PRIVACY & COOKIE POLICY

DATA PROCESSING INFORMATION

This Privacy Policy outlines which data is collected and how it is used, disclosed, transferred, and/or stored by the company.

This information is provided pursuant to Articles 13-14 of Regulation (EU) 2016/679 – hereinafter GDPR – to those who interact with the web services accessible electronically from the address: www.reel2reel-italy.com

This information is subject to updates that will be published promptly on the website.

DATA CONTROLLER

The Data Controller of the data collected from this site is Reel2Reel s.r.l., headquartered at C.so Matteotti, 30 – 10121 Turin (TO) VAT 12483220013 email: sales@reel2reel-italy.com

METHODS OF PROCESSING PERSONAL DATA

The Personal Data provided or acquired will be subject to processing based on principles of correctness, lawfulness, transparency, and protection of confidentiality in accordance with current regulations.

The Controller processes the Personal Data of Users by adopting appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.

The processing is carried out using computer and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. Among the Personal Data collected by this Website, either independently or through third parties, there are: Cookies, Usage Data, Email, and Name. Additional Personal Data collected may be indicated in other sections of this Privacy Policy or by informational texts displayed at the same time as the collection of the Data. Personal Data may be voluntarily entered by the User, or collected automatically during the use of this Website.

1. DATA COMMUNICATION AND DISCLOSURE

In addition to the Controller, in some cases, the Data may be accessible to:

a) categories of appointees, specifically trained for this purpose, involved in the organization of the Website (administrative, commercial, marketing, legal staff, system administrators);
b) external subjects (such as third-party technical service providers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Controller pursuant to Article 28 GDPR. The updated list of Data Processors can always be requested from the Data Controller;
c) public or private entities that may access the Data in compliance with legal obligations;
d) entities performing accessory and instrumental tasks with respect to the activity of the Controller;
e) external entities such as partners in the organization of initiatives and events promoted and/or sponsored by the Controller to whom the communication of Data is necessary for organizational reasons;
f) with the User’s consent, the entities listed under point 5) letter g) of this Privacy Policy.

2. DATA VOLUNTARILY PROVIDED BY THE USER

The optional, explicit, and voluntary sending of emails, including through the Contact Form or the addresses indicated on this Website, entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other Personal Data included in the email. User consent to the provision of Data is necessary to be entered into the Controller’s databases and for the establishment and proper performance of the services offered by the same to its Users, as well as to third parties for the fulfillment of the individual requested activity. Failure to provide Data therefore prevents the registration of the Controller’s databases, the execution of any contracts, and any other activity. Therefore, the User’s failure to provide certain Personal Data may prevent this Website from providing its services. The User assumes responsibility for the Personal Data of third parties published or shared through this Website and guarantees to have the right to communicate or disseminate them, releasing the Controller from any responsibility towards third parties.

3. DATA PROCESSING LOCATION

The data is processed at the operational headquarters of the Controller. For more information, you can contact the Data Controller.

4. DATA PROCESSING TIMES

As expressly provided by Article 5, paragraph 1, letter e) of the GDPR, the Data is kept for the time necessary to carry out the service requested by the User, or required by the purposes described in this document.

In particular:

– The Personal Data collected for purposes related to the execution of a contract between the Controller and the User will be retained until the execution of such contract is completed;
– The Data collected for purposes attributable to the legitimate interest of the Controller will be retained until the satisfaction of such interest. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the same;
– The Data collected based on the User’s Consent may be retained until such Consent is revoked;
– The Data collected for fiscal/administrative obligations will be kept for the time necessary to fulfill the aforementioned purposes and as provided by law, and in any case for a period not exceeding that dictated by civil law regulations;
– The Data may be retained by the Controller for a longer period in compliance with legal obligations or by order of an authority;

The User can always request the interruption of the Processing or the deletion of Data not related to the execution of the contract.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the expiration of this term, the right of access, deletion, rectification, and the right to Data portability can no longer be exercised.

5. PURPOSES OF DATA PROCESSING

The User’s Data is collected to allow the Website to provide its services, as well as for the following purposes: Contacting the User, Managing addresses and sending email messages, interacting with external platforms, and statistics. Specifically:

a) to fulfill any type of obligation contemplated and provided for by current laws, regulations, commercial practices, in particular, in tax/fiscal matters;
b) to follow up on specific requests addressed to the Controller by the User through the Website and its communication tools (Contact Forms, request for information forms, and similar);
c) for informational communications related to the services of the Controller, following the request for information via email or filling out the Contact Form and other communication tools;
d) for other purposes accessory or related to those above and in any case falling within the activities of the Website;
e) for sending information and promotional and commercial offers;
f) for profiling activities for marketing purposes;
g) for the transfer of Data to companies and/or third parties with whom the Controller collaborates or has entered into agreements, who may use the Interested Party’s Data for sending communications and/or informational material regarding events organized by them or services provided by them;

The types of Personal Data used for each purpose are indicated in the specific sections of this document.

For the purposes referred to in point a), processing is necessary for the execution of a contract to which the data subject is a party, for the execution of pre-contractual measures, or to comply with a legal obligation to which the Data Controller is subject.

For the purposes referred to in points b), c), d), processing is optional, however, the failure to communicate one or more Data will result in the impossibility of responding to your request for information and to use the services offered by the Controller.

For the purposes referred to in points e), f), g), processing is based on the freely expressed consent of the data subject.

FURTHER INFORMATION ON PROCESSING

LEGAL DEFENSE

The Personal Data of the User may be used for the defense by the Controller in court or in the stages leading to its possible establishment, from abuses in the use of the same or related services by the User. The User declares to be aware that the Controller may be required to reveal the Data at the request of public authorities.

NATURE OF DATA PROCESSED AND CONSEQUENCES OF REFUSAL

The provision of data related to browsing by Users, for the purposes mentioned above, depends on the degree of privacy that the User has enabled or disabled through their browser. In some cases, disabling may affect the navigation of this Website. For certain modules of this Website, the provision of navigation data and/or the use of technical cookies is mandatory for the proper functioning of the site itself. The provision of certain data is in any case necessary for the structure of the Website and its procedures. Specifically, for example:

• for sending messages through the Contact Form, the minimum data required therein are mandatory;

If not provided, the procedure cannot be completed.

The possible request for other optional Data will instead be preceded by an appropriate approval checkbox. The provision of all other Data is optional, depending on the type of information the User wishes to provide to the Website.

EXERCISE OF DATA SUBJECT RIGHTS

The data subject has the right to exercise the rights provided by Articles 7, 15-22 of Regulation (EU) 679/2016.

In particular, the data subject has the right to revoke their consent at any time and, upon simple request to the Data Controller, can request access to their Personal Data, receive the Personal Data provided to

the Controller and, where possible, transmit it to another Data Controller without impediments (so-called portability), obtain the updating, limitation of processing, rectification of Data, and deletion of Data processed in violation of the law. The data subject has the right, for legitimate reasons, to object to the Processing of Personal Data concerning them and to the Processing for the purposes of sending advertising material, direct sales, and for carrying out market research. The data subject also has the right to lodge a complaint with the Privacy Guarantor as a supervisory authority for the protection of Personal Data. The data subject may exercise their rights by contacting the Data Controller via email at: sales@reel2reel-italy.com

CHANGES TO THIS PRIVACY POLICY

The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving publicity to Users on this page. Therefore, please consult this page often, taking as reference the date of the last modification indicated at the bottom. In case of non-acceptance of the changes made to this Privacy Policy, the User is required to cease using this Website and may request the Data Controller to remove their Personal Data. Unless otherwise specified, the previous Privacy Policy will continue to apply to the Personal Data collected until that moment.

The Data Controller is responsible for this Privacy Policy.

Privacy Policy updated in January 2023

COOKIE POLICY

This cookie policy, or extended information regarding cookies and other tracking tools, concerns the use of Cookies by the website www.reel2reel-italy.com

The Data Controller of the data collected from this site is Reel2Reel s.r.l., headquartered at C.so Matteotti, 30 – 10121 Turin (TO) VAT 12483220013 email: sales@reel2reel-italy.com

Cookies are small text files used by websites to make the User’s browsing experience more efficient and that are sent to their browser, where they are stored to be reused by the same Website on their next visit.

Cookies have different functions. There are Cookies aimed at improving the functionality and navigation of this Website (so-called technical or necessary Cookies). And there are Cookies that are used to monitor users while browsing, record information, and reveal their interests, analyzing their readings, hobbies, to personalize the advertising shown to them when they open an email, browse a social network, or other web pages (so-called profiling Cookies). Cookies are used to personalize content, provide social media functions, and analyze traffic.

In their browser, the user can set Privacy preferences to not store Cookies, delete them after each visit or every time they close the browser, or even accept only the Cookies of www.reel2reel-italy.com and not those of third parties.

Depending on the duration of the cookies on the browser, they are distinguished into:

Session cookies: temporary cookies that remain on the device until the User leaves the site.

Persistent cookies: cookies that remain on the device for a longer time until they are deleted.

This site uses various types of Cookies

Technical Cookies

Technical cookies are those whose use does not require the User’s consent. These are Cookies used solely to carry out the transmission of a communication over an electronic communication network or to the extent strictly necessary for the provider of an information society service explicitly requested. On this Website, technical Cookies are used to store the User’s decision regarding the use of Cookies on the Website itself. The retention period of technical cookies is the duration of the browsing session on the site.

DELETE OR DISABLE COOKIES

Except for the technical cookies strictly necessary for normal browsing, the provision of Data is left to the will of the User who decides to browse the site after having read the brief information contained in the appropriate banner and to use third-party services that involve the installation of cookies. The User can therefore avoid installing Cookies by keeping the banner (thus abstaining from closing it by clicking the “OK” button), removing the checkmark from some or all categories of cookies used by the Site, as well as through the specific functions available on their browser.

The user can manage preferences related to Cookies directly within their browser and prevent third parties from installing them.

It is important for the User to know that disabling all Cookies, the functioning of this Website may be compromised. Each browser presents different procedures for managing settings.

To disable third-party cookies, it is also possible to use Your Online Choices, http://www.youronlinechoices.com/it/le-tue-scelte, a web service managed by the non-profit association European Interactive Digital Advertising Alliance (EDAA) that provides information on behavioral advertising based on profiling cookies and allows users to easily oppose (opt-out) their installation. By deleting all cookies from their browser or removing them through services such as Your Online Choices, these, if from third parties, will be generally inhibited, not only within the perimeter of this site.

FURTHER INFORMATION ON PROCESSING

Specific Information

At the User’s request, in addition to the information contained in this Cookie Policy, this Site could provide additional and contextual information regarding specific services, or the collection and processing of Personal Data.

System Logs and Maintenance

For operation and maintenance purposes, this Site and any third-party services used by it may collect System Logs, which are files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this Cookie Policy

More information regarding the processing of Personal Data can be requested at any time from the Data Controller using the contact information.

EXERCISE OF DATA SUBJECT RIGHTS

Pursuant to Articles 15-22 of Regulation (EU) 679/2016, the data subject has the right to obtain confirmation of the existence or otherwise of personal data concerning them, even if not yet recorded, and their communication in an intelligible form.

The data subject has the right to obtain information:

a) of the origin of the personal data;
b) of the purposes and methods of processing;
c) of the logic applied in case of processing carried out with the aid of electronic instruments;
d) of the identification details of the Data Controller and Data Processors of Personal Data;
e) of the subjects or categories of subjects to whom the Personal Data may be communicated or who may become aware of them as designated representatives in the territory of the State, as managers or appointees.

The data subject has the right to obtain:

a) the updating, rectification, or, when there is interest, the integration of Data;
b) the deletion, transformation into anonymous form, or blocking of data processed unlawfully, including those for which conservation is not necessary for the purposes for which the data were collected or subsequently processed.

The data subject has the right to oppose, in whole or in part:

a) for legitimate reasons to the Processing of Personal Data concerning them, even if pertinent to the purpose of collection;
b) to the Processing of Personal Data concerning them for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication.

NOTICE: The Data Controller is not responsible for updating all the links contained in this Cookie Policy, which refer to third-party sites. Therefore, should a link not work or be out of date, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to by such link.