Privacy Policy

With this document
(“Information Note”), the Data Controller, as defined below, wishes to inform
you of the purposes and methods of processing of your personal data and of the
rights which Regulation (EU) 2016/679, relating to the protection of individuals
with regard to the processing of personal data, and the free movement of such
data (“GDPR”), grants you.

Information Note applies solely to the processing of personal data relating to
the website (the “Site”).

1. Who is the Data Controller

The data controller is DUE ELLE s.r.l. (“DUE
ELLE” or the “Data Controller”), with head office at via Via S. Rosalia, 5 -
Fraz. Fagnigola 33082 Azzano Decimo (PN), Italy.

2. Which
personal data do we process

2.1 Common personal data

As a result of a
specific request made by you, and for the purposes indicated in article 3 of
this Information Note, the Data Controller uses the following personal data:
common data and contact details, such as name, surname, address, telephone
number, email address and other data which you will supply from time to time
through forms present on the Site.

2.2 Navigation data

Computer systems and
programs used in order to operate the Site collect some personal data whose
transmission is implicit in the communication protocols of the Internet (for
example, IP addresses or domain names of computers used by users who connect to
the Site, URI addresses – Uniform Resource Identifier – of requested resources,
the time of the request, the method used to submit the request to the server,
the size of the file obtained in reply, the numerical code stating the status
of the response from the server – successful, error, etc. – and other
parameters relating to the operating system and the User’s IT environment).
Although it concerns information that is not collected to be associated with
specific individuals, due to their nature they could, through the processing
and association with data held by third parties, allow users to be identified.
This data shall be used exclusively to obtain anonymous statistical information
regarding the use of the Site and to ensure proper functioning and will be
deleted immediately after processing. The data could be used to establish
responsibility in case of hypothetical computer crimes against the Site: except
for this possibility, the data on web contacts are not stored for more than
seven days.

2.3 Cookies

 In some cases, personal data is collected by
DUE ELLE by using different technologies, including the use of
"cookies". Cookies are small text files created by some websites and
sent to the user’s browser when the website is accessed. This information can
therefore be stored on your computer by means of a tag which identifies the
device but not the user.

Some pages of the Site use cookies, sent by DUE
ELLE or third parties, and other technologies in order to allow the technical
functioning of the Site itself, for a better use of the Site and to carry out
statistical analysis of the use of the Site.

information can be found in the Cookie Policy

3. What are the purposes and the
legal grounds for processing

3.1 Execution of the
contract and fulfilment of legal obligations

Your personal data
will be processed by the Data Controller for purposes strictly connected to and
instrumental to the execution of the contract which you signed with DUE ELLE,
as well as for the fulfilment of obligations foreseen by law, regulations
and/or Community regulations, or by supervisory and control bodies or other
authorities empowered to do so by law.

For the processing of
your personal data for the purposes set forth in this paragraph, your consent
is not required, as the legal basis for the processing, pursuant to applicable
regulations, consists in the execution of a contract and the fulfilment of a
legal obligation.

Your personal data will be processed for the
time necessary to the achievement of the purposes indicated and will,
subsequently, be stored exclusively for the time necessary to fulfil the
requirements provided for by law.

3.2 Management of your request

Your personal data will be processed
to follow up on requests made by you from time to time through the Site such
as, by way of example and not of limitation, request for information through
the “contact” form , registration on the Site.

The legal basis for the processing of your
personal data, in accordance with current regulations, is to deal with a
request made by you. Therefore, the Data Controller does not require your
consent for the data processing.

To manage your request, your personal data will
be processed for the time that is strictly required and, in any case, will not
be stored for more than [6] months. However, in the event that you request
registration on the Site, your personal data will be stored for as long as you
wish to remain registered. In order to fulfil legal obligations, your personal
data will be processed for the time strictly necessary for this and will
subsequently be stored exclusively for the time required each time by
applicable regulations (including provisions of limitation of rights).


Following your
request, Poliform may also process your personal data to send you
communications of commercial or editorial nature through newsletters.

For the processing of
your personal data for this purpose, your consent is required which forms the
legal basis for the processing in accordance with current regulations.

The data collected
will be processed by the Data Controller until you decide to revoke your
consent and/or obtain the termination of the processing.

4. Nature of the processing of the
personal data and consequences of refusal

For the purposes laid
down in the preceding article 3.1, it is compulsory to provide your personal
data. As a result, your refusal to do so will make it impossible for the Data
Controller to continue.

However, for the purposes laid down in the
preceding article 3.2, the conferment of your personal data is optional.
Therefore, your refusal to do so will not make it impossible for DUE ELLE to
deal with your requests, but only to inform you of any offers and/or new
products and/or initiatives.

5. Methods for the processing of
your personal data

The processing of your personal data may be
done, subject to the provisions of the GDPR, with the aid of paper,
computerised and telematic means, for the purposes indicated and, in any case,
by means of appropriate methods to ensure security and confidentiality in
compliance with the provisions laid down in Article 32 of the GDPR.

6. To which parties
may your personal data be disclosed and who may come to acquire knowledge of

In order to pursue the purposes described in
the preceding article 3, your personal data shall be disclosed to employees,
external consultants and, in general, to DUE ELLE’s staff, acting as persons
authorised to process the personal data.

Furthermore, DUE ELLE may need to disclose your
personal data to third parties belonging to the following categories:

a) parties that provide services for the
management of the Data Controller’s computer systems;

b) parties that provide technical support

c) parties that provide logistic or transport

d) parties that provide professional
consultancy services and fiscal, legal and judicial assistance;

e) authorities and bodies of supervision and control
and, in general, public or private parties with service-type functions.

The parties belonging to the above-mentioned
categories shall act, in some cases, as distinct data controllers, in other
cases as data processing managers specifically appointed by the Data Controller
under article 28 GDPR. You may request a list of the data processing managers
at all times by contacting the Data Controller at the addresses listed in the
preceding article 1. Your personal data shall not be disclosed to the public.

7. Your rights as concerned party In relation
to the processing as described in this Information

Note, you may exercise the rights listed in the
previous section, as laid down in Articles 15 to 21 of the GDPR. In particular:

• right of access: right to obtain confirmation
regarding the processing of personal data relating to you and, should this be
the case, obtain access to your personal data – including a copy of it – and
the communication, amongst others, of the following information: a) purposes of
the processing; b) categories of the personal data processed; c) past or future
recipients of the data; d) retention period of the data or criteria used; e)
rights of the concerned party (rectification, cancellation of the personal
data, limitation of data processing and right to object to data processing; f)
right to submit a complaint; g) right to receive information relating to the
source of the personal data in case it was not gathered from the concerned
party; h) the existence of an automated decision-making process, including

• right of rectification: right to obtain
rectification of inaccurate personal data relating to you and/or the
integration of incomplete personal data;

• right to cancellation (right to be
forgotten): right to obtain cancellation of the personal data relating to you,
if: a) the data is no longer required for the purposes for which it was
obtained or otherwise processed; b) you have revoked your consent and there is
no other legal basis for data processing; c) you have successfully objected to
the processing of your personal data; d) the data was unlawfully processed, e)
the data must be deleted to comply with legal obligations; f) the personal data
was obtained relating to the offering of information society services referred
to in article 8 paragraph 1 GDPR. The right of cancellation shall not apply to
the extent in which the processing is required for the fulfilment of a legal
obligation or for the execution of a task performed in the public interest or
for the establishment, exercise or defence of a right before a court;

• right to limitation of processing: right to
obtain limitation of the processing in case: a) the concerned party disputes
the exactness of the personal data; b) the processing is unlawful and the
concerned party objects to the cancellation of the personal data but requests
that the use thereof is restricted; c) the personal data is necessary for the
concerned party for the establishment, exercise or defence of a right before a

• right of objection: right to object to the
processing of personal data relating to you, except if there are legal grounds
for the Data Controller to continue processing the data;

• right to data portability: right to receive,
in a structured format, commonly used and legible on an automatic device, the
personal data relating to you supplied to the Data Controller and the right to
transmit them to another data controller without hindrance, where the
processing is based on consent and is performed with the aid of automated
means. Furthermore, the right to obtain that your personal data is transmitted
directly by DUE ELLE to another data controller where it is technically

• submit a complaint to the Italian Data
Protection Authority, Piazza di Montecitorio n. 121, 00186 Rome (RM).

The above-mentioned rights may be exercised,
against the Data Controller, by using the contact details specified under point