1) Identity and contacts of the Owner
The owner of the data collected is the company Cinque Sensi S.r.l. with its registered office in Via Pacinotti n. 2, Malo (VI) that can be contacted by sending a letter to its postal address, or by sending an email to its email address: [email protected] or certified mail: [email protected]
2) Types of data collected
Navigation data: the informatical systems and the application procedures used for the functioning of the site collect, during the normal operation, some personal data, its trasmission is implicit during internet comunication protocols.
In this category there are the IP addresses or computer domain names used by the users who visit the site, addresses in notation URI (Uniform Resource Identifier) of resources required, the request hour, the way used to do the request to the browser, the dimension of the file obtained in response, the numeric code that shows the code of the response given by the server (success, error, ecc.) and other parameters related to the operating system and to user’s IT environment.
This information is not associated to a specifical user; they could make possible the identification of a user, for example by the IP address used to connect, but this could happen only by the association and the elaboration with the data owned by third-party sites, that aren’t part of the normal purposes of the Owner .
The navigation data in fact are normally used by the owner only for the purpose to collect statistics information about the use of this site and to control the normal functioning, the data could be view by the judicial authority for the assessment of liability in the event of hypotetical cybercrime: unless this situation, the data will be conserved for at most 2 years after the elaboration.
Cookies: “Cookies” are small files that, at a time when the user visit the website www.5sensi.it or uses it’s services, can be placed on user’s device (computer, tablet, smartphone, other) and can be used for several activities: to allow to the user a protected and efficient navigation, to monitor the use and the website operation, to analyze the aggregated models, to do marketing operations.
The data given by the user voluntarily:
a. by sending an email
The data collected by sending an email to email addresses indicated on this site entails the future treatment of the sender’s address and of the other information in the letter, for the only purpose to answer to the users request, as well as the other data that is present in the letter.
We invite our users to avoid sending information as names or other third-party personal data that aren’t strictly necessary, we suggest to use, when possible, fantasy names.
The personal data given by the user that send an information request are used only to answer to it, and personal data is comunicated to third-party only when it’s necesary for the purpose.
b. Data given by compilating and sending other modules already prepared, registration to the personalized account ad submitting to the newslettter
In some pages Cinque Sensi S.r.l. proposes specifical services that need different personal data but strictly necesary for the esecution of the service requested (es. name, address, e-mail). The data given by the user will be used by the Owner only to give to user the service requested. In any moment the user can ask to Cinque Sensi S.r.l. to stop immediately the treatment of the personal data by sending an email to [email protected]
The treatment of the data is made by trained employers by using electronical struments, and in the case of periodical generation of information (by submission to the newsletter) by automated methods: in particular, in this case the employers addicted or more specifically an external company nominated as the outside Data controller, will provide to enter the mail address given by the user in the mailing list of LA GIARDINIERA DI MORGAN ; the next dispatch will be automated. The data of the user could also be communicated to third-side partenrs of Cinque Sensi srl when necessary for the purpose.
3) Purposes, legal bases of the proccessing and voluntary agreement
Except for the navigation data and for the cookies as specified in the policy, the user can give its own data voluntarly ( name, surname, email) by sending an email or by compilating the form or by the registration to the site with a personal account, for the request of more information or other communication during a pre-contractual stage or in order to buy the products on the site LA GIARDINIERA.
Cinque Sensi S.r.l. uses only strictly necessary data to the realization of the tasks assigned, for the following purposes :
a) the purpose to take further the service, by providing the information asked by the user, during the first step of a pre-contractual stage and the possible establishement and performance of the contract, in order to fulfill its obligations it’s necessary to collect user’s data. The treatment of the personal data for this purpose has its legal basis in the article 6.1.b ( performance of a contract or performance of a pre-contractual stage) of the GDPR and it’s not necessary the agreement of the user.
b) purposes related to the performance of the legal obbligations towards to Public Amministration, which includes the corporate accounting both for accounting and tax purposes, for example the operations of accounting tax data; the documents and the operations for the predisposition of financial statements, documentation related to the e-invoicing and provisions by the DPA ( Data Protector Authority) this purpose has its legal basis in the article 6.1.c (legal obligation) of the GDPR and it’s not necessary the agreement of the user.
c) purposes related to operations of administration, financial and accounting nature in order to fulfill the obligations above described, besides the fact that they are related to internal organisational requirements, for the internal accounting, for the elaboration with statistics purposes destinated also to the publication on an anonymous basis. The treatment of the personal data for this purpose has its legal basis in the article 6.1.f ( legitimate interest) of the GDPR and it’s not necessary the agreement of the user. The legitimate interest consists in the properfuncioning of the internal organisation and matches with the purpose indicated.
The agreement for the purposes 3a. 3b. 3c above described is voluntary, however if it’s not given could be impossible the esecution of a contract or to do the services requested. If the user wants to receive the requested services it’s necessary the agreement almost the data signed with *.
d) to inform the user about more services of Cinque Sensi S.r.l, similar to those treated for a previous contract ( ex. promotions on already sold products or about services already given, news about courses, ecc), by marketing activity on the email address given by the client during the previous contract ; it’s always possible to ask to not receive our communications anymore (undesirable communications, also called opt-out). The treatment of the personal data for this purposes has its legal basis in the aticle 130.4 of the Data Policy and it’s not necessary the agreement of the user.
The agreement for the next purpose it’s voluntary. The opt-out doesn’t affect the conclusion of the contract or the services requested but we will not be able to send communications by email to the user.
e) Cinque Sensi S.r.l. could use your data to make direct marketing by using all availables devices, automated and non (for example: email, fax, sms, mms, chat, social network and similars, phone o traditional post to the given address) also by external companies mandated by Cinque Sensi S.r.l. in order to do marketing activity on its behalf. The treatment for this purpose has its legal basis in the article 6.1 of the GDPR and it’s necessary the agreement of the user, which can be removed in any moment.
f) Cinque Sensi S.r.l. will be able to use your personal data for sending a newsletter by itself or by external companies responsible. The treatment for this purpose has its legal basis in the article 6.1 a of the GDPR and it’s necessary the agreement of the user, which can be removed in any moment.
g) The owner will be able to do the profilation based on the preferences of the user, the requirements and consumer habits,in its relation to market analysis and statistics. This allows us to understand at best the necessities of the user, give personalized promotions and services. The treatment for this purpose has its legal basis in the article 6.1 a of the GDPR and it’s necessary the agreement of the user, which can be removed in any moment.
The absence of the agreement for the purposes above descriobed at points 3.e), 3.f) and 3.g) doesn’t affect the conclusion of the contract or the services requested, but we will be able to send information for similar services as described above at point 3.4) only by email.
4) Procedures for treatment and period of storage
The personal data collected by using the site and its different services activated by the user, is treated by employers specificaly authorised by manual struments on paper, electronical or telematical supports, in accordance with the laws in force and in order to guarantee the security and the confidentiality.
The data will be conserved for the strictly necessary time and only for the purposes they were collected for or voluntarily communicated. To the State, the data collected by web,which wasn’t used for a contract, will be storaged for two years. The data necessary for a contract will be conserved for all the time the contract will be active and after in accordance to fulfill the legal requirements, for a maximum period of 10 years.
In case of consent the data collected for marketing and commercial purposes as described above at point 3.e) and sending the newsletter as described above at point 3.f) will be conserved by using paper, electronical or telematical supports, in accordance with the laws in force and in order to guarantee the security and the confidentiality, until the user removes the consent or for a maximum period of 24 months from the moment the consent was given.(As from 24 months after the given consent, and subsequently, every 12 months, will be send, if the consenti s still active , to all users concerned, a communication review, which contains the link to remove or confirm the consent. If the user doesn’t choose any option, the consent above described at point 3.e) will be removed.)
For the purposes described at point 3.g) the data will be conserved for the strictly necessary time in order to elaborate the data for the described purposes, for a maximum period of 2 years.
5) Recipients of personal data. Subjects who could be made aware
Without prejudice to the communications made in accordance to legal requirements, the data that can be communicated, is strictly necessary and related to the purposes above described:
To our employers or external partners that work under our authority and result to be authorized to treat the data as processors of personal data;
To partners whose activity it’s necessary for the performance of the contracts or in order to fulfill to reirements before the contract expires ( for example : banking institutions in order to manage the profit of the payments from the contracts, legal firms in cases of claim and litigation, post or other letter services, assicurations, Revenue Agency ecc.);
To external partners whose Cinque Sensi S.r.l. outsources some activities and subsequently gives specifical devices, however related to the treatment and to the purposes above described and that will be nominated Controllers ( for example companies that handle the manage of the site, of the social media of the Owner, of the newsletter, ecc. );
To legal Authority or Public .
The data collected will not be shared out of EU.
Under no circumstances will the data be disseminated.
The consent to the processing, where foreseen (point 3.e) with reference to the activities of direct marketing and point 3.f) with reference to the sending of the newsletter and point 3.g) with reference to the profiling and use of data for statistical purposes and lent, can be revoked at any time (Article 7 GDPR). The withdrawal of consent is valid only for the future and has no effect on the processing that took place before it.
6) Rights of the interested party
The interested part can exercise at any time the rights established by the GDPR. In particular:
• remove the consent to the processing of personal data previously expressed, without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation (Article 7.3).
• obtain information on their data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the processed data (so-called access right, art 15).
• verify the correctness of personal data and request the updating or correction (so-called rectification right art 16).
• when certain conditions are met, to obtain the cancellation or removal of personal data (so-called cancellation or obliteration art 17).
• when certain conditions are met, request the limitation of the processing of personal data; in this case, the Data Controller will not process these data for any other purpose other than their conservation (so-called right to limit processing art 18).
• receive your data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another holder. This provision is applicable when the data are processed using automated tools and the processing is based on the data subject’s consent, on a contract of which the data subject is a party or on contractual measures connected to it (so-called data portability art 20) .
• oppose the processing of personal data, when it occurs on a legal basis other than consent (so-called opposition law art. 21).
• oppose a decision based solely on automated processing (Article 22);
• the right to know subjects external to the Data Controller, who process their data as Data Processors (Article 13.1, e)
You can obtain this by sending a written request addressed to the Data Controller by sending an email to [email protected]
The right to lodge a complaint with the Data Protection Authority if it considers that the processing of your data is contrary to the law in force (www.garanteprivacy.it) or to act in court.
We also inform you that the Data Controller has appointed, as Data Protection Officer, contacted at the following addresses: e-mail: [email protected]