Pursuant to Article 13 of Legislative Decree No. 196 of 30 June 2003, known as the “Personal Data Protection Code” (hereinafter referred to as the “Code”), We hereby inform you that your personal data (hereinafter the “Data”) will be processed by KEYFROST S.R.L, Via Trezza, 47/A – 30027 San Donà di Piave – Venice – Italy, Share Capital: EUR 200,000.00 fully paid up – Company Registration No.: VE 02877580270 R.E.A. VE-247368 (hereinafter referred to as the “Company”), in compliance with current legislation on the protection of personal data and the related confidentiality obligations.

Please note that this Privacy Notice contains part of the information required under Article 13 of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (hereinafter, the “GDPR”), which entered into force on 24 May 2016 and has been applicable since 25 May 2018, subject to any adjustments and amendments that may become necessary as a result of European or national legislative changes and/or measures taken by the supervisory authorities following the publication of this Privacy Notice.

LEGAL BASIS AND PURPOSES OF DATA PROCESSING

1. Legal basis for processing:

  • a) the performance of a contract to which the data subject is a part;
  • b) the data subject’s consent

1. a) The processing is necessary to enable you to register on the website www.keyfrost.it and access the section dedicated to viewing product data sheets and manuals.

Please note that the provision of personal data marked with (*required) in the form is mandatory in order to complete the registration process; therefore, failure to provide such data, or providing it only partially or incorrectly, will make it impossible for you to register. The provision of data not marked with (*required) is entirely optional; therefore, failure to provide such data, or providing it only partially or incorrectly, will not prevent you from registering.

Once you have completed the registration process, you will receive an email containing your login details (username and password) at the email address you provided in the registration form.

Your username and password will be your login details for accessing the restricted content on the website.

Therefore, once you have registered, whenever you wish to access the members’ area, you will need to enter the aforementioned login details in the box provided.

The personal data you provide during registration, including data relating to internet traffic (such as, for example, your IP address), will also be processed by Keyfrost S.R.L. for the maintenance and technical support of the website; the handling of any complaints and disputes; and for the prevention and prosecution of fraud and any unlawful activity. Furthermore, such data may, of course, be processed to comply with legal obligations.

1. b) Subject to your specific and express consent, and until such consent is withdrawn, your data may also be processed for commercial purposes, such as sending communications and/or notifications regarding events organised by Keyfrost S.R.L. or in which Keyfrost S.R.L. participates, such as trade fairs and conferences, using automated means of contact (e-mail).

It is understood that consent to the processing of your data for this latter purpose is entirely optional; therefore, should you refuse consent, your data will not be processed for this purpose.

METHODS OF PROCESSING

Data processing is guided by the principles of fairness, lawfulness and transparency, and data minimisation (privacy by design); it may be carried out either manually or by automated means designed to store, process and transmit data, and will be carried out using appropriate technical and organisational measures – as far as is reasonable and in line with the state of the art – to ensure, amongst other things, the security, confidentiality, integrity, availability and resilience of systems and services, whilst avoiding the risk of loss, destruction, unauthorised access or disclosure, or, in any event, unlawful use, as well as through reasonable measures to promptly erase or rectify data that is inaccurate in relation to the purposes for which it is processed.

DATA RETENTION PERIOD

The data collected for the purpose referred to in point 1.a) above will be processed for the entire duration of that purpose.

Subject to your consent, the Data collected for the commercial purposes referred to in Article 1(b) above will be retained for 10 years.

Once these retention periods have elapsed, the Data will be destroyed or anonymised.

RIGHTS OF THE DATA SUBJECT

You have the right to request from the Data Controller access to your personal data, the rectification or erasure of such data, the completion of incomplete data, and the restriction of processing; to receive your personal data in a structured, commonly used and machine-readable format, and to transmit such data to another data controller without hindrance (right to data portability); to object, in whole or in part, to the use of your personal data for the marketing purposes referred to in point 1.b) above; to withdraw any consent you may have given at any time; to lodge a complaint with the supervisory authority; and to exercise any other rights granted to you under the applicable legislation.

These rights may be exercised by writing, by post, to KEYFROST S.R.L – Via Trezza, 47/A – 30027 San Donà di Piave – Venice – Italy or, by email, to the following email address: www.keyfrost.it – info@keyfrost.com.

It is understood that, where a request for access is submitted electronically, the information will be provided in a commonly used electronic format.

IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER

The data controller for your personal data is KEYFROST S.R.L – Via Trezza, 47/A – 30027 San Donà di Piave – Venice – Italy – Tax Code 02877580270 – VAT No. IT02877580270

PRIVACY MANAGEMENT MODEL

It should be noted that, in order to comply with the GDPR, the Company is drawing up a privacy organisational framework, defining roles and responsibilities regarding the processing of personal data and, in particular, designating the Heads of Organisational Units or Departments as internal privacy officers; these officers are responsible, in relation to the processing operations falling within their remit, for implementing the data protection framework in accordance with the applicable regulatory requirements.

The Data Controller has designated in writing, as data processors pursuant to Article 30 of the Privacy Code, the employees of the company departments responsible for pursuing the aforementioned purposes, authorising them to process the Data and providing them with appropriate instructions.

The Data may be processed exclusively by subsidiaries of the Polofin Srl group – Via Trezza, 49 – 30027 San Donà di Piave (VE), Venice Companies Register No. 02803200274 – of which KEYFROST S.R.L. is a part.

The Data may also be processed by supervisory and regulatory authorities and any public body authorised to request the data in accordance with statutory provisions or regulatory or EU legislation.

The full and up-to-date list of recipients is available on request by sending an email to the following email address: info@keyfrost.com.