PRIVACY POLICY

1. Holder of the processing of personal data

Flue Cured Verona Srl, with legal headquarter in via Duomo, 16 Bovolone – VR (Italia) (the “company”, “Flue Cured Verona Srl” or the “holder”) guarantees the observance of the regulation relating to the personal data protection providing the following information relating to the processing of the data supplied or gathered through the navigation in the current website

2. Data processed, purposes and legal bases of processing

Data generated from the access to the website

during their normal operation the informatic systems and the software procedures set up for the operation of this website acquire some personal data, whose transmission is implicit in the use of Internet communication protocols.

Such data (as for instance internet domain names, IP addresses, operating system, kind of device of browser used for the connection) are not accompanied by any personal further information and are utilized for:

1) Obtaining anonymous statistic information on the usage of the website;
2) Controls on the usage of the website;
3) ascertaining possible responsibility in case of computer crimes.

The processing of such data is legitimated to make the website functionalities usable after the user access.

Data voluntarily provided by the user

The personal data provided by the user through the form are collected and processed for the following purposes:

a. To carry out relationship activities with the customer in compliance with its requirements as expressed in the data collection form;

b. For administrative purposes and in compliance with our legal obligations such for example those connected with accounting and tax issues or to execute judicial authority requests;

c. To periodically e-mail newsletters and advertising material after specific consent is given;

d. to receive updates on our activities and advisories on the posting on our blog, after specific consent is given;

e. to receive promotional announcements and invitation to events, training sections, webinar, special promotions or to take part into market research and analysis, after specific consent is given;

f. exclusively for selection purposes, in case of submission of a curriculum vitae; the acceptance of the curriculum vitae is subject to the specific authorization provided therein to the data processing pursuant to the European Regulation; if such authorization is not provided, after a first analysis the curriculum will be deleted and the sender informed.

The legal basis for the data processing is the execution of a contract in which the person is involved or the execution of pre-contractual agreements set upon his request. For the mentioned cases the legal requirement is the consent freely provided by the person concerned.

3. Nature of the conferment

Apart from what specified in connection with the navigation data, the data conferment is:

• elective for the purposes set up in paragraph a), b) and f), but a possible refusal will mean to Flue Cured Verona Srl the impossibility to implement the contractual commitments undertaken and/or to fulfil the customer requests submitted with the inquiry form through the website
• also elective for the purposes set up in paragraph c), d) and e) and use of data is subject to the specific consent given by the customer. A possible refusal will mean to Flue Cured Verona Srl the impossibility to send newsletter and advertising material or invitations to events and other Flue Cured Verona Srl initiatives.

4. Methods of data processing and timeframe for data conservation

The collected data will be processed by means of electronic and automated tools, IT and telematic tools or through manual processing with an aim strictly connected to the purposes for which the personal data have been collected and in any case in a way that grant their security.

The data are kept for the timeframe strictly necessary for the purposes for which they have been collected, in compliance with the current regulations and the legal obligations.

Anyway, Flue Cured Verona Srl applies rules that do not permit the conservation of data indefinitely and that therefore restrict the conservation period in compliance with the principle of minimization of data processing.

5. Processing authorized persons, in charge persons and data communication

The processing of collected data is performed by internal personnel of Flue Cured Verona Srl specifically appointed and authorized to the processing according to specific instructions given in compliance with the current regulation.

The collected data, when necessary or useful for the execution of mentioned purposes, might be disclosed to third parties appointed as external data processing managers or, if the case, transmitted to them as independent entitled subjects, in particular:

i. individuals, companies, associations or professional firms that provide consultancy services to our company for the purposes set up in chapter 1, paragraph b) and f);

ii. companies, bodies and associations providing services connected to the execution of the above mentioned purposes (market research and analysis, credit card payments services, IT maintenance services, debt recovery/credit management companies)

The data collected can not be transmitted abroad

In any case, personal data will never be disclosed.

6. Rights of the interested party

At any time it is possible to access to the data, take position against the data processing or ask for the cancellation, the modification or the update of all the personal information collected by Flue Cured Verona Srl, exercising the right to restriction of processing and of portability, by emailing at info@fcverona.com

7. Data protection manager

The Chief has appointed a data protection manager, that can be contacted at the following email address:
info@fcverona.com

Last update: May 25, 2018