Cookie policy
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This information is provided for visitors and users of the websites:inim www.inimdns.biz and www.inimcloud.com, owned by INIM ELECTRONICS S.R.L. Unipersonale (henceforth INIM) and not for any additional websites that may be consulted by the user through internal links.
Pursuant to Articles 13 and 14 of the EU Regulation 2016/679 ("Regulation" or "GDPR"), we inform you that, by using the aforementioned sites, INIM, as the Data Controller (henceforth also simply "Data Controller") necessarily becomes aware of personal data relating to you.
To this end, it is necessary to provide you with the following information in fulfillment of the obligation imposed by the aforementioned legislation.
1. WHO IS THE DATA CONTROLLER
Whenever INIM acquires and processes your personal data, it does so exclusively in accordance with the principles of lawfulness set forth in the regulations and for the purposes outlined below.
2. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA
Your data is processed based on your consent for the creation and management of your personal account in INIM CLOUD. In addition, INIM may process data as it is necessary both for the performance of a contract to which you are a party and for the performance of pre-contractual measures taken at your request.
2.1. Purpose of processing
The Data are processed for the following purposes:
- purposes related to obligations under laws and regulations (including those of an accounting and tax nature) as well as provisions issued by the competent supervisory and control authorities/bodies;
- Purposes strictly related and/or necessary for the performance of the services requested by the User;
- purposes functional and/or complementary to the activity carried out by INIM such as, by way of example but not limited to, and subject to obtaining consent, the sending to Users, by e-mail, of newsletters and promotional material or, more generally, so-called "direct marketing" activities relating to products and/or services marketed by INIM itself, having, in any case, a nature similar to those covered by previous sales or supplies;
- User profiling, after obtaining consent, in order to allow INIM to process the User's choices, habits and propensities for consumption and, consequently, to send him specific offers related to its products and services.
2.2. Categories of individuals to whom the Data may be disclosed
In order to pursue the purposes described in paragraph 2 above.1, INIM may need to communicate the Data provided by the User, to third parties belonging to the following categories: agents and/or area concessionaires of the products marketed by INIM; subjects that perform banking, financial, insurance services; authorities and supervisory and control bodies and in general subjects, public or private, holding the position of Public Officials or persons in charge of a public service; other companies of the group of which INIM is part or, in any case, parent, subsidiary or associated companies; subjects that perform data acquisition, processing and processing services necessary for the execution of the instructions received from customers; parties that provide services for the management of INIM 's computer and information systems and telecommunications networks (including electronic mail); IT security and maintenance officers; parties that carry out transmission, enveloping, transport and sorting activities for communications with Users; parties that carry out documentation archiving and data entry activities; parties that carry out customer service activities; firms and companies within the scope of assistance and consulting relationships; parties that carry out promotion and sales activities for products and services of INIM and other companies of the group of which INIM is part INIM
With regard to the Data communicated to them, the individuals in the above categories may operate, as the case may be, either completely independently as separate data controllers, or, as data processors or data processors.
At the same time, the Data may, moreover, be communicated to any additional data processors appointed by INIM as well as to its own employees in their capacity as data processors, again for the purposes indicated in section 2.1 above.
3. WHERE WE PROCESS YOUR DATA
Processing related to the web services of this site takes place at the aforementioned headquarters of INIM and is handled only by technical personnel responsible for or in charge of processing, or by those responsible for or in charge of occasional maintenance operations.
4. YOUR DATA IS TRANSFERRED ABROAD
INIM currently processes your data without transferring it to foreign countries other than those belonging to the European Union or which do not ensure adequate levels of protection of individuals. Privacy legislation allows the transfer of personal data abroad with your consent, or where there is another legal justification and an adequate level of data protection is ensured. INIM is committed to ensuring that if data is transferred abroad, this is done in full compliance with local and European Union legal principles and requirements, and that appropriate security measures are taken to protect personal data in those countries/territories.
5. HOW YOUR DATA IS PROCESSED AND FOR HOW LONG
Processing of Data:
- is achieved by means of the operations or complex of operations including collection, recording and organization, processing, including modification, comparison/interconnection, use, consultation, storage, erasure/destruction, security/protection, integrity, protection;
- is carried out by means of manual, computerized and telematic tools with logics strictly related to the purposes set out in paragraph 2.1 above and, in any case, in such a way as to guarantee the security and confidentiality of the Data.
Your personal data are kept by INIM only for as long as is strictly necessary to achieve the purposes for which they were collected and processed, without prejudice to the need for further storage in the face of specific provisions of Law.
The data acquired for the purpose of registration to the portal INIM CLOUD SERVICES are governed by special detailed information in the registration form. These are processed in relation to the services offered by INIM through its portal, exclusively for the purposes that fall within the institutional tasks of the company or for the fulfillments required by law or regulations. Within the scope of these purposes, processing also concerns data related to registrations/registrations to the portal necessary for the management of relations with INIM, as well as to enable effective institutional communication and to fulfill any legal, regulatory or contractual obligations. These data are retained in accordance with the terms and conditions of the service offered or alternatively until any revocation of your consent.
Data processed for marketing and profiling purposes (always, of course, provided that your express consent has been acquired), are retained in accordance with the provisions of current legislation and in any case until your consent to the processing of personal data is revoked.
The data processed as a result of your possible purchase of products, are used for the exclusive sending of e mails according to the provisions of Article 130, paragraph 4, Privacy Code.
You have in any case the possibility of revoking your consent to the processing of data for marketing and profiling purposes at any time: there is a section in each commercial communication that allows you to easily revoke the consent you have given. When you revoke your consent, even if expressed prior to the expiration of the retention period of the data collected for these purposes, the same will be automatically deleted or permanently anonymized and INIM may ask you to renew your consent to the processing. Data transmitted to any service providers are processed by them for the time strictly necessary to carry out the tasks entrusted to them.
Specific security measures are observed at all times to prevent data loss, illegal or incorrect use, and unauthorized access.
6. WHAT ARE YOUR RIGHTS
In your capacity as a data subject, you may exercise, using the methods indicated in paragraph "11 EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY", the rights set forth in Articles 15 to 22 of the Regulations and in particular:
- Obtain confirmation of the existence or non-existence of personal data concerning you, even if not yet registered, and their communication in intelligible form;
- obtain indication of: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in case of processing carried out with the aid of electronic instruments; d) the identification details of the owner, managers and designated representative under 'art. 3, paragraph 1, GDPR; e) the subjects or categories of persons to whom the personal data may be communicated or who may become aware of them as appointed representative in the State territory, managers or agents;
- obtain: a) the updating, rectification or, when interested, the integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
- oppose, in whole or in part: a) for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of collection; b) the processing of personal data concerning you, for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator, by e-mail and / or traditional marketing methods (telephone and / or paper mail). It should be noted that the data subject's right to object, for direct marketing purposes by automated means, extends to traditional ones and in any case the possibility remains for the data subject, to exercise the right to object even in part. The data subject may, therefore, decide to receive only communications by traditional means or only automated communications or neither type of communication.
Where applicable, you may also exercise your rights under Articles 15 to 22 of the GDPR (Right to rectification, Right to be forgotten, Right to restrict processing, Right to data portability, Right to object), as well as the right to complain to the Data Protection Authority.
7. WHAT DATA DO WE PROCESS?
7.1. Navigation data
The computer systems and software procedures used to operate these websites acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties but which, by its very nature, could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used in submitting 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 the user's operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.
7.2. Data voluntarily provided by the user
Following optional, explicit and voluntary consent expressed in advance by the interested party by filling in the forms on the site or by using the addresses indicated in the same, INIM collects and retains the data received, including the e-mail address, for the time necessary to respond to requests, for the purpose of exchanging information or contacts. Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request or for particular categories of data.
7.3. Cookies
For information regarding the Cookie Policy adopted you can consult the Cookie Policy in the dedicated section of the site.
8. INIM PROCESSES DATA RELATED TO MINORS
As a general rule, INIM does not intentionally collect personal data concerning minors. If INIM learns that it has inadvertently collected personal data from such individuals, INIM will act to delete it as soon as possible, except where applicable law requires retention.
9. OPTIONALITY OF CONFERRING DAT
Apart from what has been specified for navigation data, the user is free to provide the personal data indicated in the request forms or in any case indicated in contacts to request, for example, the sending of informative material or other communications. Failure to provide them may make it impossible to obtain what has been requested. For the sake of completeness, it should be remembered that in some cases (not subject to the ordinary management of this site) the Authority may request news and information for the purpose of monitoring the processing of personal data. In these cases, the response is mandatory under penalty of administrative sanction.
9.1. Provision of Data and Consent
Without prejudice to the personal autonomy of the User, the provision of Data for the purposes mentioned in paragraph 2.1 above is optional.
However, it should be pointed out that:
- any refusal of the User to confer the Data for the purposes set out in paragraph 2.1, letters (a), (b) above, or the deletion of the same, following the User's request, entails the impossibility for INIM to guarantee access to the reserved area of the Site and, consequently, to benefit from the services requested;
- any refusal by the User to confer the Data for the purpose referred to in paragraph 2.1, letter (c) above, or the cancellation of the same, following its request, entails the impossibility for INIM to carry out the other functional/complementary activities of a promotional and advertising nature for the benefit of the User, without prejudice, however, to the possibility for the latter to access the reserved area of the Site and to benefit from the services requested;
- any refusal by the User to provide Data for the purpose referred to in paragraph 2.1, letter (d) above, or the cancellation of the same, entails for INIM the impossibility of profiling the User according to the choices, habits and propensities to consumption shown and prevents it from rendering, to the same User, information and communications structured on the basis of the preferences shown. Failure to provide the Data referred to in paragraph 2, letter (d) above, however, does not affect the possibility for the User to access the reserved area of the Site and benefit from the services requested.
With regard to the purposes under paragraph 2.1, letters (a) and (b), we inform you that the processing of the Data by INIM, including its communication to the entities referred to in paragraph 2.2 below, does not require your consent as the processing is necessary to perform services requested by you as well as to comply with legal obligations.
With regard to the purpose indicated in paragraph 2.1, letter (c), we point out that the consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Privacy Code (so-called "direct marketing") implies consent to receive such communications by both automated (e-mail) and traditional (paper mail and telephone calls through an operator). The User is, however, left the option to express his or her consent to the receipt of the aforementioned communications through the contact methods provided. This is without prejudice, on the other hand, to the provisions of art. 130, paragraph 4, Privacy Code, which authorizes INIM to use, for the direct sale of its products or services, the electronic mail details provided by the User in this context, without his prior consent, provided that the services in question are similar to those being sold and the User, adequately informed, does not refuse such use initially or on the occasion of subsequent communications. The User may object to such processing at any time.
10. USE AND METHODS OF DATA PROCESSING
10.1. Network-collected data
As a result of consulting this site, data relating to identified or identifiable persons may be processed.
The provision of data is optional, however, the same may in some cases be indispensable for the performance of specific activities and therefore, failure to provide them would result in INIM being prevented from providing services and information.
Failure to provide all data except those that do not relate to legal, tax, and contractual obligations is evaluated by INIM on a case-by-case basis and determines the resulting decisions, related to the importance to INIM of the data requested and not provided.
In particular, for the purposes defined in the following point "10.2. Data provided voluntarily by the user and collected for the performance of services ", will be required to express, free and informed consent to the processing of data, through specific signing of appropriate documentation drawn up for processing where required.
No data is disclosed or disseminated unless expressly specified in the notices drafted for specific processing for which explicit and separate consent will be required from the data subject.
Likewise, if it turns out to be necessary to acquire sensitive data, it will be required to provide explicit and separate consent to the data subject.
The technical data related to your accesses to the Site, as well as those collected from any e-mails you send, are not, in any case, disclosed to third parties, nor are they subject to dissemination.
10.2. Data voluntarily provided by the user and collected for the performance of services
The collection and processing of the User's personal data is carried out in accordance with the general principles of necessity, correctness, relevance and non-excessiveness, and in particular, the processing of data is carried out for:
- registering for the personal area or joining the services offered by INIM through the Sites;
- Answer questions and provide information requested by the User;
- The handling of User requests of a technical, commercial, order status and general nature;
- The performance of activities related, instrumental or necessary to the provision of INIM's services, including the communication of data to third party companies that, by way of example only, perform activities necessary or instrumental to the provision of INIM 's services or may handle payments on the Site;
- legally required registrations and disclosures;
- The detection of the User's satisfaction and preferences;
- enable the User to access, following registration and creation of their User profile in the INIM CLOUD SERVICES portal, the restricted area for the provision of services, products and any other kind of request and the subsequent and autonomous management of their User profile from the control panel;
- Payment processing, including anti-fraud control in the case of credit card payments;
- the sending, subject to obtaining consent, of advertising, informative and commercial information material, as well as the transfer to third parties of data processed for commercial purposes, including for sale or attempted sale, or for all those purposes of a commercial and/or statistical nature that are lawful under current legislation. Consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Code (so-called "direct marketing") implies consent to receive such communications by automated and traditional means (paper mail and telephone calls through an operator). In such circumstances, the User is nevertheless left with the option of expressing consent to receive the aforementioned communications exclusively through traditional modes of contact;
- The profiling of the User, after obtaining consent, in order to allow INIM to process his choices, habits and propensities for consumption and, consequently, send him specific offers related to its products and services;
- Subscription to the "NEWSLETTER" service. The User can subscribe to it when registering to the restricted area. Such data will not be disclosed to third parties. Specifically, it is possible to consult the dedicated information.
11. EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY
The interested party at any time may exercise against the Data Controller the rights provided for in Articles 15 to 22 of the Regulation, by contacting INIM ELECTRONICS S.R.L. Unipersonale with registered office in Monteprandone (AP), locality Centobuchi, at Via dei Lavoratori 10, c.f. and p. i.v.a. 01855460448, by e-mail: inim
12. UPDATE OF THIS POLICY
This Privacy Policy governs the processing of personal data released by the User while browsing any of the INIM Sites and may be amended or simply updated, in whole or in part, by INIM , including in consideration of changes in laws or regulations governing the protection of personal data. Changes and updates to this Privacy Policy are made known to Users as soon as they are adopted and become binding once posted on the Site. INIM therefore invites Users to regularly access this page to check the publication of the most recent and updated Privacy Policy. For this purpose, the document highlights the date it was updated.
Last updated June 1, 2020