Privacy policy for visitors to the COLORPACK SRL website 

COLORPACK SRL – Via Benvenuto Cellini, 26 – 20020 Solaro (MI), Italy – VAT No. 01485370124 – email info@colorpack.com – Tel. +39 02 96799590 (hereinafter simply “COLORPACK”), in its role as personal data controller pursuant to Italian Leg. Decree 196/2003 and subsequent amendments – Personal Data Protection Code (“Privacy Code”) – and EU Regulation 679/2016 as applied from 25 May 2018 – General Data Protection Regulation (“GDPR”) (hereinafter Privacy Code and GDPR are collectively referred to as the “Applicable Legislation”) hereby recognises the importance of the protection of personal data and considers its protection to be one of its corporate goals.

Before communicating any personal data, COLORPACK invites you to carefully read this privacy policy (“Privacy Policy”) because it contains important information about personal data protection and the safety measures adopted to ensure confidentiality in full compliance with the Applicable Legislation. Furthermore, this Privacy Policy:

is only applicable to the website www.colorpack.com (“Website”) and does not apply to any other websites that may be consulted through external links;

is intended as a Policy for anyone interacting with the Website in accordance with article 13 of the Applicable Legislation;

complies with Recommendation no. 2/2001 on the minimum requirements for on-line data collection in the European Union, adopted on May 17, 2001 by the Work Group Article 29.

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COLORPACK hereby informs you that your personal data will be processed in accordance with the principles of lawfulness, correctness, transparency, limitation of the purposes and storage, data minimisation, accuracy, integrity and confidentiality. Your personal data will, therefore, be processed in accordance with the legal provisions of the Applicable Legislation and the confidentiality obligations therein.

TABLE OF CONTENTS

The following is the table of contents of this Privacy Policy so that you can easily find information on the processing of your personal data.

1. DATA CONTROLLER
2. PERSONAL DATA PROCESSED
   a. Browsing data
   b. Data provided voluntarily
   c. Cookies and related technologies
   3. PURPOSES, LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING
   4. RECIPIENTS
   5. TRANSFERS
   6. DATA STORAGE
   7. YOUR RIGHTS
   8. CHANGES
3. DATA CONTROLLER
   In light of the Applicable Legislation, the data controller of the Website is COLORPACK as defined above, who can be contacted for any information about the processing of personal data by COLORPACK, including the list of data processors.
4. PERSONAL DATA SUBJECT TO PROCESSING

“Personal Data” means any information about an identified or identifiable natural person with particular reference to an identifier such as a name, identification number, location data, on-line identifier or one or more characteristic elements of that person’s physical, physiological, psychological, economic, cultural or social media identity.

The following type of Personal data is collected by the Website:

1. Browsing data

The Website’s computer systems collect certain Personal Data, the transmission of which is implicit in the use of Internet communication protocols. This is information that is not collected for association with you, but by its very nature could, through the processing and association with data held by third parties, allow you to be identified. This information includes IP addresses or domain names of devices used to connect to the Website, URI addresses (Uniform Resource Identifier) of requested resources, the time of the request, the method employed to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters related to your operating system and IT environment.

These data are used to obtain anonymous statistical information on the use of the Website and to check its correct operation; to allow – based on the architecture of the systems used – various functions requested by you to be correctly provided, for security reasons and to ascertain responsibility in the event of hypothetical computer crimes which may harm the Website or third parties and are deleted after 7 days.

1. Data provided voluntarily

You may voluntarily provide Personal Data via the Website, such as your name and email address to subscribe to the newsletter service or to contact COLORPACK through the “Contact” form. COLORPACK will process these data in compliance with the Applicable Legislation, assuming that they relate to you or to third parties who have expressly authorised you to provide them on the basis of an appropriate legal basis legitimising the processing of the data in question. In such cases, you act as an autonomous data controller, assuming all the obligations and responsibilities laid down by law. In this sense, it grants COLORPACK full indemnity in relation to any dispute, claim, request for compensation for damages from processing, etc. that COLORPACK may receive from third parties whose Personal Data has been processed through its use of the Website in violation of the Applicable Legislation.

1. Cookies and similar technology

COLORPACK collects Personal Data through cookies. More information about the use of cookies and similar technology is available in the disclaimer which is displayed upon accessing the Website.

3. PURPOSES, LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING

The Personal Data that you provide via the Website will be processed by COLORPACK for the following purposes:

1. a) purposes related to the execution of a contract to which you are party or to the execution of pre-contractual measures made at your request (e.g. request for contact via the Contact form, registration for the ICT Insider service, etc.);
2. b) purposes of statistical research/analysis on aggregated or anonymous data, therefore without the possibility of identifying the user, aimed at measuring the operation of the Website, measuring traffic and assessing usability and interest;
3. c) purposes relating to the fulfilment of a legal obligation to which COLORPACK is subject;
4. d) purposes necessary to ascertain, exercise or defend a right in court or whenever the judicial authorities exercise their judicial functions;

The legal basis for the processing of Personal Data for the purposes referred to in point a) is the delivery of a service or the response to a request, which do not require consent, in accordance with the Applicable Legislation.

The purpose under point b) does not involve the processing of Personal Data, whereas the purpose under point d) is a lawful processing of Personal Data within the meaning of Applicable Legislation since, once Personal Data has been provided, processing is necessary to comply with a legal obligation to which COLORPACK is subject.

Providing your Personal Data for the above-mentioned purposes is optional, but failure to do so may make it impossible for COLORPACK to respond to your request or fulfil a legal obligation to which COLORPACK is subject.

4. RECIPIENTS
   Your Personal Data may be shared, for the purposes specified in Section 3, with:
5. subjects necessary for the provision of the services offered by the Website, including, by way of example, the sending of emails and the analysis of the Website’s operation, who typically act as COLORPACK’s data processors;
   b. persons authorised by COLORPACK to process Personal Data who have undertaken to maintain confidentiality or have an adequate legal obligation of confidentiality; (e.g. employees and collaborators of COLORPACK); (a. and b. are collectively referred to as “Recipients”);
   c. judicial authorities to allow them to fulfil their functions when required by the Applicable Legislation.
6. TRANSFERS
   Your Personal Data are not transferred to recipients outside the European Economic Area. COLORPACK ensures that the electronic and paper processing of your Personal Data by the Recipients is carried out in compliance with the Applicable Legislation. In fact, transfers are based either on an adequacy decision or on Standard Model Clauses approved by the European Commission. More information and a copy of these agreements can be obtained from the Data Controller.
7. DATA STORAGE

COLORPACK will process your Personal Data for the time strictly necessary to achieve the purposes indicated in point 3. Notwithstanding the above, COLORPACK will process your Personal Data for as long as permitted by Italian law to protect its interests (Art. 2947(1)(3) c.c.). More information about the storage period of Personal Data and the criteria used to determine this period can be requested by writing to the Data Controller.

7. YOUR RIGHTS

Within the limits of the Applicable Legislation, you have the right to ask COLORPACK, at any time, for access to your Personal Data, their rectification or erasure or to object to their processing, the restriction of their processing, as well as to obtain the data concerning you in a structured, commonly used and machine-readable format.

All requests should be sent via email to the address: info@colorpack.com

In accordance with the Applicable Legislation, you have the right to lodge a complaint at any time with the competent supervisory authority (Data Protection Authority) if you believe that the processing of your Personal Data is contrary to the applicable legislation.

8. CHANGES

This Privacy Policy has been in force since June 8, 2017. COLORPACK reserves the right to modify or simply update its content, in part or in full, including as a result of changes in the Applicable Legislation. COLORPACK will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the Website. COLORPACK, therefore, invites you to visit this section regularly to find out about the most recent and updated version of the Privacy Policy to ensure that you are always up-to-date on the data collected and how COLORPACK uses them