Site Privacy Policy www.acotel.com

 

The purpose of this privacy policy is to describe how we process the personal data of users/visitors (or also "DataSubjects") who consult the website www.acotel.com ("Site"), expressly request information in the dedicated section or receive our newsletters. This information is provided pursuant to Articles 13 and 14 of the General Data Protection Regulation or "GDPR" General Protection Data Regulation" (EU 2016/679).

The Site is operated by AEM Acotel Engineering and Manufacturing S.p.A. (also referred to as "Acotel" "we", "us", "our") with registered office at Via della Macere 20, 00060, Formello, Rome, Italy, which holds the role of data controller (hereinafter also "DataController").

If you access and use this Site or our services, you accept this Privacy Policy. If you do not agree with the provisions of this Privacy Policy, you should not use the Site.

1. Definitions

• "Personal data" or "personal information" (Article 4 number 1 of the GDPR) means: "any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, by reference in particular to an identifier such as a name, an identification number, location data, an online identifier or to one or more features of his or her physical, physiological, genetic, mental, economic, cultural or social identity".
• "Processing" (Article 4 number 2 of the GDPR) means: "any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction".
• "Data controller" (Article 4 number 7 of the GDPR): means "the natural or legal person, public authority, service or other body which alone or jointly with others determines the purposes and means of the processing of personal data...".
• "Data controller" (Article 4 number 8 of the GDPR): means: "the natural or legal person, public authority, service or other body that processes personal data on behalf of the controller".

2.Methods of data processing

We collect personal information when you provide it to us, e.g. through our "Contact Us" page in order to request information, when we are contacted directly by you through the Site and you voluntarily provide us with such information, by submitting an application or registering to use one of the main services provided by Acotel. The personal information we collect may include your name, address, telephone number, e-mail address, business address or telephone number, Social Security number, payment and invoice details or any other information you provide.

Processing is carried out using automated tools (e.g. using electronic procedures and media). Specific security measures are observed to prevent data loss, unlawful or incorrect use and unauthorised access. We follow strict security procedures in the storage and disclosure of personal data, to protect them against accidental loss, damage or destruction.

Personal data will be recorded, processed and stored in Acotel's archives, paper and electronic, in compliance with the appropriate technical and organizational measures referred to in Article 32 of the GDPR. The processing of personal data of the data subject may consist of any operation or set of operations among those indicated in 'art. 4, paragraph 1, point 2 of the GDPR.

We may collect information when you use our Site, our services, our contact and registration forms or when you receive our newsletter. In addition, we may use cookies and web beacons to monitor traffic trends and collect information about previous visits to our Site as described in Section 8. The information we collect may include personal data.

We may process data in aggregate mode, including data derived from personal data, but only following a process of anonymisation or pseudonymisation by which the characteristics allowing personal identification are removed, including for statistical purposes. For more information on the types of data processed, the retention periods and the relative legal bases legitimising such processing, please refer to the table in point 5.

The data subject's personal data will be processed within the European Union and stored on servers located within the European Union. In the event that the personal data of the interested party is processed in a non-European Union country, the rights attributed to the latter by Community legislation will be guaranteed and the interested party will be promptly notified.

 

under 16 years of age

Minors under 16 years of age may not provide personal data and Acotel will not be in any way responsible for any collection of personal data, as well as false statements, provided by the minor. In any case, if it is found to be used, Acotel will facilitate the right of access and deletion of data, as described below, forwarded by the legal guardian or guardian's legal guardian. If you believe that information about your child under the age of 16 may have been provided to Acotel and/or collected by us, please contact us at: privacy@acotel.com.

3. Data Controller and Data Processors

The data controller is AEM Acotel Engineering and Manufacturing S.p.A., with registered office at Via della Macere 20, 00060, Formello, Rome. Any changes to the corporate information reported are available on the website https://www.acotel.com.

The list of Data Processors is available at Acotel's offices, they are essentially included in the category of partner companies that distribute or integrate our services, offer them to the public in their name specifying that they are developed and delivered by us, etc.

4. Information security

The security of your information, referring not only to personal information collected through the Site, is important to us. Acotel has implemented reasonable security measures to protect the information we process including, but not limited to, the use of firewalls and appropriate encryption. No method of transmission via the Web of electronic storage is 100% secure; therefore, we strive to use reasonable means to protect your information, but we cannot guarantee absolute security. If you have any questions or concerns about the security of your personal information, you can send an e-mail to privacy@acotel.com.

5. Purpose of processing, legal basis and data retention period

Purpose	Type of data processed	Legal basis	Conservation period*
a) Pre-contractual/contractual Provide information about products and services marketed by Acotel, if requested by you; performance of existing contractual relationships.	Biographical and contact data; data necessary for the execution of the contractual relationship	Performance of a contract to which you are a party or pre-contractual measures taken at your request (e.g., registering your account and verifying your identity); fulfilment of legal obligations.  Article 6(1)(b) and (c) GDPR.	According to law.
b) Direct marketing Sending, by automated means of contact (email and instant messaging) and traditional means (operator-assisted telephone calls and regular mail), advertising material, newsletters, promotional and commercial communications related to products and/or events and/or related training courses, as well as conducting market studies and statistical analysis and customer satisfaction surveys.	Personal data and contact details.	Consent (required by contract or specific request); (optional and revocable at any time) Art. 6 para. 1 lit. a) GDPR.	Until consent for that purpose is withdrawn and/or five years have elapsed since the 'expression of consent.
c) Marketing to existing customers Sending communications related to contracted products/services and/or similar products/services to those already contracted (newsletters, webinars, events, training activities).	Biographical and contact data; company affiliation data and role held.	Legitimate interest Art. 6 co 1 lett. f) GDPR.	Until consent is withdrawn.
d) Indirect marketing Disclosure of data to business partners/third parties so that they can make you the recipient of marketing communications.	Personal data and contact details.	Consent (required by contract or specific request) (optional and revocable at any time) Art. 6 para. 1 lit. a) GDPR.	Until consent for that purpose is revoked and/or five years have passed since the last interaction with the Data Controller.
(e) Collection and publication of content: generation of case histories and publications on social networks, newspapers, magazines and websites of images, videos, reviews, evaluations and other content that the data subject may freely decide to share with the Data Controller, as well as on any other media used (as provided for in the individual consents requested from time to time).	Biographical data; pictures, sounds, company affiliation, professional role and experience, nickname, social networks profile	Consent (optional and revocable at any time) Art. 6 co 1 lett. a) GDPR.	Until consent for that purpose is revoked and/or five years have passed since the last interaction with the Data Controller.
(f) If necessary, to ascertain, exercise or defend the rights of the Holder in court.	Biographical data and contact details, contract performance data.	Legitimate interest (judicial protection) Art. 6 co 1 lett. f) GDPR.	For as long as necessary for the exercise of rights in court.
(g) Service purposes on purchased products and services.	Biographical, contact, personal data according to the product/service contracted.	Execution of a contract to which you are a party (to resolve anomalies and malfunctions). Legitimate interest (for analysis aimed at service improvement).	Five years since the last interaction.

*After deletion, data may be retained for an additional period, of up to one year, according to Acotel's information systems backup retention policies.

6. Misuse of the Site

By using this Site or our services, you undertake NOT to use its contents for the following purposes: a) carrying out unlawful activities or activities in conflict with public order; b) disseminating content of a racist, xenophobic, pornographic, pro-terrorist, anti-human rights or otherwise unlawful nature; c) attempting to access and/or use the e-mail accounts of other users, modify and/or manipulate their messages; d) in general, for purposes that are unlawful or harmful to the rights and interests of third parties.

You are obliged and undertake not to transmit, disseminate or make available to third parties any type of content present on the Site, including (non-exhaustive list): information, texts, data, content, messages, graphics, drawings, audio and/or image files, photographs, recordings, software, logos, trademarks, icons, technologies, photographs, software, links, graphic design, source codes or any other content to which you have had access.

7. How we share data

Acotel will not share your personal data with other companies, except in the following cases:

• Mandatory Disclosure: We may share your personal information when we are required to do so by government authorities or applicable law (for example, for law enforcement investigations, subpoenas or court orders), or with third parties if we believe, in good faith, that disclosure is necessary to protect our rights (including to enforce Acotel's T&Cs or to protect the rights of third parties).
• Service providers: In order to properly provide our services, we may have to share some of your personal data with partner companies (e.g. product shipping), who will not make independent use of the information they receive and who have agreed to adhere to the rules set out in our privacy policy.
• Business Transfers: In the event that Acotel is (or substantially all of its assets are) acquired by a third party as a result of a sale, merger, reorganization, liquidation or other business transfer, personal information stored in our databases will be subject to such acquisition.
• Non-Personal Information: Acotel may share aggregate or anonymous information with business partners and other third parties in accordance with the terms of this privacy policy.

8. Cookies

When you interact with the Site we may automatically collect information about your browsing activities through the use of cookies, log data and etc. Cookies are short text fragments (letters and/or numbers) that allow the web server to store information on the client (the browser) to be reused during the same visit to the Site (session cookies) or later, even after a few days (persistent cookies). Cookies are stored, according to the user's preferences, by the individual browser on the specific device used (computer, tablet, smartphone). In the remainder of this document we will refer to cookies and all similar technologies by simply using the term "cookies".

Acotel may place cookies on your computer and/or mobile device, in addition to those placed by advertisers.

We use such technologies to personalize our Site and/or provide customized content, including in advertising marketing for our services, or even for analytics and tracking purposes, including collecting aggregate data on Site usage.

The above data may include:

• information about your interactions with the Site;
• technical information about your computer (URL, cookies, IP address, device ID, types of devices you are using to access our Site and/or use the Services, type of network connection, type of browser, Internet service provider, etc.);
• demographic information (gender and preferences using log files, postcode, age).

We use the following types of cookies on the Site:

1. Session cookies

These cookies are essential for the proper functioning of the site. They are temporary cookies that expire at the end of a browser session; that is, when you leave the site. Session cookies allow Acotel to recognise you as you navigate between pages during a single browser session and allow you to use the Site more efficiently. These cookies help us maintain security and verify your details while you use the Site as you navigate between pages, which saves you having to re-enter your details each time you access a new page. Deactivating them will affect your use of the Site and the services offered through it.

2. Google Analytics cookies

The Site also includes certain components transmitted by Google Analytics. These are cookies collected and managed anonymously to monitor and improve the performance of the host site (performance cookies). Google Analytics uses "cookies" to anonymously collect and analyze information about site usage behavior (including the user's IP address). This information is collected by Google Analytics, which processes it for the purpose of compiling reports regarding activity on the websites themselves. This site does not use (and does not allow third parties to use) Google's analytics tool to track or collect personally identifiable information. Google does not associate IP address with any other data held by Google or attempt to link an IP address with a user's identity. Google may also disclose this information to third parties where required to do so by law or where such third parties process this information on Google's behalf.

Personal data collected: Cookies and Usage data.

Place of processing: USA - Privacy Policy - Opt Out.

3. Google Conversion Tracking Cookie

Google AdWords conversion tracking is an analytical service provided by Google, Inc. which links data from the Google AdWords advertising network with actions performed on this Site. The conversion tracking cookie is set when a user clicks on an ad published by Google. These cookies will expire after 30 days and will not generate personal identification.

Personal data collected: Cookies and Usage data.

Place of processing: USA - Privacy Policy.

 

CHOICE / OPT-OUT

You can manage cookies through features available in most Internet browsers, e.g. choosing which cookies can be placed on your computer, deleting them or disabling them. You can find instructions for managing cookies, for example, on Browser-specific sites:

• Microsoft Internet Explorer browsers
• MacIntosh Safari browsers
• Mozilla Firefox browsers
• Google Chrome browsers

You can also refuse/revoke consent to third-party cookies by accessing the third-party links listed above or by visiting http://www.youronlinechoices.com/.

9. Personal data processed by third parties

Please note that we do not control and are not responsible for the privacy policies used by third parties, including, without limitation, our customers or any site/service linked to our Site or services. We always require our customers and suppliers to share an adequate and comprehensive privacy policy that fully and accurately represents their data processing practices, but we cannot control the actions of our customers, so please be sure to review the privacy policies of all such websites and applications. This site may contain links to other sites. We cannot be responsible for the privacy policies or the content of those sites. Therefore, when you leave our site or view any part of a third party's site through our site, we encourage you to read the privacy policies of the destination sites. This Privacy Policy applies only to information collected by Acotel.

10. Rights of interested parties

Data subjects have the right, in certain circumstances, to:

• Ask whether we possess such information and, if so, what it is and why we process it.
• Request access to your personal information.
• Request correction of personal information.
• Request restriction of the processing of your personal information, for example, if you want to check its accuracy or reasons.
• Request deletion of one's personal information where there is no valid reason to continue processing it.
• Withdraw consent to the collection, processing and transfer of your personal information, even for a specific purpose, at any time.
• To object to the processing of one's personal data for "direct marketing" purposes; this right may cover both automated and traditional modes of contact and may also be exercised only toward certain individual modes
• To object to the processing of one's personal data where a legitimate interest (or that of a third party) is invoked and there are elements relating to a specific personal situation that prompt one to object to the processing.
• Request the transfer of your personal information to you or another party (right to data portability).

If you wish to exercise any of these rights, you may send a notice to privacy@acotel.com, and a response will be sent to you within 30 days. You will not incur any cost to exercise these rights. However, if your request for access is clearly unfounded or excessive we may charge you a reasonable fee. In such circumstances, we may alternatively refuse to comply with the request.

11. Amendment to the Privacy Policy

Any changes to our privacy policy will be posted on this Site and, where appropriate, we will notify you of the changes, for example, by email.

12. Contact details

You may contact Acotel by writing to AEM Acotel Engineering and Manufacturing S.p.A., Via della Macere 20, 00060, Formello, Rome, or by calling +390661141000. Alternatively, you may send a communication by e-mail to privacy@acotel.com.