Dear user, as the personal data controller, Makro Labelling Srl intends to provide you with the broadest possible feedback concerning the methods of processing your personal data and we invite you to carefully read this policy, which is provided pursuant to art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter « GDPR »). The information you will find below allows you to know, even before accessing the various sections of the Website, how the controller will process your personal data, both those provided directly by you, and those collected in other ways by Makro Labelling Srl (hereinafter, collectively, « Personal Data »).
Controller The Controller is Makro Labelling Srl , with its registered office at Via Giovanna dell’Arco 9, 46044 Goito (MN – Italy); phone +39 0376 1872203, e-mail: firstname.lastname@example.org;
Data Protection Officer (DPO): 5.0 Data Solutions Srls can be contacted at the email address email@example.com or by writing to the Controller for the attention of the DPO.
What Personal Data we process
While you are browsing on the Website and/or accessing some sections, the computer systems automatically and indirectly provide and/or acquire some information (for example “cookies”) as well as possibly make requests for information, or should you choose to contact us through the « Contact Us » section of the Website, this involves the processing of data, such as name and surname, email address and the data contained in the message that you will spontaneously send.
What are the purposes of the processing of your Personal Data and its legal bases Your Personal Data are processed without the need for consent, applying the legal basis provided for in art. 6 of the GDPR (execution of the contract and pre-contractual measures, legal obligation of the controller and its legitimate interest) for the following purposes:
- browsing the website, operations related and/or connected to the provision of services by the Company in the context of browsing the website, such as providing the services requested by the data subject while browsing the website, including data collection, storage and processing for the purposes of establishing this provision and subsequently for the operational and technical management
- to respond to your requests for information or contact; (pre-contractual measures art. 6 paragraph 1 letter b) GDPR)
- to manage and implement the formalities required by law (security of computer communications, etc. Article 6 paragraph 1 letter c) GDPR;
- to exercise the rights of the controller with particular reference to the right of defence in court (legitimate interest of the controller, Article 6 paragraph 1 letter f)).
- to send you commercial communications via email concerning products related to those already previously purchased (soft spam) (Article 6 par. 1 letter f)
For subsequent purposes, Makro Labelling will carry out the processing only with your consent, (Article 6 par. 1 letter a) GDPR, which may subsequently be revoked, at any time, by means of a written request to the controller:
- receipt of the newsletter, you can decide to subscribe to the newsletter dedicated to all the news and updates of Makro Labelling Srl
- marketing operations, you may decide to consent to your Personal Data being processed for marketing purposes, i.e. for commercial communications, by email or paper mail, concerning our products.
In relation to this purpose, your consent is required when registering for the newsletter or when using our contact form
Nature of data provision
Since the transmission of the personal data of the data subject for the purposes referred to in points 1) to 5), although always optional, is necessary for the purpose of maintaining and providing all the services connected to navigating the website, failure to communicate these will make it impossible to provide the specific services requested by you. The provision of personal data for the purposes of points 6) and 7) is optional and not necessary, therefore without your specific consent we will not be able to use them for these purposes.
To whom we can communicate your Personal Data Without prejudice to communications made in compliance with legal obligations, your personal data may be known, as well as by the controller, by:
- employees and collaborators and service providers required for the proper operation of the Website and of its functions/services (by way of example and not limited to, ICT service providers, hosting service providers, platform and IT application providers);
- professional third parties appointed for the management, marketing, and assistance in the sale of our products (by way of example but not limited to, the agents who will contact you if you express interest in purchasing our products, marketing agencies);
- legal, administrative and/or public security authorities, in compliance with legal provisions, for the purposes of ascertaining and prosecuting offences, preventing and safeguarding risks or threats to security and public order, as well as for any reason connected with the protection of rights and freedoms of individuals.
These recipients act as authorised data processors, independent controllers or data processors. Personal data will not be disclosed to third parties and are not subject to dissemination. In any case, your personal data are not processed outside the European Union area.
How we process your Personal Data
Processing your Personal Data may include various operations carried out by electronic, automated and/or paper means. The tools and supports used whilst carrying out the processing activities are suitable for guaranteeing the security, integrity and confidentiality of the data, therefore whilst carrying out the processing operations, Makro Labelling Srl undertakes: to ensure the accuracy and update of the data processed, and to promptly acknowledge any corrections and/or additions requested by the data subject; to adopt appropriate security measures to ensure adequate data protection, in consideration of the potential impact that the processing entails on the fundamental rights and freedoms of the Data subject; to ensure compliance of the processing operations with the applicable legal provisions.
Retention of personal data
In order to ensure compliance with the principles of necessity and proportionality of the processing, the Controller has identified different retention periods for Personal Data in relation to the individual purposes pursued:
- a) for the purpose of managing and responding to your requests in relation to products and initiatives of Makro Labelling Srl, (« Contacts » section of the Website), your Personal Data will be kept for the time strictly necessary to process your request;
- b) for the purpose of managing and executing contracts and of fulfilling the obligations required by law (of an accounting, administrative, fiscal nature, etc.), your Personal Data will be kept for the time required by the mandatory regulations;
- c) for the purpose of managing disputes and any litigation, your Personal Data will be kept for the time strictly necessary for this purpose and, in any case, not beyond the applicable limitation periods.
- d) for newsletters, personal data will be kept until cancellation from the newsletter and in any case not beyond 36 months, after which we will ask you to renew your subscription
e) for marketing purposes, they will be kept for 2 years or until you should request to revoke your consent, at the end of the 24 months we will ask you to renew the consent given.
- f) soft spam, 30 days from the closure of the contract unless you object.
Minors under the age of 18 must not provide information or Personal Data to Makro Labelling Srl, should this occur the controller will avoid processing them.
Rights of the Data Subject
The Data Subject can assert his/her rights, recognised by articles from 15 to 22 of the GDPR, such as: Right of access: the right to obtain the confirmation as to whether personal data are being processed and, should this be the case, to obtain access to his/her personal data and to further information on the origin, purposes, categories of data processed, the recipients of the transmission and/or transfer of the data, etc. Right to rectification: the right to obtain from the controller the rectification of any incorrect data without any undue delay, and the integration of any incomplete personal data, including by providing a supplementary statement. Right to erasure: where applicable, the right to obtain the deletion of personal data without undue delay in the event that the personal data are no longer necessary with respect to the purposes of the processing; the consent on which the processing is based has been revoked and there is no other legal basis for the processing; the personal data have been unlawfully processed; the personal data must be deleted to fulfil a legal obligation. Right to object to the processing: the right to object at any moment to the processing of your personal data whose legal basis is the pursuit of legitimate interest of Makro Labelling Srl. Right to restriction of processing: the right to obtain from the controller the limitation to the processing, in cases where the accuracy of personal data is contested (for the period necessary for Makro Labelling Srl to verify the accuracy of said personal data), if the processing is illegal and the Data Subject has objected to the processing, if the personal data are necessary for the Data Subject to ascertain, exercise or defend a right in court, if the Data Subject has objected to the processing, pending the verification of whether the legitimate grounds of the controller override those of the data subject. Right to data portability: where applicable, the right to receive the personal data in a structured, commonly used and machine-readable format and the right to transmit those data to another controller, only in cases in which the processing is based on consent and the processing of the data is carried out by electronic means.
The right to lodge a complaint with a supervisory authority: without prejudice to any other administrative or judicial remedy, if the Data Subject considers that the processing of his/her personal data infringes the GDPR, he/she has the right to lodge a complaint with a supervisory authority. For the purpose of exercising the rights provided for by the GDPR, the Data Subject may:
- forward his/her requests to Makro Labelling Srl by email at the address: firstname.lastname@example.org
- write to the Controller at the following address: Makro Labelling Srl – Privacy Office – Via Giovanna dell’Arco 9, 46044 Goito (MN – Italy)
Furthermore, should you believe that the processing of your Personal Data violates the Privacy Laws, you can lodge a complaint with the Italian Data Protection Authority.
Policy update: We invite you to periodically check the section of the Website within which this Policy is hosted, and to consult the text of the most recent Policy which is effective only with reference to this website, which can be reached at www.makrolabelling.it, but not for other and different portals or websites which may possibly be consulted through the links available or by web-sharing tools for which the Controller is in no way responsible. For more information on the processing of personal data that these websites carry out, we recommend that you consult their privacy policies.
The Controller uses social buttons on the Website, i.e. direct connection links with Social Network platforms (Facebook, Instagram, LinkedIn) configured in each single « button ». By clicking on these links you will have the opportunity to interact directly with the Controller’s social network accounts. The providers of the Social Networks to which the buttons refer are independent controllers. More information on the individual privacy policies of the Social Network platforms and on the methods of management and deactivation of the relative cookies can be found on the reference Social Network platforms