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Privacy policy

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Privacy policy

Latest update: 12/06/2019

PRIVACY NOTICE PURSUANT TO THE ARTICLE 13 OF EU REGULATION 2016/679

This privacy policy describes you in which way Eural Gnutti S.p.A., hereafter also “Eural”, collects and processes your Personal Data. This Document is provided by Eural, as Data Controller pursuant to the article 4 of the EU Regulation 2016/679. The latter (hereafter “GDPR”) lays down very important principles about “the protection of natural persons with regard to the processing of personal data and on the free movement of such data”.

For more information click on the links below:

Definitions

"Personal Data", pursuant to the definition 1 of the article 4 of the GDPR, means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing", pursuant to the definition 2 of the article 4 of the GDPR, means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Who is the Data Controller?

  • Business Name: Eural Gnutti S.p.A.
  • Registered Office: Street S. Andrea, 3, 25038 Rovato (BS)
  • Headquarter: Street S. Andrea, 3, 25038 Rovato (BS)
  • Pontevico Establishment: Via Mattei, 10, 25026, Pontevico (BS)
  • Phone: 030 7725011
  • Email: privacy@eural.com
  • This website is powered by Lbdi Global Omnichannel MarComm Partner & HR Booster
  • You can easily contact Eural Gnutti S.p.A. using the aforementioned informations.

Data Processing Activities related to the Website

Personal Data Collected
Eural collects and processes those Personal Data obtained from the data subjects, such as the identifying ones (i.e: name, surname, email address)

Data Processings Activities Purposes

Eural processes Data Subjects’ Personal Data, collected from the Website, to pursue the following purposes:

  • 1. Login, with which the application identifies the User allowing him/her to access to his/her services, also using third parties. For this purpose, this application will be able to access to some data stored by the third party in order to make available the login action for the user.
  • 2. Direct registration, filling the registration form providing Eural data subjects’personal data.
  • 3. Statistical purposes and profiling, through this website and Google Analytics (Google Inc.) services, that allow the Data Controller to analyze the traffic data and to profile the User.

The following table specifies for each above identified purpose: lawfulness of processing, categories of personal data, categories of data subjects and data storage period:

Data Processing Purposes

Lawfulness of processing

Type of processed personal data

Data Storage Period

Recipients Categories
Purpose 1 Contract / Website Registration • Identification Data
• Personal data		 Until the service disablement *
Purpose 2 Contract / Website Registration • Identification Data
• Personal data		 Until the service disablement *
Purpose 3 Contract / Website Registration • Identification Data
• Personal data		 12 months from the receipt of the Data Subject Consent, unless specifical Italian Supervisory Authority Authorization or data conversion in anonymous form *

*Recipient Categories

In relation to the aforementioned purposes, personal data could be disclosed to the following Companies, Bodies and/or natural persons, located in Italy and also outside Italy, which provide services, also external, on behalf of the Data Controller. Among which**, in order to clarify, we just give an example, not as an exhaustive list:

  • Accounting and business Consultants;
  • IT Service Company;
  • Supervisors Bodies;
  • Supervisor Board;
(**)Recipients / Processors list with additional data useful for the purpose of identification, is available at the Data Controller.

Data Transfer to extra-EU Countries

The Data Controller does not transfer your personal data to Extra-EU Countries.

Data Retention Period

Personal Data will be stored until the execution of the request.

Data Subjects’ Rights

With reference to the aforementioned data processing, the Data Subject can exercise the following rights provided by the GDPR:

  • Right of access by the data subject [art. 15 of the GDPR];
  • Right to rectification [art. 16 of the GDPR];
  • Right to erasure (‘right to be forgotten’) [art. 17 of the GDPR];
  • Right to restriction of processing, including in the case of unlawful processing or disputing the accuracy of personal data by the data subject [art. 18 of the GDPR];
  • Right to data portability [art. 20 of the GDPR];
  • Right to object [art. 21 of the GDPR];
  • Right not to be subject to a decision based solely on automated processing [art. 22 of the GDPR].


The aforementioned rights may be exercised, according to the provisions of the GDPR, by sending an email to privacy@eural.com
Eural, pursuant to the article 19 of the GDPR, proceeds to inform recipients to whom the personal data have been communicated, about any requested corrections, erasure or treatment purpose limitations, where this is possible. Where the data processing activity purpose has Consent as legal basis, the data subject will always be able to withdraw his/her consent, simply sending an email to the aforementioned email address. Pursuant to the article 7 of the GDPR, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

The Data Subject, if he/she considers that his/her rights have been harmed, can lodge a complaint with the Supervisory Authority. For further informations about Data Subjects’ Rights and how to exercise them, please take a look to the LINK Guarantor for the protection of personal data

Mandatory Personal Data Conferral

The Data Controller informs the User that, when the data processing activity purposes have a legal or a contractual obligation as legal basis, the data subject must necessarily provide the Data Controller his/her personal data. On the contrary, the Data Controller will not be able to pursue the specific data processing purposes.Eural Gnutti S.p.A. does not make use of any automated decision-making process.

Modalities of the Data Processing

Personal data will be processed in paper form and electronically inserting them in the applicable data banks (prospects, clients, users, etc.), which can be consulted and processed by the operators and processors appointed by the Data Controller who will be able to carry out the consultation, use, handling, comparison and any other appropriate operation, direct or automatic, respecting the legal requirements necessary to guarantee the confidentiality and the security of the data, as well as their accuracy, updating, and their relevancy to the declared aims.

Notice concerning Children Younger than 16 years old

Children younger than 16 years old cannot express their consent to collect and process their personal data. Eural will not be in any way responsible for any collection of personal data, as well as false statements, provided by the child, and in any case, if you notice its use, Eural will facilitate the right of access and erasure forwarded by the legal guardian or by those who exercise parental authority.

Exercise of the rights of the data subject

The data subject, in relation to the personal data subject of this privacy policy, shall be entitled to exercise the rights provided for by the EU Regulation below:

  • Right of access by the data subject [art. 15 of the GDPR]:
    the data subject has the right to obtain from the Data Controller confirmation that his personal data is being processed and, in this case, access to the information expressly provided for in the aforementioned article, including the purpose of the processing, the categories of data and recipients, the retention period, the existence of the right of cancellation, correction or limitation, the right to propose a complaint, all the available information on the origin of the data, the exemplary and non-exhaustive any existence of an automated decision-making process pursuant to art. 22 of the Regulations, as well as a copy of their personal data.
  • Right to rectification [art. 16 of the GDPR]:
    the data subject has the right to obtain from the data controller the correction and / or integration of the incorrect personal data concerning him, without unjustified delay;
  • Right to erasure (‘right to be forgotten’) [art. 17 of the GDPR]:
    the data subject has the right to cancel his / her personal data without unjustified delay, if one of the reasons expressly provided by the aforementioned article exists, including as an example and not exhaustive the need for treatment with respect to the purpose, revocation of the consent on which the treatment is based, opposition to the treatment in case it is based on non-prevailing legitimate interest, unlawful data processing, deletion due to legal obligations, data of minors treated in the absence of the conditions of applicability expected by art. 8 of the Regulations;
  • Right to restriction of processing [art. 18 of the GDPR]:
    in the cases provided by art. 18, including the unlawful processing, the contestation of the accuracy of the data, the opposition of the interested party and the loss of the need for treatment by the data controller, the information provided by the data subject must be processed only for storage unless the consent of him and the other cases expressly provided by the aforementioned article;
  • Right to data portability [art. 20 of the EU Regulation]:
    the data subject, in cases where the processing is based on consent and contract and is performed by automated means, he may request to receive personal data in a structured format, commonly used and readable by automatic device , and he has the right to transmit them to another Data Controller;
  • Right to object [art. 21 of the GDPR]:
    the data subject has the right to object to the processing of his / her personal data, in the event that the processing is based on a non-prevailing legitimate interest or is carried out for direct marketing purposes;
  • Right not to be subject to a decision based solely on automated processing [art. 22 of the GDPR]:
    the data subject has the right to be not subjected to a decision, including profiling, based solely on automated processing (for example carried out exclusively through electronic tools or computer programs).
The description given above does not replace the text of the articles cited here which are referred to. You can exhaustively and fully read it in the following section “Legal references about rights of data subject.

Right to lodge a complaint

If the data subject considers that his/her rights have been harmed, he/she has the right to lodge a complaint to the SupervisorAuthority (or Data protection Supervisor), according to the modalities indicated by the same authority. If you are Italian you can refer to the following link: http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524. For more information on the rights of the data subject provided by Supervisory Authority, please refer to the following section “Legal references about rights of data subject.

Change and updates

This privacy policy reports the date of its last update in the header. Eural can make changes, update or additions to this privacy policy also as a consequences of any addendum laid down by legal obligations, EU Regulations, Italian and European law.

Legal references about rights of data subject

Article 15
Right of access by the data subject

1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

  • a) the purposes of the processing;
  • b) the categories of personal data concerned;
  • c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  • f) the right to lodge a complaint with a supervisory authority;
  • g) where the personal data are not collected from the data subject, any available information as to their source;
  • h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

2.Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

3.The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

4.The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Article 16
Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Article 17
Right to erasure (‘right to be forgotten’)

1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

  • a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
  • c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
  • d) the personal data have been unlawfully processed;
  • e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
  • f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

2.Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

3.Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
  • a) for exercising the right of freedom of expression and information;
  • b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
  • d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing;
  • e) for the establishment, exercise or defence of legal claims.

Article 18
Right to restriction of processing

1.The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

  • a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  • b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  • c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
  • d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

2.Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

3.A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

Article 19
Notification obligation regarding rectification or erasure of personal data or restriction of processing

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

Article 20
Right to data portability

1.The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

  • a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point b) of Article 6(1)
  • b) the processing is carried out by automated means.
2.In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3.The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

4.The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21
Right to object

1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

6.Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Article 22
Automated individual decision-making, including profiling

1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

2. Paragraph 1 shall not apply if the decision:

  • a) is necessary for entering into, or performance of, a contract between the data subject and a data controller;
  • b) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests;
  • c) is based on the data subject's explicit consent.
3. In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

4. Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject's rights and freedoms and legitimate interests are in place.