With this policy, Golden Clef provides the user with information regarding the processing of personal data, which is collected automatically or which the same voluntarily provides, when accessing and navigating the Site, as well as when using the services provided therein.
Browsing is free of charge and does not require any registration;
The website may contain hypertext links to websites, pages or online services of third parties. By clicking on such links, the user will be able to access multimedia contents that, being exclusively the property of the aforementioned entities, are beyond the control of Golden Clef and are in no way subject to the provisions of this Privacy Policy. Therefore, Golden Clef invites the user to be careful when subscribing to services offered by third parties and to carefully read the information on data processing provided by said subjects, over which Golden Clef cannot exercise any control or be held responsible.
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1. Data Controller
The data controller is Golden Clef International S.p.a. (C.F. and P. IVA 01893540516), with registered office in Arezzo, Via del Gavardello 69 e-mail address info@goldenclef.it, (hereinafter the “Company”).
2. Data Protection Officer.
The Data Protection Officer appointed by the Company is Mrs. Peruzzi Elisabetta (hereinafter the “Data Protection Officer”).
3. Nature of the personal data processed
Personal data is any information that concerns the user and that can be related to the user. In particular, the processing will concern:
Personal data related to navigation
When accessing and browsing the Site, the Company generally collects browsing data through cookies or other tracking technologies. The computer systems and software procedures responsible for the operation of the Site acquire, during their normal operation and automatically, some personal navigation data whose transmission is implicit in the use of Internet communication protocols.
These are data relating to telematic traffic which, by their very nature, are not collected in such a way as to be directly associated with identified users, but which, through processing or association with data held by third parties, could make it possible to identify the user. This category of data includes, for example, the “IP addresses” or domain names of the computers used to connect to the Site, the addresses in the URL (Uniform Resource Identifier) of the resources requested, the time of the request, the method used to submit 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 allow access to the Site and use of the services it offers and may be used – in anonymous and aggregated form – to obtain information about visits, to carry out statistical analyses, to deliver advertising messages in line with the user’s browsing habits, to verify the correct functioning of the Site and to detect anomalies and/or misuse. These data will be kept for a maximum of 30 (thirty) days and for the period expressly indicated in point 5) below regarding cookies, without prejudice to the possible need for criminal investigations by the judicial authorities.
4. Purposes of processing, legal basis and nature of the data provided
In the context of consultation of the Site and use of the services provided therein, the data will be processed for the following purposes:
a) to allow you to browse the Site, to obtain anonymous statistical information on its use, to check its correct functioning and to establish liability in the event of computer crime (hereinafter “browsing the Site“). The processing has a legal basis in the legitimate interest of the Company (art. 6.1 f) Regulations);
b) the exercise and defense of the rights of the Company in any forum, including judicial, administrative, arbitration and/or mediation and conciliation proceedings (hereinafter “Defense”). The processing has a legal basis in the legitimate interest of the Company (art. 6.1 f) Regulations).
5. Use of cookies
The Site uses technical, analytical and profiling cookies, including cookies from third parties, to enable normal navigation and use of the Site and for statistical analysis. More information about the characteristics of the cookies used on the Site can be found at our Cookie Policy.
6. Processing methods
Within the scope of the purposes indicated at point 4) above, the data will be processed using electronic and automated tools, in compliance with the legal provisions on the processing of personal data, with the adoption of appropriate security measures. The processing of the data will be carried out by the Company’s internal personnel, specially authorized, trained and instructed to ensure adequate security and confidentiality, as well as to avoid risks of loss and/or destruction and access by unauthorized parties.
7. Communication and Dissemination of Data
The data will not be subject to dissemination. Within the limits strictly relevant to the purposes indicated at point 4) above, the data may be communicated to:
subjects entitled by law or regulation, such as, for example, but not limited to, public and judicial authorities;
subjects who, as autonomous controllers or processors pursuant to art. 28 of the Code (such as, by way of example but not limited to, the company in charge of the management and maintenance of the computer systems, the company in charge of the management of the Site, the company in charge of the automation platform of the e-mail marketing service).
The updated list of data processors can be requested from the Company by sending an e-mail to info@goldenclef.it.
8. Data Retention Period
The Company will keep the data for the period of time strictly necessary to achieve the purposes for which such data was collected.
Without prejudice to the right to revoke consent for the processing operations based on this legal basis, the right to object to the processing, as well as to the fulfillment of specific preservation obligations provided by law and the exercise of the right of defense in case of dispute.
9. Rights of the interested party
With reference to the data, there is the right to request from the Company, in the manner indicated in the Regulations, and without prejudice to the provisions and limitations provided for in Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016.
Access, in the cases provided for (art. 15 of the Regulations);
the rectification of inaccurate data and the integration of incomplete data (art. 16 of the Regulation);
the deletion of data for the reasons provided (art. 17 of the Regulation), such as when they are no longer necessary for the purposes indicated above or are not processed in compliance with the Regulation;
the restriction of processing for the purposes indicated (art. 18 of the Regulation), such as when the accuracy of the data is disputed and its accuracy needs to be verified;
portability, i.e. the right to obtain, in the cases provided for (art. 20 of the Regulation), the data in a structured format in common use and readable by automatic means and to transmit them to another controller;
to object to the processing, in the cases provided for (art. 21 Regulations).
In the case of processing based on consent, the right to revoke it at any time is also recognized, without prejudice to the lawfulness of the processing carried out prior to the revocation.
All the above rights may be exercised by sending a communication to the Company by e-mail to info@sgoldenclef.it or by registered letter to the address of the Company: Via del Gavardello 69, 52100, Arezzo.
10. Complaint
In the event that the User believes that the processing of data violates the provisions contained in the Regulation, it is recognized the right to file a complaint to the Guarantor, through the PEC at protocollo@pec.gpdp.it, for the protection of personal data in accordance with the provisions of Article 77 of the Regulation itself.
11. Transfer of data abroad
The data are stored in the offices of the Company and on servers located in the European Union. Further information regarding the transfer of data and the guarantees provided for their protection may be requested by contacting the Company at the e-mail address info@goldenclef.it or by registered letter sent to the Company’s address.