Privacy Policy

(Web Site)

Pursuant to and for the purposes of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter also only “GDPR” or “Regulation”) and pursuant to the Legislative Decree no. 196 of 30.6.2003 (hereinafter also only the “Privacy Code“) as modified by the Legislative Decree no. 101/2018 which has made effective the GDPR in Italy, we inform you that the processing of user and / or visitor data (hereinafter also only the “User” or cumulatively also the “Users“) who consult and / or visit and / or register on the website “armundia.com” (hereinafter also only the “Site“) and / or use the related services – regardless of the purchase of the products – takes place in compliance with the legislation for the protection of personal data and the confidentiality by which our business is dutifully inspired, for the purposes and procedures better described in this Privacy Policy.

 The principles, in fact, on which the Website Privacy Policy is based are the following:

1) process personal data exclusively for the purposes and in the manner explained in the information provided at the time of their collection;

2) make personal data available to third-party companies only for purposes that are essential for the provision of the requested service; not to communicate personal data, sell or transfer them to third parties for their own processing without Users having been informed in advance and given their consent;

3) respond to requests for cancellation, modification, integration of personal data provided, in contrast with the personal data processing for the purpose of sending commercial and advertising information;

4) ensure the correct and lawful management of personal data, safeguarding the privacy of Site Users, as well as applying appropriate security measures to protect the confidentiality, integrity and availability of the personal data provided.

We inform you that the Privacy Policy only concerns the Site and not any other websites that may be visited by the User through other links.

 This Privacy Policy is easily available for consultation from the home page of the Site and through links from any other page of the same, where personal data is collected. For the use of specific services provided at the request of the User, specific information will be provided and, where necessary, specific consent will be requested for the processing of their personal data.

1. Type of data processed

Browsing data

The IT systems and software processes functional to the Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow Users to be identified. This category of data includes the IP addresses or domain names of the computers used by the Users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the procedure 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 relating to the operating system and the user’s IT environment.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning. In any case, it should also be noted that the navigation data could be used to ascertain responsibility in the event of hypothetical cyber crimes.

Data provided voluntarily by the User

The optional, explicit and voluntary forwarding of emails to the addresses indicated on the Site entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the communication.

In some sections of the Site, the User will be asked to provide personal data. In this case, specific information will be provided to the User pursuant to art. 13 Legislative Decree 196/2003 relating to the processing of personal data in relation to individual purposes and, if required, where necessary, specific consents expressed.

2. Purpose of the processing

The User’s personal data are collected and processed by Armundia Group S.r.l. for purposes strictly related to the use of the Site and its services. In particular, personal data is processed for the provision of available services by accessing the Site listed below:

• technical administration of the Site;

• registration on the Site, in order to use the relative services;

• management of User requests, whether they are technical or commercial, and requests for information in a broad sense;

• contact with customer service;

• for marketing purposes (receiving newsletters, news, promotions);

Any processing purpose other than the specific one for which the personal data have been provided will be highlighted in the specific information and will be pursued by Armundia Group S.r.l. only after obtaining the express consent of the User.

3. Collection of Users’ personal data

In addition to what is specified above regarding the browsing data, the User is free to provide personal data when sending e-mails to the addresses indicated on the Site and when requesting and using other services.

The transfer to Armundia Group S.r.l. of the User’s personal data requested through the Site in the several collection instances may be necessary for the pursuit of the purposes identified in the specific information, or optional. The mandatory or optional nature of the provision is specified for each instance, at the time of the individual collection of personal data. Any refusal to disclose personal data marked as mandatory makes it impossible to pursue the main purpose of the specific collection. This refusal could also make it impossible to complete the purchase or use complementary services, such as, by way of example, sending newsletters and using the contact form.

The transfer to Armundia Group S.r.l. of further personal data, other than those marked as essential, is optional and has no consequence.

4. Responsible for the personal data processing

The person responsible for the processing of the personal data collected through the Site is Armundia Group S.r.l. (hereinafter also just “Armundia Group” and / or the “Owner”), with headquarters in Viale Trastevere, 209 – 00153 Rome (RM). The Personal Data Protection Officer is the Lawyer Paolo Todaro.

5. Managers and persons in charge of the processing of personal data

For the pursuit of the purposes for which the personal data are collected, the Owner may make use of the following categories of subjects to whom the personal data may be communicated or who may learn about them as data officers: providers of IT services, such as example direct marketing, internet service and cloud computing; subjects who carry out warehouse logistics, promotion, sale and delivery of the Owner’s services; subjects who carry out customer assistance activities; firms and other entities that provide assistance, consultancy and services of a legal, fiscal, accounting, economic-financial, technical-organizational, data processing, communication nature; entities that provide banking, financial, insurance and credit recovery services; subsidiaries, parent companies, investee companies and associates; public authorities and supervisory and control bodies.

To have a complete list of the aforementioned managers who process personal data, the User can contact the Owner, including confirmation of the rights of the interested party, in the manner indicated in the “Contacts” section below.

For the same purpose, Armundia Group appoints as in charge of data processing the following subjects categories: administration, customer service, information systems and marketing (where consent is given), information systems and management of the Site, those involved in the provision of the Site services and the technical and commercial staff.

No personal data collected on the Site will be disseminated in the public sphere.

6. Methods of processing personal data and its storage 

The personal data of the User are mainly processed in electronic format and in some cases also in paper format.

The User’s personal data will be stored allowing identification for the time strictly necessary for the purposes for which the personal data are collected and subsequently processed and, in any case, within the limits of the law. To ensure that the User’s personal data are always accurate and up-to-date, however relevant and complete, we suggest that the User update the personal data entered by him within his account or by contacting the Owner.

7. Transfer and communication of personal data to third parties

The User’s personal data will be disclosed to third parties and / or transferred to foreign countries – even those not belonging to the European Union (e.g. USA) – only with his express consent, except in cases where the communication is mandatory by law. o it is necessary for purposes established by law for the pursuit of which the consent of the interested party is not required and in any case in compliance with the current legislation.

8. User rights

Pursuant to articles 15-22 of the Regulation, the User has the right to obtain from the Owner confirmation of the processing or not of personal data concerning them, even if not yet registered, and their communication in an intelligible way.

Furthermore, the User has the right to obtain from the Owner information about the origin of their personal data, the purpose and procedure of processing their personal data, the logic applied in case of processing carried out with the aid of electronic tools; the identification details of the data officers; the indication of the subjects or categories of subjects to whom the personal data may be communicated to or who can learn about them as, for example, data officers.

The User also has the right to obtain from Armundia Group:

1) the update, rectification, integration of their personal data;

2) the cancellation, anonymization or blocking of their personal data processed in violation of the law, including those that do not need to be kept for the purposes for which the personal data were collected or subsequently processed;

3) the attestation that the operations referred to in points 1) and 2) above have been brought to the attention, also as regarding to their content, of those to whom the personal data have been communicated or disseminated to, except in the case of which this fulfillment proves impossible or involves the use of means that are manifestly disproportionate to the protected right.

Finally, the User has the right to object in whole or in part:

1) for legitimate reasons, to the processing of personal data concerning them, even if relevant to the purpose of the collection;

2) to the processing of personal data concerning them for the purpose of sending advertising or direct marketing material or for carrying out market research or commercial communication.

In order to exercise the aforementioned rights, the User can send a specific written request to the Owner or Data Protection Officer for the purpose of verifying the rights of the interested party, by:

• post office: Armundia Group Srl, Viale Trastevere, 209, 00153, Rome (RM);

• email: dpoarmundia@armundiagroup.it

9. Hypothesis of exclusion of consent

By reason of the Regulation and of the Privacy Code, Armundia Group can process the User’s personal data without requesting consent when this is necessary to comply with a legal obligation or when it is necessary to execute the obligations undertaken contractually towards the User.

10. Personal data of third parties

Should Armundia Group process personal data of third parties communicated directly by its User (for example in the event that the User intends to report a Site service to a friend), the User must ensure that he or she correctly informs the third party in relation to the processing of personal data of the latter pursuant to art. 13 of the Regulation and obtain the consent of the person to whom the personal data refer before communicating them. The User will remain the one and only responsible for the communication of information and data related to third parties without those having given their consent or for their possible erroneous use or against the law.

Consent is not only necessary when such personal data are communicated to Armundia Group for the conclusion of the contract in favor of the third party.

11. Cookies

To allow safe and efficient exploration of the Site, the Owner uses the so-called Cookies. For more information about cookies and their use on the Site, please refer to the page https://www.armundia.com/politica-dei-cookie-ue/ integral part of this information.

12. Social sharing buttons

Social sharing buttons may also be found on the Site. These are specific “buttons” that depict the icons of social networks, such as Facebook, Twitter, Instagram, Pinterest and Google+, and that allow Users – by means of a “click” on the icon – to reach and interact with the related social networks. With the support of these tools, the User can, for example, share content or recommend Site products on social networks.

Following clicks on the Social sharing buttons, the social network may collect data relating to the User’s visit to the Site. As anticipated in the introduction, this privacy statement does not concern the processing of the User’s personal data by the social network for which the User must refer exclusively to the privacy information provided by the social network.

Except for cases where the User spontaneously shares their browsing data with the selected social networks by clicking on the social buttons / widgets, the Owner does not share or disclose any personal data of the User with the social network.

13. Security measures

Armundia Group and the persons appointed as data officers implement adequate security measures in order to minimize the risk of destruction or loss – even accidental – of personal data, unauthorized access or processing that is not permitted or does not comply with the purposes of collection indicated in our Privacy Policy.

However, Armundia Group cannot guarantee its Users that the measures adopted for the security of the Site and the transmission of personal data and information on the Site limit or exclude any risk of unauthorized access or loss of personal data by the devices belonging to the User.

It is always advisable that the User’s computer is equipped with adequate software for the protection of the transmission of personal data over the network, both incoming and outgoing and that its internet service provider has adopted suitable measures for the security of the transmission of personal data on the web.

14. Links to other websites

The Site contains links to other websites which may have no connection with Armundia Group.

The Owner does not control or monitor these websites nor their content. The Data Officer cannot be held responsible for the content of these sites and the rules adopted by them, also regarding the privacy and the processing of the User’s personal data while browsing.

This Privacy Policy does not apply to third party websites. The Site provides links to these sites solely to facilitate the User in searching and browsing and to facilitate hypertext links on the Internet to other sites. The activation of the links does not imply any recommendations or warnings for accessing and browsing these sites, nor any guarantee regarding their content, services or goods supplied by them and sold to Internet users.

15. Use of the Site by minors

The Site is intended for use and consultation by adults. Therefore, any requests from minors will not be taken into consideration.

16. Contacts

For any further information on the processing of personal data, we recommend that you visit the website of the Data Protection Authority at http://www.garanteprivacy.it.

For more information on the processing of personal data carried out by Armundia Group and its managers and / or for the purpose of exercising the rights referred to articles 15-22 of the Regulation, the User can send a specific written request to the Owner or Data Protection Officer, for the purpose of verifying the rights of the interested party, via:

• post: Armundia Group Srl, Viale Trastevere, 209, 00153, Rome (RM);

• email: dpoarmundia@armundiagroup.it

17. Applicable law

This Privacy Policy is governed by Italian law and in particular by the Regulation and by the Privacy Code, by the measures, authorization and guidelines adopted by the Privacy Guarantor governing the processing of personal data.

The Regulation and the Privacy Code guarantee that the processing of personal data is carried out in compliance with fundamental rights and freedoms, as well as the dignity of the interested party, particularly regarding confidentiality, personal identity and the right to data protection.

18. Changes and updates to the Privacy Policy

The Data Controller may modify or simply update, in whole or in part, the Website Privacy Policy, also in consideration of the modification of the laws or regulations governing the matter. Changes and updates to the Privacy Policy will be notified to Users on the Home Page as soon as they are adopted and will be binding as soon as they are published on the Site and will be contained and available for consultation on the Site itself. It is therefore advisable to regularly access this section to check the publication of the most recent and updated Privacy Policy.

19. Specific information relating to the processing of personal data contained in the User Generated Content

It is possible that the User Generated Content (hereinafter also just “UGC” or the “Authorized Contributions”, contain personal data of the User or of third parties (such as, for example, images or identifying depiction of individuals). On this matter, notwithstanding the above detailed Privacy Policy, the following is also specified.

The processing of any personal data contained in the Authorized Contributions is carried out exclusively following the User´s specific consent and will be based on principles of correctness, lawfulness and transparency. Pursuant to article 13 of the Regulation, we therefore provide the following additional information: personal data will be processed within the limits and by reason of the procedures provided by the Regulation and by the Privacy Code: the latter; ii) by publication on the Site, as well as through Armundia Group social handles such as Facebook and / or Instagram as well as by affixing Contributions to promotional-advertising material relating to Armundia Group and its products; iii) for the time strictly necessary to pursue the aforementioned purposes; iv) on paper and / or electronic support.

The conferement of personal data is optional and in the absence of the User’s consent, the Authorized Contributions containing personal data will not be published by Armundia Group.