This section describes the methods adopted by ELSTEAM S.r.l. to process the personal data of Users who consult the www.elsteam.com website.

This privacy statement was drawn up in accordance with article 13 of European Regulation 2016/679 to protect the personal data of natural persons and permit the free movement of such data, for subjects interacting with ELSTEAM S.r.l. via the website www.elsteam.com.

Services that require the supply of personal data, such as access to private areas, requests for commercial or technical information, job applications and requests to subscribe to the newsletter, can no longer be provided unless the privacy statement has been read and accepted by ticking the relevant box.

The company shall not be held liable if the User ticks the box without reading the statement as requested. The User may nevertheless invoke the rights described in this privacy statement.

The company shall not be held liable if the User utilises third-party data for authentication or subscription purposes without authorisation. In such circumstances, however, the third party will be entitled to enforce the rights described in this privacy statement, in particular, the right to have data erased.

The privacy statement:

–    is intended to apply solely to this website and not other sites that may be consulted by the User via hypertextual links

–    may be subject to modifications in the future: the User is therefore invited to consult the statement on a regular basis; notification of any important changes will however be given by ELSTEAM S.r.l.

–    is intended to provide the information set out below.

If the User is below the age of 16 years, in accordance with article 8 of the Regulation, such processing shall be lawful only if consent is given in the form of authorisation from the minor’s parents or a subject acting on their behalf.

 

  1. DATA CONTROLLER

The Data Controller is the company ELSEAM S.r.l., with registered office in Piazzale Cesare Battisti 3, 32100 Belluno (BL) ITALY, email address info@elsteam.it

 

  1. DATA PROCESSOR

Pursuant to article 28 of European Regulation 2016/679, the company EVCO S.p.A. with registered office in Via Feltre 81, 32036 Sedico (BL) ITALY, is appointed as data processor, being instructed to deal with the technical aspects of the website.

 

  1. COOKIES POLICY

Cookies are short text strings that websites visited by the User send to the browser on his or her display device, where they are stored before being re-transmitted to the same sites during that visit or when the same user next visits the site.

While navigating on a website, the User may receive cookies on his or her browser that are sent from different websites or web servers (referred to as third parties).

Cookies are used for different purposes, such as IT authentication, session monitoring, storage of data on specific configurations for Users accessing the server, storage of preferences, etc.

According to the purposes for which they are used, cookies can be classified as technical cookies, first- or third-party analytics cookies, first- or third-party profiling cookies.

Technical cookies, defined as either navigation or session cookies, are those used to ensure that Users can browse and benefit from the website and the services requested; they are not used for any other purpose and are normally installed directly by the manager of the website (the User’s prior consent is not required). Without the use of this type of cookies, certain operations would be impossible to perform or would become more complex and/or less secure.

ELSTEAM S.r.l. uses exclusively technical session cookies on its website (cookies that are strictly necessary) in order to enable and facilitate browsing; the website cannot function without them.

 

  1. TYPES OF DATA PROCESSED

Browsing data

During normal operation the information systems and software procedures used to operate the www.elsteam.com website acquire a certain amount of data. Transmission of such data is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified data subjects but, by its very nature, could allow Users to be identified through processing and association with data held by third parties.

This category of data includes IP addresses or domain names of computers operated by Users connecting to the site, URI (Uniform Resource Identifier) of 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 from the server (successful, error, etc..) and other parameters relating to the User’s operating system and IT environment.

These data are used solely for the purpose of obtaining anonymous statistical information on how the website is used and to check that it is functioning properly.

The data may be used to ascertain liability in a suspected computer crime directed against the site.

 

  1. WHERE, HOW AND FOR HOW LONG DATA ARE PROCESSED

Browsing data

Data are stored at the EVCO S.p.A. head office at via Feltre 81, 32036 Sedico (BL) ITALY (using automated tools and taking specific security measures to prevent loss, unlawful or improper use or unauthorised access) for the period of time necessary for browsing purposes, with the exception of log files that will be retained for a period of six months in order to safeguard the Data Controller’s legitimate rights. This information, collected in aggregate form for technical operational testing and security purposes, is processed in the legitimate interests of the Data Controller.

 

  1. PURPOSES, LEGAL BASIS AND CONSENT TO PROCESSING OF DATA

The data provided by the User to the www.elsteam.com website in order to benefit from the services are supplied voluntarily, with his or her implicit expression of intent and he or she will be held liable in connection with such data, exonerating the Data Controller from any responsibility for violation of the law, such as the supply of data that are incorrect or belong to third parties or the disclosure of confidential information without the necessary authorisation.

Data may be transferred once this privacy statement has been consulted and cannot be sent until it has been accepted by ticking the relevant box.

It therefore follows that the transfer of data and information is an expression of the User’s free, informed consent, which forms the legal basis for the processing of data collected on the website for the purposes stated in the various services provided.

 

Browsing data

These data are obtained with the use of technical cookies and do not therefore require consent (measure of the Data Protection Authority no. 229 dated 8 May 2014). The User may not therefore opt out unless he or she is prepared to forgo a service that is complete and of the highest standards.

For security purposes, these data are recorded automatically, including the IP address, which may be used in accordance with relevant legislation in force to block attempts to damage the service, to prevent damage to other Users or harmful activities and crimes. These data are never used to identify or profile a User, but merely for prevention purposes and to safeguard the service, its Users and the legitimate interests of the Data Controller, and the User is presumed to have supplied them freely and willingly in order to benefit from the service.

 

  1. POSSIBLE RECIPIENTS AND INTENTION TO TRANSFER DATA TO THIRD COUNTRIES OR TO INTERNATIONAL ORGANISATIONS

ELSTEAM S.r.l. will process the data of European Users and those based in Europe exclusively in the European Union and will not transfer them to third countries or international organisations.

 

  1. USERS’ RIGHTS

Users who have supplied data and given their consent to processing may, in any event and at any time, exercise a number of rights referred to in article 13 and other articles of European Regulation 2016/679.

 

Article 7

Conditions for consent – Right to withdraw consent

 

Article 15

Right of access by the data subject

 

Article 16

Right to rectification

 

Article 17

Right to erasure – Right to be forgotten

 

Article 18

Right to restriction of processing

 

Article 19

Notification obligation regarding rectification or erasure

 

Article 20

Right to data portability

 

Article 21

Right to object

 

Users may exercise their rights by contacting ELSTEAM S.r.l., with registered office in Piazzale Cesare Battisti 3, 32100 Belluno (BL) ITALY, email address info@elsteam.it

 

Article 77

Right to lodge a complaint with a supervisory authority

Users may exercise their rights by contacting the Data Protection Officer, whose head office is situated at Piazza di Monte Citorio 121, 00186 (ROME) ITALY, email address rpd@gpdp.it

 

  1. SECURITY OF DATA PROVIDED

The Elsteam.com website processes Users’ data in a manner that is fair, accurate and transparent and the Data Controller has, in accordance with European Regulation 2016/679 and in particular, articles 24 and 25, adopted appropriate, proportional technical and organisational measures to prevent such data from being lost, used in an unlawful or improper manner or accessed without authorisation.

It is also understood that these measures are extended by the Data Controller to all subjects who have been instructed and authorised to access data, both within ELSTEAM S.r.l. itself and at the premises of third parties who may be permitted to process them on its behalf.

 

  1. MODIFICATIONS TO THE DOCUMENT AND REVISIONS

This document is published at the address https://www.elsteam.it/privacy-policy, represents the privacy statement for the website www.elsteam.com and may be subject to modification.

It should be consulted on a regular basis.

If the modifications made are significant and have an impact on the rights and freedoms of the User, notification will be given by ELSTEAM S.r.l.

This privacy statement was last revised on 10 January 2022.