Privacy policy and legal notes

This Privacy Policy aims to describe the management of the web site www.paspa.it, owned by Pagano&Ascolillo S.p.A., with registered office in Piazza Sante Bargellini, 21 00157 – ROME (RM), Share Capital: € 1,500,000.00 Register of Companies Number REA RM – 1458421 – Tax Code and VAT Number: 03579660659 in relation to the processing of personal data of users who consult it.
This Privacy Policy constitutes Information pursuant to art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter also the “Regulation“) and art. 13 of Legislative Decree 30 June 2003, No. 196, containing the “Code for the Protection of Personal Data” (hereinafter the “Privacy Code“), and subsequent amendments and additions, to Users connecting to the Portal.
The information is provided only for the Portal and not for other web sites that may be consulted by the User through links.
The Information also takes into account the contents of Recommendation No. 2/2001 of the Group “WP 29”, adopted on 17 May 2001 to identify certain minimum requirements for collecting personal data online, and, in particular, the manner, timing and nature of the information that owners of the data processing must provide users when they connect to web pages, regardless of the purpose of the link.
Users are required to read this Privacy Policy carefully before submitting any personal information and/or filling out any electronic form on the Portal.
For the use of specific services by Users, specific information will be provided from time to time and, where necessary, specific consents will be requested to the processing of their Personal Data.
Pagano&Ascolillo S.p.A. may modify the content of this Privacy Policy at any time by publishing the new version on the Portal. All new privacy terms and conditions will be effective on the date of posting.

Owner of the data processing

Pagano&Ascolillo S.p.A., with registered office in Piazza Sante Bargellini, 21 00157 – ROME (RM), Share Capital: € 1,500,000.00 Register of Companies Number REA RM – 1458421 – Tax Code and VAT Number: 03579660659, is the Owner of the personal data processing of Users who access the Portal, in the person of the pro tempore legal representative Mr. Vittorio Luisi. The Owner of the personal data processing manages the Portal and processes the Data of Users who navigate within it and/or access the following Sections:

  • “Lavora con noi” from paspa.it;
  • “Contacts” of the site paspa.it.

The Owner of the personal data processing guarantees the respect of the prescriptions provided by the Regulation, the Privacy Code and the provisions of the Privacy Guarantor. Any information and request, pursuant to art. 7 of the Privacy Code and articles 15 to 22 and 34 of the Regulations, can be sent by writing to the Owner of the personal data processing at the following address: privacy.pa@paspa.it

Responsible for data processing

Pagano&Ascolillo S.p.A., the Owner of the personal data processing collected from the Users of the Portal – in compliance with articles 39 and following of the Regulations – has appointed as “Responsible for data processing”, Mr. Corleto Giancarlo whose contact data are as follows:
strada provinciale 39, Km1+200 – 84030 San Pietro al Tanagro (Sa)
Tel.: 0975- 395529
Email: info@paspa.it
The Responsible for data processing collects, manages, processes, stores and deletes the Personal Data of the Portal Users, with the collaboration of internal and external Managers for data processing and of Appointees for data processing appointed for this purpose, in compliance with the provisions of the law and regulations. The complete list of the Managers and Appointees for the data processing can be known by writing to the email address: privacy.pa@paspa.it

Place

The processing of Users’ Personal Data, acquired through the navigation of the Portal, takes place in Italy, through servers located at the aforementioned headquarters of the Owner and further and possible secondary offices; and are only handled by staff in charge of processing, or by any appointees of occasional maintenance operations. The processing of the Data takes place on the basis of their storage in computer files kept by the Company. No data processed through the Portal is communicated or disseminated.
The personal data of Users who access the section “Lavora con noi” and “Contacts” of the site paspa.it, are always processed on servers in use at the headquarters of the company, which Appointees for the data processing may have access authorised for that purpose by the Department of Owner of the data processing concerned.

Duration of treatment

The Data is processed for the time necessary to perform the service requested by the User, or required by the purposes described in this document, and the User can always request the interruption of the Processing or deletion of Data, in accordance with applicable regulations.

Methods of treatment

The Owner shall process the Personal Data of Users taking appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of the Personal Data.
The processing is carried out by means of computer and/or telematic tools, with organisational methods and with logic strictly related to the purposes indicated. In addition to the Owner of the data processing, in some cases, the Data may be accessed by categories of employees involved in the organisation of the site (administrative, commercial, marketing, legal, system administrators) or external parties (such as third party technical service providers, couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Managers for data processing by the Owner of the data processing. The updated list of persons in charge can always be requested to the Owner of the data processing.

Purpose of processing of collected data

The Portal provides information about the company, Pagano&Ascolillo S.p.A., and the services offered by it.
In addition to the Navigation Data, the Owner of the data processing may process the User Data, provided voluntarily, in the “Lavora con noi” or “Contacts” sections of the paspa.it website.
User Data are collected to allow the Owner of the data processing to provide its services, as well as for the following purposes:
SPAM Protection, Statistics, Logging and Authentication, Content Commentary, Viewing Content from External Platforms, Content and Functionality Performance Testing (A/B testing), Heat Mapping and Session Recording, Interaction with Online Survey Platforms, Managing Addresses and Sending E-mails, Interaction with Social Networks and External Platforms, and Platform and Hosting Services.
The types of Personal Data used for each purpose are indicated in the specific sections of this document.

Types of Data collected

Navigation Data
The computer systems and software procedures used to operate the Portal acquire, during their normal operation, some personal data (so-called log files) whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified interested parties, but by their nature could, through processing and association with data held by third parties, allow users to be identified.
This category of data includes IP addresses or domain names of computers used by users who connect 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 operating system and computer environment.
For any access to the Portal, regardless of whether a cookie is present or not, the Site may record the following information: browser type (e.g Chrome, Firefox), operating system (e.g. Windows, Macintosh), the host and the URL of origin of the visitor, as well as the Data on the page requested. This Data is used only to obtain anonymous statistical information on the use of the Site and to check its proper functioning and is deleted immediately after processing. The Data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site or third parties: except for this possibility, at present the Data on web contacts are not kept permanently, unless the User requests it.
Data provided voluntarily by the User
The User may browse the Site without revealing his/her personal identity to the Owner of the data processing. However, if you choose to provide your Personal Data, you consent to its collection and use as described in this Privacy Policy.
If the User, by connecting to this Portal, should send – optionally, explicitly and voluntarily – their Personal Data in the “Lavora con noi” section or by sending a message in the “Contacts” section of the paspa.it web site, this will entail the acquisition and processing of the same by the Owner of the data processing for the purposes stated. Personal data voluntarily provided includes:
– Personal data (name, surname, date of birth), Identification data (tax code), Location data (address, etc.), contact details (telephone data, email).
The Owner of the Portal Users’ Data does not process the particular Data referred to Article 9 of the Regulations.
Users who have any doubts about what Data is required are encouraged to contact the Owner.
Cookies
Cookies are not used for the transmission of personal information, nor are systems used for tracking, identifying and profiling Users.
The use of so-called cookies is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow the safe and efficient exploration of the site and used for statistical purposes for the detection of monthly visitors. The cookie can be deleted by the browser using the functions of your browser.
For more information, please check the “Cookie Policy”.

Faculty of data conferment

Apart from what is specified for the Navigation Data, the User is free to provide the Personal Data requested in the section “Lavora con noi” and “Contacts”.
The Personal Data provided voluntarily in the section “Lavora con noi” or by sending a message in the section “Contacts”, are mandatory in order to obtain a response from the Owner of the data processing. Failure to provide the same inhibits, in fact, the possibility of forwarding the request in the appropriate section.
It should be remembered that in some cases strictly established (not object of the ordinary management of the Portal) the Authority may request news and information, pursuant to Article 157 of Legislative Decree No. 196/2003, for the purposes of monitoring the processing of personal data. In these cases, the response is mandatory, under penalty of administrative sanctions.

Scope of data communication

No personal data resulting from navigation in the Portal and processed to process requests sent by the User, accessing the sections “Lavora con noi” or “Contacts” is communicated or disseminated.
The personal data provided by Users who request work, send messages or sending information material (newsletters, answer questions, etc..) are used only to respond to questions received and perform the service or provision requested and are communicated to third parties only if this is necessary for that purpose. The personal data provided by the Users will be communicated to third parties only in the event that the communication is necessary to comply with the requests of the Users themselves.
The User’s personal data are known, processed and managed by employees and persons who may be para-subordinates of the Owner of the data processing, for this purpose in charge of processing, in compliance with applicable laws and regulations, as well as by internal and external data Managers, specifically appointed, and their employees and collaborators in charge.
The User acknowledges and accepts that the Owner of the data processing has the right to disclose Personal Data at the request of the Judicial Authority, within the limits prescribed by law, as well as in cases of violation of the Privacy Rules, civil and criminal proceedings, including for violation of the rights of third parties, in order to protect the rights, property or safety of each User.
The Privacy Policy refers exclusively to the use and disclosure of Data provided directly by the User. If Personal Data is disclosed to others on other Internet sites, the use and disclosure of the Data disclosed may be subject to other rules. Pagano&Ascolillo S.p.A. does not share and does not control the privacy policies or rules of third parties, and with regard to other browsing we inform you that the User is subject to the privacy rules of such third parties, if applicable. We encourage you to obtain information about this before disclosing your Personal Data to others.

Marketing

The Data Controller does not sell, nor transfer for a fee, the User’s Personal Data collected during navigation on the Portal to third parties for marketing purposes, without the explicit consent of the User concerned.
The Owner of the data processing may associate User Data with information that will be collected by other companies in order to improve and customise the services offered and the contents of the Portal.

Data transfer abroad

The personal data of the Portal User processed by the Owner of the data processing and by each Responsible for the data processing, appointed for this purpose in accordance with the applicable Italian and EU regulations, are not transferred abroad to other EU countries or third countries.

Rights of Interested Parties

Transparent Communications: Pursuant to Article 7 of the Personal Data Protection Code and Articles 15 – 22 and 34 of the Regulations, Users of the Portal, by contacting Pagano&Ascolillo S.p.A. at the email address: privacy.pa@paspa.it, may obtain all necessary communications relating to the processing in a concise, transparent, intelligible and easily accessible form, in simple and clear language, particularly in the case of information specifically intended for minors. The information shall be provided in writing or by other means, including, where appropriate, by electronic means. If requested by the data subject, the information may be provided orally, provided that proof of the identity of the data subject can be furnished by other means. The Owner of the data processing may not refuse to comply with the data subject’s request in order to exercise his rights, unless the Data Controller proves that he is unable to identify the data subject. The Owner of the data processing shall provide the data subject with information on the action taken in respect of a request without undue delay and, in any event, no later than one month after receipt of the request.
Without prejudice to the provisions of art. 12, paragraph 5 of the Regulation, the information is provided free of charge.
The right of the Owner of the data processing to request documents attesting to the identity of the party requesting the information referred to in Article 7 of the Privacy Code and Articles 15-22 and 34 of the Regulations remains unaffected, should he have reasonable doubts as to the identity of the natural person submitting the request in accordance with the applicable regulatory provisions referred to above.
Right of access: The User expressly acknowledges that he has the right to obtain the following indication:

  • origin and category of the Personal Data;
  • purposes and methods of processing;
  • logic applied in case of processing carried out with the aid of electronic instruments;
  • the identification details of the Owner, the persons responsible and the designated representative;
  • entities or categories of entity to whom or which the Personal Data has been or will be communicated, in particular, recipients in third countries or international organisations, or who or which may get to know Data in their capacity as designated representative(s) in the State’s territory, managers or person(s) in charge of the processing;
  • the period of retention of Personal Data envisaged, or if not possible the criteria used to determine such period;
  • updating, rectification or, where interested therein, integration of the Data;
  • the cancellation of data, personal, or limitation of the processing of personal data concerning him or oppose the processing;
  • the transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
  • to know all the available information on the origin of the Data;
  • the existence of an automated decision-making process, including profiling, meaningful information on the logic, and the importance and expected consequences of such processing for the data subject.

The Owner of the data processing shall provide a copy of the Personal Data being processed. In the event of further copies requested by the data subject, the Owner of the data processing may charge a reasonable fee based on administrative costs. If the data subject submits the request by electronic means, and unless otherwise specified by the data subject, the information shall be provided in a commonly used electronic format.
The User always has the right to lodge a complaint with the Data Protection Authority.
If Personal Data is transferred to a third country or an international organisation, the data subject has the right to be informed of the existence of adequate safeguards in accordance with Regulation (EU) 2016/679.
Right of rectification: The User has the right to obtain from the Owner of the data processing the rectification of inaccurate Personal Data without justified delay, as well as the integration of incomplete Personal Data.
Right to cancellation: The User has the right to obtain from the Owner of the data processing the cancellation of personal data concerning him without undue delay and the Data Controller has the obligation to delete without undue delay personal data, where the conditions provided for in the Regulation, the Privacy Code and the provisions of the Privacy Guarantor.
Right to Limitation of Processing: The User has the right to obtain from the Owner of the data processing the limitation of processing when one of the following conditions occurs: a) the data subject contests the accuracy of the Personal Data for the period necessary for the Owner of the data processing to verify the accuracy of such Personal Data; b) the processing is unlawful and the data subject objects to the deletion of the Personal Data and requests instead that its use be limited; c) although the Owner of the data processing no longer needs it for the purposes of processing, the Personal Data are necessary for the data subject to ascertain, exercise or defend a right in court; d) the data subject has objected to the processing pursuant to Article 21(1) of the Regulation, pending verification as to whether the legitimate reasons of the Data Controller override those of the data subject.
Right to Data Portability: The User has the right to receive in a structured format, commonly used and readable by automatic device the Personal Data concerning him provided to an Owner of the data processing and has the right to transmit such Data to another Owner of the data processing without hindrance by the Owner of the data processing to which he has provided them.
Right of Opposition: The User has the right to object at any time, for reasons related to his particular situation, to the processing of personal data concerning him including profiling. The Owner of the data processing refrains from further processing of Personal Data unless he proves the existence of legitimate reasons to proceed with the processing that prevails over the interests, rights and freedoms of the person concerned or for the establishment, exercise or defence of a right in court. If the Personal Data is processed for direct marketing purposes, the interested party has the right to object at any time to the processing of personal data for such purposes, including profiling in so far as it is related to such direct marketing, to mean any processing of data for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication.

Prohibition of Spamming

The Owner of the data processing and the Users of the Portal do not tolerate “spamming”, i.e. the unwanted and unsolicited sending of commercial and advertising material and information. The Owner of the data processing periodically carries out an automatic verification of the messages and may use manual filters to check for the presence of spamming, viruses, attempts to acquire Personal Data, to carry out other illegal activities or to transmit illegal or prohibited content, but does not permanently archive the messages sent through these tools. E-mails sent to the Owner of the data processing will not be permanently stored, the email address will not be used for marketing purposes and will not be sold.

Safety and security

The Owner of the data processing guarantees the security of the Users’ Personal Data in compliance with the applicable regulatory framework.

Principles of pertinence and not overuse of the processing.

The User’s Personal Data will be processed in accordance with the principle of relevance and not overused with respect to the purposes pursued. Personal data will be kept for the time strictly necessary for the purposes pursued with the processing of the same.

Right of Complaint

The User expressly acknowledges that the processing of data by the Owner of the data processing is subject to the control of the Guarantor for the protection of personal data, which may be addressed to any and all complaints about the collection, management and processing of data in accordance with the Privacy Code.

Prohibition of Profiling

The User Data of the portal are not profiled or processed by means of an automated decision-making process.

Defence in court

The User’s Personal Data may be used by the Owner in court or in the stages leading up to its possible establishment to defend against abuse in the use of this Application or related services by the User.
The User declares to be aware that the Owner may be required to disclose the Data at the request of the public authorities.