F.I.L.A. SpA shall herein provide comprehensive information on the processing of personal data collected during web browsing, on registration to the site or through participating in initiatives of F.I.L.A. (events, competitions, workshops) and more generally within the scope of using the services offered by F.I.L.A.
F.I.L.A., as Data Owner in accordance with EU Regulation 679/2016, operates in full compliance with domestic and European regulations on personal data protection and is highly cognisant of the confidentiality of the personal data of its users, observing the appropriate security measures to ensure the protection of the information collected.
The Data Owner is F.I.L.A. – Fabbrica Italiana Lapis ed Affini S.p.A.- via XXV Aprile 5 Pero (MI), Italy
You can contact the Owner at email@example.com
Data Protection Officer
F.I.L.A. S.p.A. has appointed a DPO (Data Protection Officer) who can be contacted at the following address: F.I.L.A. – Fabbrica Italiana Lapis ed Affini S.p.A. – via XXV Aprile 5 20016 Pero (MI), Italy – e-mail firstname.lastname@example.org. Pursuant to art. 38, para. 4, the Data Subject may contact the DPO for any matter relating to the processing of their personal data.
Which data is processed?
1) Browsing data
In principle, it is possible to browse the website without having to provide any personal data. The website comprises separate sections, some of which may require data entry, while others may not.
The computer systems and software procedures used to operate this website acquire, as part of their normal operation, certain information that is implicitly sent in the use of internet communication protocols.
This information may, by its nature, through association and the processing of data held by third parties, allow users/visitors to be identified (e.g. via their IP address, computer domain names used to connect to the website, etc.).
This data is mainly used to create statistics, to check the correct functioning of the website and to make browsing more efficient.
Such web contact data is not retained after processing, unless required to investigate any cyber-crimes against the website. No data from the web service will be communicated or disseminated.
2) Data provided voluntarily by users or visitors
Registration to one of the websites of F.I.L.A. or the requesting of information and services by users may require the collection and subsequent processing of personal data such as one’s name, surname, e-mail address, telephone number, residential address, gender, date of birth, profession, etc..
This type of data may be collected for:
- Entry to specific competitions
- Participation in events organised or sponsored by F.I.L.A.
- Filling out forms online
- Registration and publication of contributions through Social Networks
- Sending requests through the Contacts section of the site
F.I.L.A. within the scope of the activities listed above, shall not process data of a sensitive nature, as per Article 9, Chapter I (“special categories of personal data”) of the Regulation (i.e. data “…which may indicate racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organisations of a religious, philosophical, political or trade union nature, in addition to personal data pertaining to one’s health and sex life”).
F.I.L.A. invites users not to send such data (e.g. through the blank fields on contact forms) unless strictly necessary with respect to the request being made. In this case, the need to give explicit consent to the processing of special categories of data, should it be decided to share such information, is underlined.
F.I.L.A. pays particular attention to the protection of personal data of underage persons. The F.I.L.A. group websites currently do not provide for the collection of personal data directly from minors. Although content of interest also for persons in the under-16 age category exists. F.I.L.A. has taken reasonable precautions to ensure that it does not intentionally collect, store, use or process personal information from minors who may use the F.I.L.A. website and services without adequate parental consent.
Purpose of processing and legal basis
We process personal data for the following purposes:
1. For the functioning of the websites, to improve and personalise the user experience (legal basis: legitimate interest)
2. For registration to F.I.L.A. group websites, when necessary to access reserved sections of the site or to provide specific services of interest to users; this includes sending “transactional” e-mails, linked to site registration and account maintenance (legal basis: processing necessary for the execution of a contract or pre-contractual measures).
3. To respond to users’ requests about F.I.L.A. products/services through the contact forms or other methods (legal basis: legitimate interest)
4. For direct marketing activities, surveys and communication, i.e. sending information about the F.I.L.A. group’s products and initiatives also by e-mail, SMS, ordinary mail, social channels (legal basis: legitimate interest in cultivating relationships with users in order communicate initiatives and new services, or specific consent when necessary)
5. To send the newsletter on F.I.L.A. group products, educational initiatives, sponsored public events, partnerships with other companies, etc. (legal basis: specific consent)
6. To manage registration for and participation in competitions and prize-giving events, including the awarding of prizes (legal basis: performance of a contract or pre-contractual measures).
7. To improve products and services provided by the F.I.L.A. group, determine consumer clusters and optimise communications, through the analysis of web browsing behaviour, social interactions and transactional data (legal basis: specific consent).
8. To comply with EU laws, regulations and provisions of an administrative, fiscal, accounting nature etc. To comply with contractual obligations and to exercise and defend a right in court.
Upon the refusal or revocation of consent, the only consequences of any kind are the cessation of communication activities; the activities carried out before the revocation of consent are considered valid and lawful. Users may at any time object to the processing carried out for direct marketing purposes by contacting the Owner.
Additional specific informative notices may be provided and published from time to time on the Group and partner company websites in relation to individual operations involving the provision of specific personal data (e.g. in the case of special events, competitions, etc.) Always refer to the site www.fila.it to find the most complete information.
Video and photographic material
With regard to video content (images and videos) recorded during events organised or sponsored by F.I.L.A. , we inform you that such may be used, only where the specific release is signed, for public relations initiatives such as, by way of example but not limited to: videos, notice boards, print publications and on websites, social networks and other web communication channels owned by the F.I.L.A. group. Please note that the photographic and video material shall be published anonymously.
Data security and retention time
The processing is performed using automated tools (e.g. using electronic procedures and supports) and/or manually (e.g. on paper) for the time necessary to achieve the purposes for which the data was collected, always in compliance with any regulations in force and in any case no later than the revocation of consent for those purposes that permit such.
In order to protect the security and confidentiality of data, the Owner adopts (and requires its partners to adopt) technical and organizational security measures in order to prevent the risk of loss, destruction, unauthorized access and unlawful use of data.
F.I.L.A. has developed a procedure to deal with and manage possible violations of personal data (“Data Breach”), as required by the European Regulation. Violations will be notified to the Authority if the violation poses a risk to the rights and freedoms of the persons concerned.
Nature of conferment
The provision of data may be necessary to comply with legal obligations and to perform a contract or provide a specific service (e.g. registration for a competition, request for information from the site, etc.). In these cases, any refusal to process in whole or in part may result in the impossibility for F.I.L.A. to perform contractual relations or in any case to provide that requested.
For all other purposes, apart from that already specified for browsing data, users/visitors are free to provide their personal data. Failure to provide such may only result in the impossibility of obtaining that requested or of remaining informed in the best possible way.
If you register on the site or subscribe to the Newsletter, users are required to provide updated, complete and truthful information. If the User provides false, inaccurate, outdated or incomplete information or if F.I.L.A. considers, at its own discretion, that the information provided by the User is false, inaccurate, not current or incomplete, F.I.L.A. will still have the right to deactivate, temporarily or permanently, the account of the User in question and to prevent any subsequent use of the service.
Scope of communication and circulation
Personal data may be brought to the attention of F.I.L.A. employees or collaborators or those of other Group companies. Such parties are formally appointed and authorised to process and receive appropriate operational instructions in this regard. In addition, the data may be processed by outside natural or legal persons whom F.I.L.A. utilises in managing relations with users (internet providers, communication agencies, individual professionals or firms) or for organisational needs. These parties act, where appropriate, as external data processors.
The above-mentioned recipients may operate in other locations than those where the data is collected, although always within the European Economic Area. Should it be necessary to transfer data outside this area, the Owner undertakes to comply with the provisions of Chapter V of the Regulation and to do all necessary to ensure adequate levels of protection and safeguarding of personal data.
The personal data is, in any case, not subject to general disclosure.
Rights of the Data Subject
You may exercise your rights against the Data Owner at any time; they are summarised below, although for an exhaustive description we invite you to check articles 15 to 22 of the Regulation:
- right of access
- confirmation as to whether or not personal data related to him or her are being processed;
- communication of the transfer of data to a third country or an international organisation;
- obtain a copy of the personal data being processed (if and only if the rights and freedoms of others are not violated);
- right of rectification
- right to total cancellation (right to be forgotten)
- right to restriction of processing
- right to data portability
- right to object (not exercisable if there are legitimate reasons for processing overriding his/her interests, rights and freedoms or for the defence of a right in court)
- right to object to direct marketing and/or profiling
- right to withdraw consent
The data subject also has the right to receive timely communication in case of a violation of personal data that could damage their dignity and freedom.
Finally, the data subject has the right to lodge a complaint with the Data Protection Supervisory Authority Autorità di Controllo Italiana – Garante per la protezione dei dati personali – Piazza Venezia 11 – 00187 Roma – email@example.com