Privacy policy on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) INTRODUCTION This information takes into account the provisions of the GDPR and the Privacy Code (Legislative Decree 30 June 2003 n. 196). The document has also been drafted in accordance with the Guidelines of the Privacy Guarantor (especially the Guidelines for combating spam issued by the Privacy Guarantor on July 4, 2013). Data Controller: Torneria A. C. S.r.l. with registered office in Asola (MN) Via Parma, 68/B (registered in the Chamber of Commerce of Mantova at number REA: MN - 240158; P.Iva - C.F.: 02291190201; Cap. Soc.: € 10.000,00 I.V.; Email: info@torneriaac.eu; PEC: torneriaacsrl@pec.it) Site to which this privacy policy refers: www.torneriaac.eu (Site). The Data Controller has not appointed a DPO. Therefore, you may send any inquiries directly to the Data Controller. GENERAL INFORMATION This document describes how the Data Controller processes your personal data. The following describes the main processing of your personal data. In particular, we explain the legal basis of the processing, whether the provision of personal data is compulsory and the consequences of not providing personal data. To better describe your rights, if necessary, we have specified if and when a certain processing of personal data is not carried out. Site registration The Site does not offer the possibility of registration. Therefore, the Data Controller does not process your personal data for this purpose. Purchases on the Site It is not possible to make purchases on the Site. Therefore, your personal data will not be processed for this purpose.The Data Controller does not process the user's data to send "reminder" emails to purchase products and/or services from the Data Controller. Answering your requests Your data will be processed to respond to your requests for information. The conferment is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user's interest in receiving a response to communications sent to the Data Controller. Marketing Subject to your consent, the Data Controller may process the personal data provided by you in order to send you advertising material and/or newsletters relating to its own products or those of third parties. The legal basis of this treatment is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties, as well as making it impossible for the Data Controller to carry out market surveys, also aimed at assessing the degree of user satisfaction, and to send you newsletters. These communications will be sent to your e-mail. Profiling The Data Controller does not carry out "profiling" with your personal data. Therefore, it will not send you advertising material and/or newsletters relating to its own products or third parties of your specific interest. Data transfer The Data Controller does not transfer your personal data to third parties. Geolocalization The Site does not implement tools to geolocate the user's IP address. Curriculum Vitae It is not possible to send CVs via the Website. Your data will therefore not be processed for these purposes. Communication of personal data As part of its ordinary business, the Data Controller may communicate your personal data to certain categories of subjects. In article 2 you can find the list of subjects to which the Data Controller communicates your personal data. In order to facilitate the protection of your rights, Article 2 may specify in certain cases when your data is not communicated to third parties. The "communication" of personal data to third parties is different from the "transfer" (governed by the preceding point). In fact, in the communication the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the transfer, instead, the third party becomes the autonomous Data Controller. Moreover, to transfer your personal data to third parties is always required your consent. Without prejudice to the foregoing, it is understood that the Data Controller may still use your personal data in order to correctly fulfill the obligations provided for by the laws in force. PRIVACY POLICY Art. 1 Method of processing 1.1 The processing of your personal data will be mainly carried out with the help of electronic or automated means, according to the methods and with the tools suitable to ensure their security and confidentiality in accordance with the GDPR. 1.2 The information acquired and the methods of treatment will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances. 1.3 Through the Site are not processed "special data". Particular data are those that can reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union, health and sex life. 1.4 No judicial data is processed through the Site. Art. 2 Communication of personal data The Data Controller may communicate your personal data to certain categories of subjects. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below: • The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures. • Your personal data may also be disclosed to all those public and / or private individuals and / or legal entities (legal, administrative and tax, judicial offices, Chambers of Commerce, Chambers and Offices of Labor, etc..), if the communication is necessary or functional to the proper fulfillment of obligations under the law. • The Data Controller uses employees and/or collaborators in any capacity. For the proper functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators. • The Data Controller does not use companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of the Data Controller's hardware and software. Therefore, your data will not be communicated to these categories of subjects. • The Data Controller does not use CRM platforms (companies that carry out the activity of sending automated communications to users. Therefore, your personal data are not communicated to these companies. • The Data Controller does not use external companies to provide customer care services. Therefore, your personal data will not be processed for this purpose. The Data Controller reserves the right to modify the above list in accordance with its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data. Art. 3 Personal data retention 3.1 This article describes how long the Data Controller reserves the right to retain your personal data. • User data will be kept only for the time necessary to ensure the proper provision of the services offered through the Site. 3.2 Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time. Art. 4 Transfer of personal data 4.1 The Data Controller is based within the European Union. Therefore, the processing of your data is safe from a regulatory point of view as it is governed by the GDPR. If the transfer of your personal data takes place in a non-EU country and for which the European Commission has issued an adequacy opinion, the transfer is in any case considered safe from a regulatory point of view. This Article 4.1 indicates from time to time the countries to which your personal data may possibly be transferred and where the European Commission has issued an adequacy opinion. • You are therefore invited to access this article regularly to check whether the transfer of your personal data takes place in a country with these characteristics. 4.2 Without prejudice to what is stated in article 4.1, your data may also be transferred to countries outside the EU for which the European Commission has not issued an adequacy opinion. You are therefore invited to regularly review this article 4.2 to find out to which of these countries your data may be transferred. In order to allow for the proper functioning of the Site, your personal data may be transferred to the U.S.A.. In these cases, the Data Controller will take all appropriate contractual measures to ensure an adequate level of protection of personal data, including, among others, the Standard Contractual Clauses approved by the European Commission on June 4, 2021. 4.3 In this article, the Data Controller indicates the countries in which it may specifically direct its activities. This circumstance may imply the application of the legislation of the country of reference, together with that of the GDPR. • At the request of the user, the Data Controller will apply to the processing of personal data any more favourable legislation provided for by the user's national legislation. Art. 5. Your rights under the GDPR Pursuant to art. 13 of the Privacy Regulations, the Data Controller informs you that you have the right: • to request from the Data Controller access to your personal data and the rectification or erasure of the same or the restriction of the processing thereof or to object to the processing thereof, in addition to the right to data portability • revoke consent at any time without affecting the lawfulness of the processing based on the consent given before revocation • to lodge a complaint with a supervisory authority (e.g. the Italian Data Protection Authority). The rights referred to above may be exercised by making a request without formalities to the contacts indicated in the Introduction. Art. 6. Amendments The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Site and ensuring in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this policy. In case of substantial changes to this privacy policy, the Data Controller may give notice of such changes also by email.