in the event of hypothetical crimes against the Site. However, navigation data does not in itself identify the User. The Site offers specific services that benefit the User and for which the User must provide additional data, classified as personal data. For example, registration to the Site, access to reserved areas on the Site and the purchase of INIM products and services, are all activities that involve the transfer by the User of personal data that permit INIM to uniquely identify the User such as, but not limited to, name, surname, date of birth, address of residence and/or home address, telephone number, email address, credit card data.
It is expressly understood that the transfer of such personal data is optional, but becomes mandatory in order to enable the User to access certain services on the Site. The waiver to provide personal data, therefore, will have no consequences for the User, but in the absence of the conferment of data for the purposes indicated will prevent INIM from providing the User with certain services. In order to promote and improve our products, services and contents, INIM reserves the right to aggregate personal information and non-personal information. In this case, non-personal information will be processed as personal data until it remains aggregated to the latter.
3. Purposes and methods of processing.
The processing of personal data is done mainly through electronic and computer systems and is carried out by INIM and other parties who are selected with care for their reliability and competence, and who conduct operations in such a way as to achieve the purposes strictly related to the use of the Site, its services [and the purchase of products through the Site].
The specific methods and purposes of the processing of the User's personal data are indicated from time to time, in the Informative Notice, pursuant to art. 13 of the Privacy Act, which INIM provides for the User upon release of personal data by the latter.
In general, the processing of User data by INIM is implemented in order to allow:
- registration with the Site or adhesion to the services offered by INIM through the Site;
- the implementation of activities related, instrumental or necessary to the supply of INIM services, including disclosure of data to third party companies who, without limitation, perform necessary or fundamental activities for the provision of INIM services or who manage payments on the Site;
- the recognition of the degree of satisfaction and preferences of the User;
- the management of payments, including fraud control in case of payment by credit card;
- the management of the User's requests: technical, commercial, concerning the state of progress of orders and general in nature;
- the sending, after obtaining consent, of advertising material, communications and commercial information, as well as the sale to third parties of data processed for commercial purposes for the sale or potential sale, or for all purposes of a commercial and/or statistical nature under current legislation. Consent granted to INIM for the sending of commercial and promotional communications pursuant to art. 130, paragraphs 1 and 2, of the Privacy Act (so-called "Direct Marketing") implies consent to the sending of said communications not only through automatic means, but also through traditional means (paper mail and phone calls through an operator). In these circumstances, the User has the right to grant their consent to the receipt of such communications only through traditional methods of contact;
- the profiling of the User, after obtaining consent, in order to allow INIM to process the choices, habits and propensities of the User that are subsequently used to target advertisements and send specific offers regarding INIM products and services.
The User data will be disclosed to third parties only with the User's express consent, except in cases where the disclosure is required by law or is required for purposes envisaged by the law for the prosecution of which consent is not required; in such cases, the data may be made available to third parties who will process it independently and exclusively for such purposes (e.g. in the case of a request made by the police or by the courts or other competent authorities, or to perform obligations arising from the contract with the User, as is the case of communications to the bank responsible for payment of the products purchased).
Any other processing purpose different from the specification for which the User has provided their personal data will be highlighted in this form and will be carried out by INIM only after obtaining the User's express consent.
There are processing procedures for which the law establishes the exclusion of consent. For example, the processing of personal data can take place without obtaining the User's consent when it becomes necessary to fulfill a legal obligation or when it is necessary to execute the contractual obligations undertaken with the User.
Also, please note that INIM, pursuant to art. 130, paragraph 4 of the Privacy Act, has the right to use the User's personal data, without the need to obtain expressed consent, for the business of direct sales involving products similar to those the User has already purchased and for opinion polls, provided that the User has not refused such use with reference to the e-mail address communicated to INIM.
The User's personal data will not be transferred to foreign countries, other than European Union countries, which do not provide a sufficient level of privacy protection. Should this be necessary in order to provide services or to finalize a contract for the purchase of products, INIM ensures that the transfer of the User's personal data to countries that do not belong to the European Union and which do not ensure an adequate level of protection will be implemented only after the finalization between INIM and such parties of specific contracts in accordance with the current law and regulations.
4. Redirecting to external sites.
The Site may use so-called social plugins. Social plugins are special tools that allow Users to incorporate the functionality of social networks directly within the Site (e.g. The “Like” button on Facebook).
All social plugins on the Site are marked by the respective property logo of the social networking platform.
When the User visits a Site page and interacts with a plugin (e.g. by clicking the “Like” button) or decides to leave a comment, the corresponding information will be transmitted from the User's browser directly to the respective social networking platform (Facebook this case) and stored.
5. Connecting to/from third party sites.
The User can connect through special links on the Site to other third-party websites.
INIM does not control or monitor such websites or their content.
Links to other websites do not imply any endorsement by INIM or responsibility in regard to access and navigation by the User of such websites, or any guarantee of their contents, services or goods provided by them and sold to Users.
INIM, therefore, declines all responsibility regarding the content of these websites and the regulations adopted by them, even with regard to the protection of personal data and its processing during navigation within the websites in question.
6. The rights of persons concerned.
Under Article. 7 of the Privacy Act, the “person concerned”, understood as the person to whom the personal data refers, has the right to obtain confirmation as to whether or not personal data concerning them exists, even if not yet stored by INIM, and its communication in an intelligible form. The person concerned has the right to obtain information regarding:
- the origin of personal data;
- the purposes and methods of processing;
- the logic applied in the case of processing with the aid of electronic tools;
- the identity of the holder, the controllers and the representative appointed in compliance with article 5, paragraph 2 of the Privacy Act;
- the persons or categories of persons to whom the data may be communicated or who may become acquainted with the data as appointed representatives of the State, persons responsible or appointees.
- updating, rectification or, when interested, integration of data;
- the cancellation, anonymization or blocking of any personal data processed unlawfully, including data whose retention is unnecessary for the purposes for which the personal data was collected or subsequently processed;
- certification that the operations mentioned in points a) and b) have been notified, also as regard to their content, to whom the data was communicated or disclosed, except where such compliance proves impossible or involves means that are manifestly disproportionate to the protected right.
- for legitimate reasons to the processing of personal data, pertinent to collection purposes;
- to the processing of personal data for the purposes of sending advertising materials or direct selling or for the carrying out of market research or commercial communications.
7. Security Measures
However, INIM cannot guarantee to Users that the measures taken for the security of the Site and the transmission of personal data and information on the Site will prevent or exclude risk of unauthorized access or dispersion of data via the User's own devices; it is suggested, therefore, that the User checks the security of the computer or device in use and makes sure that it is equipped with appropriate security software (such as updated antivirus systems) for the protection of incoming and outgoing data transmissions on the network, and that the User's Internet service provider has taken appropriate measures for the security of network data transmission (such as firewalls and spam filters).
Updated on 01.12.2016