Privacy

1. Controller and data contact

FRANCO SRL

VIA FABRIZIO PLINIO 23 

31046 ODERZO (TV) 

VAT and Fiscal Code 05301990262   

E-mail: francosrlsolutions@legalmail.com

(“Franco Srl” or “Controller”), hereby provides to the users (“Users”) of the website www.movefranco.com (“Website”) the privacy policy pursuant to Article 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter, the “Regulation”, the Regulation and the Privacy Code are together referred to as the “Applicable Legislation”).

2. Category of data personal data

• personal data (e.g. first name, last name, telephone number, e-mail address), any personal data provided by the User through the contact form and other interaction methods provided for by the Website;
• browsing data, i.e. personal data whose transmission is implicit in the use of Internet communication protocols, e.g. IP addresses, browser data, the time of the request and other parameters relating to the User’s operating system and computer environment, cookies (for which we invite the User to read the cookie policy).

The Website does not process special categories of personal data (i.e. data concerning health, religious beliefs, trade union membership, sexual preferences and the others indicated in Article 9 of the Regulation) and we ask all users not to include such data when sending a contact through the Website, or in other forms of interaction provided by the Website.

This Website and the services that may be offered through the Website are solely addressed to individuals who are eighteen years of age or older. The Controller does not collect personal data relating to persons under the age of eighteen. Upon request of Users, the Controller will promptly delete any personal data that has been involuntarily collected.

The Website may contain links to other websites. With reference to these further websites, and to the processing of personal data carried out by them, the User will want to read the relevant information provided by their respective controllers.

3. Purpose and legal basis of the processing

The Users’ personal data, as described above, will be processed in the manner and in the forms prescribed by the Regulation, for the performance of the Website’s own functions, with particular, but not exclusive, reference to the procedures described therein for data collection, contact forms and other similar activities.

In particular, personal data provided to the Controller will be processed for the following purposes:

1. to follow up specific requests made to the Controller by the User through the Website and its communication tools (contact forms, information request forms, e-mails to the e-mail addresses on the Website). The legal basis for this processing is the implementation of a contract of which the data subject is a party, or for the execution of pre-contractual measures adopted at the request of the same – art. 6.1. (b) of the Regulation.
2. enabling the User’s browsing of the Website. The legal basis for this processing is the implementation of a contract of which the data subject is a party, or for the execution of pre-contractual measures adopted at the re-quest of the same – art. 6.1. (b) of the Regulation.
3. direct marketing activities through communications or other materials (e.g. by e-mail, newsletter) with respect to products/services similar to those for which the User has requested information and/or has already purchased. The legal basis for this processing is the lawful interest of the Controller, which is represented by the promotion of its activity through direct marketing – see Recital no. 47 of the Regulation.
4. marketing and other promotional activities, including by profiling the User. The legal basis for this processing is the consent given by the User – art. 6.1.(a) GDPR. Consent may be revoked at any time by the User.

For the sake of clarity, we specify that in sending e-mail communications, the Controller uses a platform that, through statistical tracking systems, makes it possible to detect the opening of a message, the clicks made on the hyperlinks contained in the e-mail, the IP address, which type of browser is used, and other similar data. The collection of such data is part of the message delivery system.

The personal data provided via the Website may be subject to profiling. Profiling enables the Controller to assess certain personal aspects of the User relating in particular to his/her preferences, interests, tastes with reference to the products sold and the activities carried out by the Controller, in order to enable the Controller to offer the User a sales service that is more specific and targeted to his/her needs. 

4. Mandatory disclosure

The provision of data for marketing purposes under Sec. 3 iii) and iv) is optional and failure to provide such data and/or the request not to use it for direct marketing purposes will not affect the possibility of browsing the Website and/or sending messages through the communication tools provided by the Website. The provision of the other data is necessary for browsing and/or sending messages through the communication tools provided by the Website. Failure to provide such data may make it impossible to navigate on the Website and/or sending messages through the communication tools provided by the Website.

5. Possible recipients of personal data

The data may be communicated to companies connected with, associated with or controlled by the Controller, as well as to consultants, or even to third parties who operate, also on behalf of the Controller, for the provision of services connected with the purposes indicated in this policy, both within the EU and outside the EU.

In some cases, personal data may be processed by the Controller through third party services that involve their possible transfer outside the European Economic Area (EEA) (e.g.: [-]) In these cases, the Controller undertakes to select reputable providers and to verify their commitment to comply with the provisions of the Regulation in relation to transfers of personal data outside the EEA. Where required by applicable law, the Controller will appoint such entities as processors pursuant to Article 28 GDPR.

Browsing data and the like (for which please refer to the above), as well as profiling cookies also from third parties (for which please refer to the Cookie Policy of this Website), may be disclosed to the respective third parties where they do not directly handle them as Controllers.

6. Retention 

The data provided by the User are kept in the Controller’s archives and are retained for a period of 10 (ten) years from the date of the last interaction with the User, in light of the limitation period of any claims arising from the relationship between the Controller and the user, as provided for by law.

7. Rights of the data subject

At any moment, the data subject may exercise towards the Controller, the rights provided for in articles 15 to 22 of the Regulation, i.e. the right to ask for:

a. access to personal data, or to be informed by the Controller of his/her personal data retained by the Controller, the purposes for which these data are processed, their origin and other information required by art. 15 of the Regulation;

b. the rectification of personal data in case of inaccuracy of the same;

c. the cancellation of personal data (so-called ‘right to be forgotten’);

d. the limitation of the processing of personal data, or the right to obtain the suspension of the processing of personal data for the period necessary to verify the request for revision of personal data, or in other cases provided for by art. 18 of the Regulation;

e. the right to the portability of data, i.e. the right to receive personal data in a structured format, commonly used and machine-readable format- even by requesting the direct transfer to another controller (with respect to data whose processing is carried out by automated methods);

f. he right to object to the processing data pursuant to art. 6, paragraph 1, letters e) or f) of the Regulation (the right to object).

g. the right to lodge a complaint pursuant to Articles 77 et seq. of the Regulation to a supervisory authority, which for the Italian State is identified in the Italian Data Protection Authority (Garante per la protezione dei dati personali). The methods of complaint are indicated at this link: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524

Last updated: 6^th October 2022