Privacy Policy

PRIVACY POLICY — DM INFORMATICA SRL

Data protection is of paramount importance to DM INFORMATICA SRL. Users can browse the DM INFORMATICA SRL website without providing any personal data; however, if a data subject wishes to access specific services via our website, processing of personal data may become necessary. If such processing is required and there is no other statutory legal basis, we will generally obtain consent from the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, shall always comply with the General Data Protection Regulation (GDPR – Regulation UE 2016/679) and the national data protection regulations applicable to DM INFORMATICA SRL. By means of this privacy policy, our company wishes to inform the general public of the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed of their statutory rights herein.

DM INFORMATICA SRL has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may, in principle, have security vulnerabilities, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, such as telephone.

1. Definitions

Our privacy policy is based on the terminology used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy is intended to be legible and understandable to the general public, as well as to our customers and business partners. To ensure this, we would first like to outline the terminology used herein.

In this privacy policy, we use, inter alia, the following terms:

• a) Personal data: 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.
• b) Data subject: any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
• c) Processing: 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, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• d) Restriction of processing: the marking of stored personal data with the aim of limiting its processing in the future.
• e) Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
• f) Pseudonymization: the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
• g) Data Controller: the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• h) Data Processor: a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
• i) Recipient: a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
• j) Third party: a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
• k) Consent: any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the Data Controller

The Data Controller for the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection laws within the Member States of the European Union is:

• DM INFORMATICA SRL
  Via Pisciarelli, 79 – 80078 Pozzuoli (NA), Italy
  Telephone: +39 08118940302
  Email: info@dminformatica.it
  Website: www.dminformatica.it

3. Name and Address of the Data Protection Officer (DPO)

The Data Protection Officer (DPO) appointed by the controller is:

• Renato Di Monta
  c/o DM INFORMATICA SRL
  Via Pisciarelli, 79 – 80078 Pozzuoli (NA), Italy
  Telephone: +39 08118940302
  Email: info@dminformatica.it

Use of Cookies

The website of DM INFORMATICA SRL uses cookies. Cookies are text files that are stored in a computer system via an Internet browser. Many cookies contain a so-called “cookie ID”, which is a unique identifier of the cookie consisting of a character string through which websites and servers can be assigned to the specific Internet browser where the cookie was stored.

Through the use of cookies, DM INFORMATICA SRL can provide the users of this website with more user-friendly services that would not be possible without the cookie setting. The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

5. Collection of General Data and Information (Server Log Files)

The website of DM INFORMATICA SRL collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider (ISP) of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems. When using this general data and information, DM INFORMATICA SRL does not draw any conclusions about the data subject.

6. Subscription to Our Newsletter

On the website of DM INFORMATICA SRL, users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller. DM INFORMATICA SRL informs its customers and business partners periodically by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if: (1) the data subject has a valid email address and (2) the data subject registers for the newsletter shipping. A confirmation email will be sent to the email address registered by a data subject for the first time for newsletter shipping, for legal reasons, using the double opt-in procedure. This confirmation email is used to prove whether the owner of the email address as the data subject is authorized to receive the newsletter. The subscription to our newsletter may be terminated by the data subject at any time.

7. Newsletter Tracking

The newsletter of DM INFORMATICA SRL contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, DM INFORMATICA SRL may see if and when an email was opened by a data subject, and which links in the email were called up by data subjects. Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller, subject to explicit consent, in order to optimize the shipping of the newsletter. These personal data will not be passed on to third parties.

8. Contact Possibility via the Website

If a data subject contacts the controller via email or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

9. Routine Erasure and Blocking of Personal Data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject. If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

10. Rights of the Data Subject

• a) Right of confirmation: Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed.
• b) Right of access: Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her stored personal data at any time and a copy of this information (purposes, categories of data, recipients, storage periods).
• c) Right of rectification: Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her or the completion of incomplete personal data.
• d) Right to erasure (Right to be forgotten): Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay where the data are no longer necessary or consent is withdrawn.
• e) Right of restriction of processing: Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where the accuracy of data is contested or processing is unlawful.
• f) Right to data portability: Each data subject shall have the right granted by the European legislator to receive the personal data concerning him or her in a structured, commonly used and machine-readable format, and transmit those data to another controller.
• g) Right to object: Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her.
• h) Automated individual decision-making, including profiling: Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing which produces legal effects concerning him or her.
• i) Right to withdraw data protection consent: Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

11. Data Protection Provisions on the Application and Use of LinkedIn

On this website, the data controller has integrated components and links of the LinkedIn platform. LinkedIn is a web-based social network that enables users to connect with existing business contacts and to create new professional acquaintances. The operating company of LinkedIn for users within the European Economic Area (EEA) is LinkedIn Ireland Unlimited Company (Wilton Place, Dublin 2, Ireland). In compliance with regulations, LinkedIn plugins activate only after explicit user consent via the Cookie Banner. If the data subject is logged in at LinkedIn, the platform associates the visit with their personal profile, unless the user logs out before calling up our website. The applicable data protection guidelines for LinkedIn can be accessed under linkedin.com.

12. Data Protection Provisions on the Application and Use of Google Analytics (with Anonymization Function)

On this website, the data controller has integrated the component of Google Analytics (configured with the IP anonymization function active by default). The operator of the Google Analytics component is Google LLC, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States. In compliance with data protection regulations, the activation of Google Analytics is strictly conditional upon the user’s prior explicit consent via the Cookie Banner. Google Analytics places a cookie on the information technology system of the data subject to analyze the use of our website. The personal data collected (including the shortened IP address) are transmitted to and stored on Google servers in the United States of America. Users can block Google Analytics tracking by installing the official browser add-on available under google.com. Additional information and the applicable data protection provisions of Google may be retrieved under google.com. [1]

13. Data Protection Provisions on the Application and Use of Google AdWords (Google Ads)

The data controller has integrated the Google AdWords service on this website, operated by Google LLC. The placement of tracking and conversion cookies is strictly conditional upon the user’s prior explicit consent via the Cookie Banner. If a data subject reaches our website via a Google ad, a conversion cookie is stored on the information technology system of the data subject (valid for 30 days, non-personally identifiable) to check whether specific actions on the site have been completed (conversion). The data subject can object to interest-based advertising by Google by managing their preferences at google.com. Additional information and the applicable data protection provisions of Google may be retrieved under google.com.

14. Data Protection Provisions on the Application and Use of YouTube

This website includes embedded video components of YouTube, LLC, a subsidiary of Google LLC. The activation of embedded videos is strictly conditional upon the user’s prior explicit consent via the Cookie Banner. If the data subject is logged into YouTube at the time of the call, the platform detects the specific sub-page visited. This tracking can be prevented if the data subject logs out of their YouTube and Google accounts before calling up our website. The applicable data protection provisions for YouTube and Google can be accessed under google.com.

15. Legal Basis for Processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain explicit consent for a specific purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party (e.g., for the supply of goods or services), it is based on Art. 6(1) lit. b GDPR. The same applies to processing operations necessary for executing pre-contractual measures (e.g., inquiries concerning our products or services). If our company is subject to a legal obligation requiring the processing of personal data (e.g., fulfillment of tax and accounting duties), the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person (e.g., if a visitor is injured on our premises and vital health data must be transmitted to medical professionals), based on Art. 6(1) lit. d GDPR.

Finally, processing operations may be based on Art. 6(1) lit. f GDPR for treatments necessary to pursue the legitimate interests of our company or a third party (e.g., ensuring efficient business operations to protect our employees and corporate assets), provided that the fundamental rights and freedoms of the data subject do not override such interests.

16. Retention Period of Personal Data and Nature of Provision

The criteria used to determine the retention period of personal data are the respective statutory retention periods mandated by applicable law (civil, tax, and employment law). After the expiration of that period, the corresponding data are routinely deleted, provided they are no longer necessary for the performance of a contract or the execution of pre-contractual measures. The provision of personal data is partly required by law or contractual obligations; failure to provide such necessary data would automatically result in the inability to enter into a contract with the data subject. DM INFORMATICA SRL does not utilize automated decision-making or profiling on this website.