WYLER VETTA SRL, in compliance with the legislation on the protection of personal data (EU Regulation 679/2016), makes this information to the users of its website (“Users”) so that they can provide free and informed consent to the processing of their personal data with regard to all services offered by WYLER VETTA SRL by means of its web pages related to the website https://www.wylervetta.com/ (“Site”).
Processing means: any operation or set of operations, whether or not involving automated processes, applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, restriction, erasure or destruction.
Personal data means: any information relating to an identified or identifiable natural person with particular reference to an identifier such as a name, an identification number, location data, an online identifier or one or morè characteristic elements of his or her physical, physiological, mental, economic, cultural or social identity
This information does not, however, refer to sites that are not owned by WYLER VETTA SRL and which may be accessed through links placed on the sites of WYLER VETTA SRL. On them WYLER VETTA SRL has no power of control and therefore disclaims any responsibility for the processing of personal data of Users that is carried out through such sites.
This statement may be subject to changes directed at updating it with respect to legislation and technological developments that may have occurred. In that case, updated versions will be widely publicized on the Site.
- Who is the controller of the processing of Users’ personal data?
- What types of data are processed?
- For what purposes is personal data of Users processed?
- What is the legal basis for the processing of Users’ personal data? Can consent given be revoked?
- What happens if personal data are not given by Users?
- How is personal data of Users processed? With whom might WYLER VETTA SRL share the personal data of Users?
- How long will the personal data of Users be stored?
- Will personal data of Users be transferred abroad?
- What are the rights of the Users?
1. WHO IS THE CONTROLLER OF USERS’ PERSONAL DATA?
The owner of the processing of such data is WYLER VETTA SRL, C.F. and P. IVA 12024470960, which is based in Milan (MI), Via Francesco Melzi d’Eril 26, cap 20154.
Phone +39 3792961316
2. WHAT TYPES OF DATA ARE PROCESSED?
A) BROWSING DATA
The computer systems and software procedures responsible for the operation of the sites owned by WYLER VETTA SRL automatically acquire, in the course of their normal operation, certain personal data relating to the User’s navigation.
This is information that is collected exclusively for the purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, and which is used only within WYLER VETTA SRL. However, this information could, by its very nature, make it possible to trace the identity of the User, including through processing and association with data held by third parties.
This category of data includes:
- the IP addresses of the computers used by Users using the service
- the number of accesses
- the pages viewed
- the date and time when the access took place
- the Url where the browser was before viewing our page
- the browsing browser
- the operating system used
B) DATA VOLUNTARILY SUPPLIED BY THE USER
- contact data: the data optionally and freely provided by the User with the completion of the form required to access the services of WYLER VETTA SRL. These data will be used by WYLER VETTA SRL only to perform the requested service and to improve it and make it more effective, within the limits of the purposes for which the data were collected.
Specific summary disclosures may be shown or displayed on pages of the Site set up for particular on-demand services and in the terms and conditions of sale.
Cookies are small text files that are installed by a website on the User’s browser and that record certain information about the User’s browsing activity; this data, if the cookies are not disabled, is communicated to the site that installed them whenever the User returns to visit the website.
3. FOR WHAT PURPOSES ARE USERS’ PERSONAL DATA PROCESSED?
WYLER VETTA SRL will process the data provided by Users for the following purposes:
- to fulfill Users’ requests for information or clarification on Wyler Vetta products
- to send the newsletter and/or informative, commercial and marketing communications related to Wyler Vetta products. Communications for these purposes may be sent either through traditional means (e.g., paper mail, operator phone calls) or through automated means of communication such as e-mail and SMS.
4. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF USERS’ PERSONAL DATA? CAN THE CONSENT GIVEN BE REVOKED?
Legal basis of data processing
The processing of data referred to in Section 3 letter a) is necessary to provide feedback to the User’s requests for information or clarification on Wyler Vetta products.
On the other hand, the processing of data under 3(b) is based on the consent given by the User.
Users’ personal data could also be, also, processed on the basis of a legitimate interest of WYLER VETTA SRL, for example, to defend its rights in a dispute with the User, to prevent fraud or abuse.
Withdrawal of consent
If the User wishes to withdraw his or her consent, he or she may do so at any time by writing to email@example.com or through the appropriate link at the bottom of any e-mail with promotional content sent by WYLER VETTA SRL that allows automatic unsubscription from the newsletter.
The User’s right to object to the processing of his or her personal data for marketing purposes carried out through automated means of contact (e-mail, SMS) also extends to traditional means of contact (mail), without prejudice to the User’s ability to exercise this right in part, i.e. by objecting, for example, only to the sending of promotional communications carried out.
5. WHAT HAPPENS IF PERSONAL DATA IS NOT GIVEN BY USERS?
Apart from what has been specified above with regard to navigation data, the personal data that must be compulsorily provided by Users are marked with an asterisk placed in the margin of the fields in the forms. Such mandatory data normally consist of the User’s first name, last name, telephone and e-mail address.
With reference to the purposes of the processing referred to in point 3 letter (b), the provision of the User’s personal data is merely optional. Failure to provide such personal data will not result in any consequence other than the inability of WYLER VETTA SRL to send the newsletter and/or informative and promotional communications.
6. HOW ARE USERS’ PERSONAL DATA PROCESSED? WITH WHOM MIGHT WYLER VETTA SRL SHARE USERS’ PERSONAL DATA?
Method of treatment
The processing of Users’ personal data will be mainly carried out with the aid of electronic or otherwise automated tools, in the manner and with means suitable to ensure the security and confidentiality of such data, in accordance with the provisions of the legislation on the protection of personal data. In particular, appropriate technical, computer, organizational, logistical and procedural security measures will be adopted, so that the minimum level of data protection required by law is guaranteed, allowing access only to those responsible for processing.
Scope of data reporting
Users’ personal data may be disclosed to the following parties:
- employees and/or collaborators of WYLER VETTA SRL, for the performance of administration, accounting and IT and logistical support activities, who act as, respectively, data processors and persons in charge of the processing
- to companies or consultants in charge of the installation, maintenance, updating and, in general, the management of hardware and software of WYLER VETTA SRL (including the Site)
- to companies entrusted by WYLER VETTA SRL with the sending of online communications
- to all those public and/or private individuals and/or legal entities (legal, administrative and tax consulting firms), if the communication is necessary or functional to the proper fulfillment of contractual obligations undertaken in relation to the services provided through the Site, as well as obligations arising from the law
- to all those subjects (including Public Authorities) who have access to the data by virtue of regulatory or administrative measures;
These individuals act either as autonomous data controllers or as data processors. The updated list of data controllers can be requested by sending an e-mail to firstname.lastname@example.org.
The data will in no way be disseminated or disclosed to any other external parties, without prejudice to the obligations in this regard required by law.
7. HOW LONG WILL USERS’ PERSONAL DATA BE KEPT?
Users’ personal data will be kept only for the time necessary to ensure the proper provision of the services offered by WYLER VETTA SRL.
For the purpose of sending the newsletter, personal data (first name, last name and email address) will be kept until the User has communicated his/her wish to unsubscribe and in any case for a period equal to 24 months from the date of last use by WYLER VETTA SRL.
The criteria for determining the period of retention of personal data shall take into account the period of permitted processing and applicable tax regulations, prescription of rights, and the nature of legitimate interests where they form the legal basis for processing.
In accordance with current regulations, personal data may be retained for a period later than originally planned in the event of any litigation or requests by the competent authorities.
More information regarding the retention period of Users’ personal data and the criteria used to determine this period can be requested by writing to: email@example.com.
8. WILL USERS’ PERSONAL DATA BE TRANSFERRED ABROAD?
It may be the case that WYLER VETTA SRL has to share Users’ personal data with selected providers who may process Users’ personal data in countries both within and outside the EU/EEA. In the case of transfer of personal data to countries outside the EU, which the European Commission does not consider to have a level of protection adequate to that of the EU/EEA countries, WYLER VETTA SRL will take appropriate security measures to ensure that the transfer of personal data is safe and secure, such as signing the standard data protection contractual clauses approved by the EU Commission.
To inquire about the possible transfer of your personal data abroad, you can write to: firstname.lastname@example.org.
9. WHAT ARE THE RIGHTS OF USERS?
This section summarizes the rights that Users may exercise at any time and free of charge by writing to: email@example.com.
The User’s rights are as follows:
- to obtain confirmation of the existence or otherwise of personal data concerning him/her and to have communication of such data in intelligible form
- to know the origin of the data, the purposes of the processing and its methods, as well as the logic applied to the processing carried out by electronic means
- request the updating, rectification or – if he/she is interested – the integration of the data concerning him/her
- obtain the cancellation, transformation into anonymous form or blocking of any data processed in violation of the law, as well as to oppose, for legitimate reasons, the processing
- oppose any processing aimed at sending advertising material, direct sales, market research and commercial communication
- withdraw consent at any time in cases where the same has been previously provided. Revocation of consent does not affect the lawfulness of the processing based on the consent previously given. Request the restriction of the processing of your personal data in the event that: (i) should you dispute the accuracy of your personal data, for the period necessary for WYLER VETTA SRL to verify the accuracy of your personal data; (ii) the processing is unlawful and you object to the deletion of your personal data and instead request that its use be restricted; (iii) although WYLER VETTA SRL no longer needs it for the purposes of the processing, the User’s personal data were necessary to the same for the establishment, exercise or defense of a right in court; (iv) the User should object to the processing pending verification as to whether the legitimate reasons of the data controller prevail over those of the User
- obtain the portability of data concerning him/her, where technically feasible;
WYLER VETTA SRL may request additional information before processing requests, should it need to verify the identity of the individual who submitted them.
Pursuant to Regulation (EU) 2016/679, WYLER VETTA SRL is not authorized to charge costs for complying with any of the requests set forth in this paragraph, unless they are manifestly unfounded or excessive, and in particular are repetitive in nature.
In cases where a data subject requests more than one copy of his or her personal data or in cases of excessive or unfounded requests, the Company may (i) charge a reasonable fee, taking into account the administrative costs incurred in processing the request or (ii) refuse to comply with the request. In these instances, the Company will inform the User of the costs before processing the request.
Without prejudice to any other administrative or jurisdictional recourse, the User also has the right to lodge a complaint with a Supervisory Authority (for Italy: the Garante per la protezione dei Dati Personali), if he or she believes that the processing concerning him or her is carried out in violation of the legislation on the protection of personal data. Further information is available at http://www.garanteprivacy.it.
WYLER VETTA SRL does not intend to collect personal information from individuals under the age of 16. Should the User believe that WYLER VETTA SRL may be in possession of personal information regarding minors under the age of 16, the User may contact WYLER VETTA SRL at the following e-mail address: firstname.lastname@example.org.
For any information, requests or clarifications regarding the privacy of Users, as well as for the exercise of the rights referred to in the preceding paragraph, you can write to the e-mail address: email@example.com.
Date of last update November 17, 2021