Privacy and Cookie Policy

Friul Intagli Industries S.p.A., with registered offices at Villanova di Prata (33080 - PN), Via Oderzo n. 68 (hereinafter, "Friul Intagli") is committed to protecting the online privacy of the users of its websites. As such, this Privacy Policy has been written, under Article 13 of EU Regulation 2016/679 (hereinafter, the "Regulation"), in order to allow you to understand Friul Intagli’s policy regarding your privacy, and how your personal information will be handled when using our website www.friulintagli.com (hereinafter, "Website"). This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.

The information and data which you may provide, or which may otherwise be collected in the context of your use of Friul Intagli’s services – e.g., access to "Reserved area", subscription to the Newsletter, filling the "Contacts" form (hereinafter, the "Services") - will be used by Friul Intagli in compliance with the Regulation and the confidentiality obligations.

According to the Regulation, any personal data processing carried out by Friul Intagli will respect the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.

CONTENTS

1. Data Controller
2. Personal Data processed
   • Browsing data
   • Data provided voluntarily by the data subject
   • Third party Personal Data provided voluntarily by the user
   • Cookies
3. Purpose of the processing
4. Legal bases and mandatory / discretionary nature of the processing
5. Recipients of Personal Data
6. Transfers of Personal Data
7. Retention of Personal Data
8. Data subjects’ rights
9. Amendments

1. Data Controller

The data controller regarding all personal data processing operations carried out through the Website is Friul Intagli, as identified above. For any information regarding the processing of Personal Data by Friul Intagli, including a list of Friul Intagli’s data processors, please contact: privacy@friulintagli.com.

2. Personal Data processed

As you use the Website, we inform you that Friul Intagli may collect and process information related to you as an individual and which allows you to be identified (either directly, or together with additional information), or which is related to other individuals (“Personal Data”), such as your name, an identification number, an online ID or one or more characteristic elements of your physical, physiological, mental, economic, cultural or social identity.

Personal Data which may be processed by Friul Intagli through the Website are as follows:

The Website’s operation, as is standard with any website on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Friul Intagli does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information is also considered Personal Data. This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.

These data are used exclusively to compile anonymous, statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website – the data is deleted immediately after processing, unless it must be used to identify responsible parties in the event of cybercrime committed which harms the Website or third parties, in which case information on web contacts may be kept for a period of 7 (seven) days.

The Site offers users the opportunity to voluntarily provide personal information through, for example, registering a "Contact" form, subscription to the Newsletter, the optional sending of, explicit and voluntarily, an e-mail to the addresses listed on the Site, etc. This Privacy Policy is intended for the processing of Data provided voluntarily by the User through the Site.

When using some of the services of the Site (e.g. when filling the "Contacts" form), you are allowed to submit Personal Data related to other persons. In any situation where you decide to share Personal Data related to other persons through the Website, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. To this end, you must fully indemnify Friul Intagli against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, initiated by the third parties whose Personal Data have been processed through the use of the Site in violation of the applicable rules on personal data protection.

In any case, if you provide or in other way process Personal Data of third parties in using the Site, you henceforth guarantee – assuming all related responsibilities – that this specific processing is grounded on an appropriate legal basis in accordance with art. 6 of the GDPR, which legitimizes the processing of the information in question.

Definitions, characteristics and application of the legislation

Cookies are small text files that websites visited by the user send and record on the computer or mobile device of the same, and then are transmitted back to the relative sites during the next visit. Thanks to cookies the site remembers the actions and preferences of the user (such as, for example, login data, the default language, font sizes, additional display settings, etc.) so that the user doesn’t need to specify them again when they re-visit the site and browses its pages. Cookies are therefore used to perform authentication information, session monitoring and the storing of information about the activities of users access of a website and may also contain a unique identifier that allows for the monitoring of user experiences on the site for statistical or advertising purposes. During the navigation of a site, the user may also receive cookies on their computer or mobile device from sites or web servers other than the one they are visiting (so-called “third party” cookies). Some operations cannot be performed without the use of cookies, which in some cases are technically necessary for the operation of the site.
There are various types of cookies, depending on their features and functions, and these may remain on the computer or mobile device of the user for different periods of time: so-called session cookies, which are automatically deleted when you close your browser; so-called persistent cookies, which remain on the user’s device until a pre-established date.
Under the legislation in force in Italy, prior explicit consent for the use of cookies is not always required. In particular, such consent is not required for “technical cookies”, i.e. those used for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or as strictly necessary to provide a service explicitly requested by the user. In other words, cookies which are indispensable for the operation of the site or to perform tasks requested by the user.
Among the technical cookies, which do not require prior explicit consent for their use, the Italian Data Protection Authority (see General Measure “Simplified Arrangements to Provide Information and Obtain Consent Regarding Cookies – May 8, 2014”) also includes:

• “analytic cookies” used directly by the site operator to collect information, concerning the number of users and how they visit the site, provided they only process information in aggregate form,
• navigation or session cookies (for authentication),
• functional cookies which allow user navigation on the basis of a set of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided to the same.

The prior consent of the user is instead required for “profiling cookies”, i.e. those aimed at creating profiles related to the user in order to send him/her advertising messages in line with the preferences expressed by the same while surfing the web.

Types of cookies used by the Site and the possibility of (de-)selection

The Site uses the following cookies offering the possibility to (de-)select the same (and therefore to disable them), except for third-party cookies, for which the user must directly refer to the relevant procedures for selecting and de-selecting the cookies mentioned below indicated by way of links:

• Technical cookies – session or navigation – are strictly necessary for the operation of the Site or to allow the users to make use of the content and services they have requested.
• Technical-analytics cookies, which allow for an understanding of how the Site is used by users. These cookies do not collect information about the identity of the user or any personal data. The data is processed in an aggregate and anonymous form.
• Technical-functional cookies, i.e. used to activate specific functionalities of the Site and a number of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.

WARNING: disabling the technical and/or functional cookies of the Site may lead to certain services or features of the Site being unavailable or the Site many not function properly, and the user may be forced to change or manually enter some information or preferences each time they visit the Site.

In detail, the cookies sent from Friul Intagli via their own Site are specified below:

Cookies present on the Website

Cookie settings

The user can authorise, block or delete (in whole or in part) cookies through the specific functions of their navigation program (so-called browser). However, in the hypotheses in which all or some of the cookies are disabled it is possible that the site may not be consulted or that certain services or certain features of the Site will not be available or will not work properly and/or the user may be forced to change or manually enter some information or preferences each time he/she visits the site. For more information on how to set preferences on the use of cookies through your browser, it is possible to consult these instructions:

• Internet Explorer
• Firefox
• Chrome
• Safari

3. Purpose of the processing

Friul Intagli intends to use your Personal Data, collected through the Website, for the following purposes:

• to provide the Services you may request, such as subscribing to the Newsletter, navigating on the Website, granting access to the "Reserved Area" of the Website for users to whom, as customers, credentials are provided directly by the persons authorised of Friuli Intagli, so that they can consult the documents that are reserved to them;
• to respond to any of your requests for assistance or information for the users which filled the request through the "Contact" form;
• to discharge legal, accounting and tax obligations.

4. Legal basis and mandatory / discretionary nature of the processing

The legal basis of the processing of Personal Data for the purposes referred to in section 3.a and 3.b is art. 6 (1) (b) of the GDPR, since processing operations are required in order to provide the services or to respond to requests. The provision of Personal Data for these purposes is optional, however, failure to provide them would imply the inability to initiate the requested Services provided through the Website or to respond to requests.

The purpose referred to in Section 3.c constitutes a lawful processing of Personal Data pursuant to art. 6 (1) (c) of the GDPR. Once Personal Data are provided, the processing may indeed be required to comply with legal obligations Friul Intagli may be subject to.

5. Recipients of Personal Data

Your Personal Data may be shared, for the purposes listed in Section 3, with:

• subjects typically acting as data processors, namely: i) persons, companies or professional firms providing Friul Intagli with advice and consulting in accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services; ii) subjects to engage with in order to provide the Services (collectively "Recipients");
• subjects, bodies or authorities to disclose your Personal Data to in accordance with the provisions of law or under the orders of the authorities;
• persons authorized by Friul Intagli to process the Personal Data required for carrying out activities strictly related to the provision of the Services, who have committed themselves to confidentiality or have an appropriate legal obligation of confidentiality, for example Friul Intagli employees.

The processing operations related to the use of this Website take place at Villanova di Prata, Via Oderzo n. 68 and they are taken care of by persons authorised by the Data Controller. If necessary, data related to the Newsletter service or to the "Job" area can be processed by the personnel of the companies that take care of the technological part of the Website, for example Spider 4 Web S.r.l, at the company's headquarters.

6. Transfers of Personal Data

Friul Intagli does not intend to transfer your Personal Data outside the European Economic Area.

7. Retention of Personal Data

Personal Data processed for the purposes set out in Section 3.a and 3.b will be kept by Friul Intagli for the period deemed strictly necessary to fulfil such purposes. In any case, as these Personal Data are processed for the provision of the Services, Friul Intagli will retain the Personal Data for the period allowed by Italian law to protect its interests (art. 2946 and ensuing articles of the Italian Civil Code).

Personal Data processed for the purposes set out in Section 3.c will be kept by Friul Intagli for the period required by the specific legal obligation or by the applicable law.

For more information on Friul Intagli’s Personal Data retention periods and the criteria adopted in determining these periods, please contact: privacy@friulintagli.com.

8. Data subject rights

Under Articles 15 and following of the Regulation, you, as a data subject, are entitled to request from Friul Intagli, at any time, access to your Personal Data, the correction and erasure of your Personal Data, as well as to object to its processing pursuant to Article 21 of the Regulation. You are also entitled to request the restriction of the processing of your Personal Data in the cases set out in Article 18 of the Regulation, as well as to obtain the Personal Data you have provided to Friul Intagli in a structured, commonly used and machine-readable format, in the cases set out in Article 20 of the Regulation.

Requests should be made in writing to Friul Intagli Industries S.p.a., to the following address: Via Oderzo n. 68, Villanova di Prata (PN), 33080.

In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through this Website violates applicable law.

9. Amendments

This Privacy Policy entered into force on May the 21st 2018. Friul Intagli reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Friul Intagli will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. Friul Intagli therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how Friul Intagli collects and uses Personal Data