Policy on browsing pursuant to Art. 13, Regulation (EU) 2016/679

Var Group S.p.A. (hereinafter also "the Company"), part of the SeSa S.p.A. business group, with registered office in Via Piovola 138, Empoli (FI), VAT no. 03301640482, wishes to inform users about the methods and conditions applied by the Company to personal data processing operations.

In particular, the information is provided in relation to the personal data of users who view and use the Company's website at: www.francescamoriani.it

The Company acts as the "Data Controller", meaning "the natural or legal person, public authority, service or other body that, individually or together with others, determines the purposes and means of processing personal data".

In practice, the processing of personal data may be carried out by persons specifically authorised to carry out processing operations on users' personal data and duly instructed by the Company for this purpose. Under legislation on personal data processing, users who view and use the Company's website acquire the status of "data subjects", meaning the natural persons to whom the personal data being processed refer. It should be noted that the information is not intended to cover other websites that may be viewed by users through links, including social share buttons, on the Company's website. In particular, social share buttons are digital buttons, i.e. direct links to social media platforms (such as, but not limited to LinkedIn, Facebook, Twitter, YouTube) configured in each individual "button". By clicking on these links, users will be able to access the Company's social media accounts. Social media operators, to which the social share buttons provide a link, operate as independent data controllers. Consequently, any information relating to the methods by which these data controllers perform processing operations on users' personal data can be found on their relevant social media platforms.

1. Personal data subject to processing

Browsing data: during normal operation, the computer systems and software procedures used to operate this website acquire certain personal data the transmission of which is implicit in the use of internet communication protocols. This information is not collected in order to be associated with identified data subjects, but it could, by its very nature, allow the identification of users through processing and association with personal data held by third parties. This category of personal data includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) addresses of the requested resources, 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 related to the user's operating system and computer environment. These personal data are only used to obtain anonymous statistical information on the use of the website and to check its correct functioning. Browsing data do not persist for more than 12 months, except in cases of crime investigation by the legal authorities. This information may also be collected through cookies or other tracking tools. For more information on cookies you can view our cookie policy.

Dati personali spontaneamente conferiti: la trasmissione facoltativa, esplicita e volontaria di dati personali alla Società, mediante compilazione dei form presenti sul sito web, comporta l’acquisizione dell’indirizzo email e di tutti gli ulteriori dati personali degli utenti richiesti dalla Società al fine di ottemperare a specifiche richieste.

Key Performance Indicators: la Società tratterà i dati relativi alle visualizzazioni del sito, visualizzazioni dei post e le relative interazioni per migliorare la prestazione del sito web e l’interazione dello stesso.

2. Purpose and legal basis of personal data processing

In relation to the personal data referred to in point 1), letter a) of this policy, the personal data of users are processed, automatically and only if strictly necessary, by the Company in order to enable browsing. In this case the processing takes place on the basis of the execution of the contract and a legal obligation to which the Company is subject (Art. 6(1)(b) Regulation (EU) 2016/679), so as to ensure the proper functioning and security of the website (Art. 6(1)(b) Regulation (EU) 2016/679); therefore, the express consent of users is not necessary.

With regard to the personal data referred to in point 1), letter b) of this policy, the processing is carried out in order to provide information or assistance to users. In this case, the processing is based on the execution of specific requests and the fulfilment of pre-contractual measures; the express consent of users is therefore not necessary (Art. 6(1)(b) Regulation (EU) 2016/679).

With regard to the personal data referred to in point 1), letter c), of this policy, the processing is carried out in order to improve interaction with the website and analyse its performance; in this case, the processing is based on the legitimate interest of the Data Controller. For this reason, the express consent of users is not necessary (Art. 6(1)(f) Regulation (EU) 2016/679).

3. Nature of the provision of personal data

Notwithstanding the requirements concerning browsing data, whereby their provision is mandatory as they are instrumental in browsing the Company's website, users are free to provide or not to provide personal data in order to receive information or assistance from the Company.

With reference to the processing of personal data provided by filling in the contact form placed on this website, users are free to provide personal data. However, it should be noted that in the event of refusal to provide their data, it will not be possible to respond to any request for information or assistance.

4. Methods and duration of processing of personal data

The processing of personal data is carried out by persons authorised to process personal data, specifically identified and instructed for this purpose by the Company.

The processing of users' personal data is carried out through the use of automated tools with reference to the data for accessing the pages of the website; for more information, we invite users to view our cookie policy.

In all cases, personal data are processed in full compliance with provisions to guarantee the security and confidentiality of personal data, as well as, inter alia, the accuracy, updating and relevance of personal data with respect to the purposes stated in this policy.

Notwithstanding that the browsing data referred to in point 1, letter a) do not persist for more than 12 months; the processing of personal data takes place for the time strictly necessary to achieve the purposes for which they were collected or in any case in accordance with the deadlines provided for by law.

It should also be noted that the Company has adopted specific security measures to prevent the loss or unlawful or incorrect use of personal data and unauthorised access to the data.

5. Recipients of personal data

Solely for the purposes identified in this policy, your personal data may be disclosed in Italy or abroad, within the territory of the European Union (EU) or the European Economic Area (EEA), for the fulfilment of legal obligations. For more information on the recipients of the personal data of users that they have provided by filling in the contact form placed on this website, please refer to the "contact form policy".

Personal data will not be transferred outside the territory of the European Union (EU) or the European Economic Area (EEA).

Personal data will not be circulated and therefore will not be disclosed to the public or to an indefinite number of subjects.

6. Rights pursuant to Articles 15, 16, 17, 18, 20 and 21 of Regulation (EU) 2016/679

Users, as data subjects, may exercise the rights of access to personal data provided for by Art. 15 of the EU Regulation and the rights provided for by Articles 16, 17, 18, 20 and 21 of the same Regulation regarding the rectification, erasure, restriction of the processing of personal data, data portability (where applicable), and objection to the processing of personal data.

The aforementioned rights can be exercised by writing to the following address: digitallaw&dataprotection@vargroup.it. If the Company does not reply within the timeframe provided for by the law, or if the response to the exercising of rights is not appropriate, users may lodge a complaint with the Data Protection Authority.

Contact details:
Personal Data Protection Authority
Piazza Venezia no. 11 - 00187 Rome
Telephone switchboard: (+39) 06.69677.1
E-mail: protocollo@gpdp.it

7. Personal Data Protection Officer

The Personal Data Protection Officer can be contacted at the company headquarters and at the following email address: dpo@sesa.it.