In accordance with EU Regulation 2016/679 “General Data Protection Regulation (GDPR)” (hereinafter referred to as “GDPR”), we inform you that the personal data voluntarily entered on the contact page of our website and data from navigation are processed in the manner and for the purposes described below.

Premise

Personal data processing, as defined in Article 4, No. 2 of the GDPR, refers to any operation or set of operations performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, registration, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, deletion or destruction.

In compliance with the provisions of the Regulation on the protection of personal data, we provide the following information about the use of your personal data collected through the completion of the “contact” form on our company’s website and through navigation on our website www.viplas.it.

Data Controller

The Data Controller is Viplas S.r.l. (hereinafter “Viplas” or “Data Controller”), represented by its legal representative pro tempore, with registered office in Gussago (BS), Via Tartaglia 22, which will use them for the purposes indicated below.

For further information, you can contact the Data Controller at the following email address: info@viplas.it

Types of Data Processed

Personal Data

To respond to information requests and communications sent to the Data Controller via telematics or telephone and/or to send messages to the Company by mail or email at the addresses provided on the “Contact” page of the website www.viplas.it, the following personal data voluntarily provided by the User will be processed:

• Name and surname;
• Company affiliation;
• Email address;
• Possible phone number.

Navigation Data

The IT systems and software procedures used to operate the website of the company accessible at www.viplas.it acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. These are information that is not collected to be associated with identified data subjects but which, by their nature, could, through processing and association with data held by third parties, allow for the identification of users. This category of data includes IP addresses or domain names of computers used by users connecting to the website, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method 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 related to the operating system and the user’s IT environment. Navigation data will be collected solely for the purpose of allowing access to the contents of the Data Controller’s website and its correct administration and management. These data are used only to obtain anonymous statistical information on the use of the site and to check its correct functioning. The data may be used by the competent authorities for the investigation of responsibilities in the event of possible computer crimes to the detriment of the site and the company.

All collected data will be processed in compliance with current regulations and, in any case, with due confidentiality.

Cookies

The company’s website uses cookies. By browsing our website and using its features and accepting the terms of this privacy notice, the User consents to the use of cookies in accordance with the terms and conditions of this notice.

What Cookies Are

Cookies are small data files that websites visited by the User send to their terminal or device, where they can be deleted at the end of each session or stored to be retransmitted to the same sites upon the next visit by the same User. Cookies allow a site to recognize the user’s device, track their navigation through the different pages of the site, and identify users who revisit the site.

For more information on cookies and tools that can help users reduce tracking, it is possible to consult the section of the Authority’s website dedicated to it: [http://www.garanteprivacy.it/cookie](http://www.garanteprivacy.it/cookie)

Cookies Used by the Site www.viplas.it

Viplas uses cookies for specific and limited purposes, particularly: to offer the user a more convenient navigation, for internal security purposes, and for system administration. The cookies used on the company’s website belong to the category of “technical cookies”, which are used solely to “transmit a communication over an electronic communication network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to deliver such a service” (Article 122, paragraph 1 of the Privacy Code). They are usually installed directly by the site owner or manager and are divided into:

• Navigation or session cookies necessary for the normal navigation and use of the website;
• Functionality cookies, which allow navigation based on a series of selected criteria (e.g., language, selected services) to improve the browsing experience on the website.

Blocking/Managing Cookies

It is possible to configure the browser to accept all cookies, reject all cookies, or receive a notification when a cookie is set. Each browser is different, so it is advisable to check the browser’s guide for the procedures to change cookie preferences.

Blocking all cookies will have a negative impact on the usability of many websites. If all cookies are blocked, it will not be possible to fully use the functionalities of the website.

Deleting Cookies

It is also possible to delete cookies already stored on the computer: it is necessary to check the guide of the browser.

Links to Third-Party or Partner Services

Through the website www.viplas.it, users may be provided with some services from third parties and/or links to partner platforms. The collection and use of information by such third parties are governed by their respective privacy policies, which should be referred to, and Viplas remains unrelated and assumes no responsibility even for the updating of sites linked to the Viplas portal.

Users acknowledge and agree that they should always refer to the websites referred to by such links and their respective privacy policies.

Data Provided Voluntarily by the User

The spontaneous sending of requests or messages to the email address info@viplas.it or through the completion of the contact form on the company’s website, or even by mail to the Data Controller’s registered office, and/or subscription to the company’s newsletter service involves the processing of the personal data provided by the sender necessary to respond and follow up on the requests sent, such as, by way of example, the name and surname and contact details of the User.

The data will be kept for the time necessary to fulfill the sender’s requests and, in any case, for the time required by specific legal provisions.

We invite users not to send in their communications the names or personal data of third parties unless duly authorized by them.

Purposes of Processing

The personal data of Users will be processed lawfully by the Data Controller pursuant to Article 6 of the GDPR for the following purposes:

• Fulfill the User’s request: The personal data of Users are collected and processed by the Data Controller solely to fulfill their request for sending information, messages, and newsletters. No other processing will be carried out by the Data Controller in relation to the personal data of Users. Except as provided below in this privacy notice, the Data Controller will not make Users’ personal data accessible to other Users and/or third parties.
• Administrative-accounting purposes, or to carry out organizational, administrative, financial, and accounting activities, such as internal organizational activities and activities functional to the fulfillment of contractual and pre-contractual obligations;
• Legal obligations, or to comply with obligations required by law, an authority, a regulation, or European legislation.

Except as specified for navigation data necessary for the execution of IT and telematics protocols, the provision of personal data for the above-mentioned processing purposes is optional but necessary, as failure to provide it will result in the impossibility for the User to receive feedback on their request from the Data Controller. In case of consent, the User may revoke it at any time by requesting it from the Data Controller using the methods indicated in the section dedicated to “rights of the data subjects”.

For the newsletter service, the User may also object to further newsletter deliveries by clicking on the appropriate link for revoking consent, which is present in each email containing the newsletter. After revoking consent, the Data Controller will send the User an email to confirm the revocation.

The personal data necessary for pursuing the processing purposes described in this paragraph are marked with an asterisk in the request form.

The collected data will be processed exclusively for purposes related to the User’s request.

The User is responsible for their own and third-party personal data used or provided to the Data Controller and guarantees that they have the right to use and communicate them, indemnifying the Data Controller from any liability, including to third parties, in relation to the use of personal data of their own or third parties for contacts or requests for information or services from Viplas.

The User consents to the processing by the Data Controller of the personal data voluntarily provided so that the Data Controller can respond to the User’s request and/or execute the requested service.

Processing Methods

Personal data are processed in compliance with principles of fairness, lawfulness, and transparency. In relation to the stated purposes, the processing of personal data occurs through manual, IT, and telematic tools with logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security and confidentiality of the data subject, using appropriate procedures to avoid the risk of loss, unauthorized access, illegal use, and dissemination, in compliance with the limits and conditions established by the EU Regulation 2016/679.

Data Communication

Personal data is processed by our staff and/or by our collaborators who are responsible for managing the Website and following up on communications and/or requests for information or services submitted by Users.

These individuals, who have been instructed accordingly by the Data Controller pursuant to Article 29 of the Regulation, will process User data exclusively for the purposes indicated in this privacy notice and in compliance with the provisions of the Applicable Regulation.

Additionally, third parties involved in managing services connected to and instrumental to our activities may have access to Users’ personal data. These third parties may process personal data on behalf of the Data Controller as “External Data Processors,” such as, for example, IT service providers essential to the Website’s functionality, outsourcing service providers, professionals, and consultants.

Personal data will not be disseminated.

Users are aware that the Data Controller may be required to disclose personal data upon request from judicial authorities and other third parties to whom disclosure is mandatory by law, including in the context of preventing/repressing any illegal activities related to accessing the website and/or submitting a request for information or services.

The list of Data Processors appointed pursuant to Article 28 of the GDPR is available at the Data Controller’s office.

Who We Share Your Data With

Address Management and Email Sending

The following services allow the management of a database of email contacts, phone contacts, or any other type of contacts used to facilitate communication with you. These services may also collect data related to the date and time of message views and your interactions with them, such as information on clicks on links included in the messages.

MAILCHIMP

Mailchimp is an address management and email sending service provided by Mailchimp Inc. Mailchimp participates in the Privacy Shield framework, which is considered an adequate protection measure by the European Commission.

Personal data collected: Email and Name.

Location of processing: USA.

[Privacy Policy](https://mailchimp.com/legal/privacy/)

STATISTICS

The services in this section allow the Data Controller to monitor and analyze traffic data and track your behavior. We have committed to ensuring that these services monitor usage habits without collecting any personal data (anonymizing IP).

GOOGLE ANALYTICS (GOOGLE INC.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the personal data collected to track and analyze the use of this Website, compile reports, and share them with other Google-developed services.

Google may use personal data to contextualize and personalize ads in its advertising network.

Google also offers a browser add-on to disable Google Analytics: [Opt-Out Google Analytics](https://tools.google.com/dlpage/gaoptout).

Personal data collected: Cookies and Usage Data.

Retention period: 14 months.

Location of processing: USA.

[Privacy Policy](https://policies.google.com/privacy)

Transfer of Data to Third Countries or International Organizations

VIPLAS does not transfer personal data to third countries or international organizations. However, the Data Controller reserves the right to use cloud services. In this case, service providers will be selected among those who provide adequate guarantees as provided by Article 46 of the GDPR.

Data Retention Period

Personal data collected through browsing the company’s website and/or following the submission of an information request via the contact form or email of the company and/or to ensure the correct provision of requested and offered services through the VIPLAS website will be retained for the time strictly necessary to respond to the request, for the purposes outlined in the “Purpose of Processing” section.

Users’ personal data will be retained for the time strictly necessary to achieve the primary purposes outlined in the “Purpose of Processing” section, or otherwise according to what is necessary for civil protection of the interests of both the Users and the Data Controller.

Pursuant to Article 13, paragraph 2, letter (f) of the GDPR, it is stated that all collected data will not be subject to automated decision-making processes, including profiling.

Rights of Data Subjects

Pursuant to Articles 15 and following of the GDPR, the User has the right to request at any time access to their personal data, the correction or deletion of the same, restriction of processing in the cases provided for by Article 18 of the Regulation, and to obtain in a structured, commonly used, and machine-readable format the data concerning them, in the cases provided for by Article 20 of the GDPR (data portability).

At any time, it is also possible to:

• Withdraw consent, pursuant to Article 7, paragraph 3 of the GDPR, where consent is the legal basis for processing under Article 6, paragraph 1, letter a);
• File a complaint with the competent supervisory authority under Article 77 of the GDPR (Italian Data Protection Authority), if the User believes that the processing of their data is contrary to the applicable legislation;
• Submit a request to object to the processing of their personal data under Article 21 of the GDPR, providing reasons justifying the objection. The Data Controller reserves the right to assess the request, which may not be accepted if there are compelling legitimate grounds for proceeding with the processing that override the interests, rights, and freedoms of the user, or for the establishment, exercise, or defense of a right in court.

Requests concerning the exercise of the above rights must be sent to the Data Controller: VIPLAS S.r.l. with headquarters in Gussago (BS), Via Tartaglia 22 CAP 25064 or to the email address: info@viplas.it

Updates and Changes to This Privacy and Cookie Policy

The Data Controller reserves the right to make changes and updates to this Privacy Policy at any time, publishing the most recent updated version on this page. By regularly visiting this page, you can view the updated privacy policy, which will include the date of the last modification published at the bottom of the page.

The information may be subject to review following:

• Changes in privacy legislation affecting relevant aspects;
• Technological implementations of the site that impact the current processing methods;
• Organizational changes in the Data Controller’s privacy structure that may affect the user.

Users are kindly invited to periodically visit this Policy to stay constantly updated on the characteristics of processing.

Gussago (BS), July 2024