Ponzi S.p.A., with registered office in Corso Monforte, 9, 20122.
Contact details of Data Protection Officer of the Ponzi Group: email@example.com (Art. 38 GDPR)
Ponzi informs you that the personal data provided by you or in any case acquired at the same time as the request for information and/or contact, registration on the Website and use of the services via smartphone or any other device used to access the Internet, therein including browsing data and data used for the purchase of services offered by Ponzi, also via websites of the Ponzi Group companies, will be processed in respect of applicable data protection regulations, with particular reference to Regulation (EU) 679/2016 on Data Protection (“GDPR”) and the national adjustment legislation in force.
The IT systems and software procedures used for the Website functioning acquire, during their normal exercise, some personal data whose transmission, based upon the TCP/IP protocol, is implicit in the use of the Internet.
This is information that is not collected to be associated with identified data subjects but that, by its very nature, may - through processing and association with data held by third parties - allow for users to be identified.
This category of data includes "IP addresses" or domain names of computers used by users who connect to the website, addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the web server, the size of the file obtained in response, the numerical code indicating the status of the response given by the web server (successful, error, etc.) and other parameters relating to the operating system and computer environment of the user.
You may be asked to provide your personal data (e.g. personal details, bank details) to allow Ponzi to provide the requested services. In addition, the use of some functions of the Website, the sending of email communications, the spontaneous compilation of contact forms, as well as contacts via the free-phone number, may involve the processing of your additional personal data in order to follow up on the request for information and/or to send documentation, pamphlets or informative leaflets which provide a comprehensive picture of the products and services offered by Ponzi and by other Group companies. Specific detailed information may be reported or displayed on the website pages focusing on particular services.
Cookies stored on your computer cannot be used to obtain any data from your hard disk, to send computer viruses or to identify and use your e-mail. Each cookie is unique in relation to the browser and device used by you to access the Ponzi Website. In general, the purpose of cookies is to improve the website functioning and user experience in using the same, although cookies can be used to send advertising messages (as specified below). For further information on what cookies are and on how they function, consult the website “All about cookies” http://www.allaboutcookies.org.
Your personal data will be processed to provide you with the requested service, meaning access, browsing and provision of the Website contents. Additional processing other than that just indicated may also be based upon the execution of contractual relationships of which you are part, or to fulfil pre-contractual measures involved in the same. In addition, if necessary in accordance with the GDPR, your data will be processed based upon your free and express consent, for one or more given purposes.
Subject to the legal bases just identified, your data will be processed within the limits of what is strictly necessary to pursue the following purposes:
To carry out the activities highlighted above, the personal data may become known by personnel instructed by Ponzi, within its structures, in charge of the services and web services, and will be processed also by way of computerised procedures and electronic communication systems, protected by suitable security and confidentiality measures, as well as methods and logics coherent with the pursued purposes and for the storage times strictly necessary to fulfil the contractual and legal obligations.
In particular, in the website sections focusing on particular services, if your personal data is requested, the data will be encrypted by way of security technology known as Secure Sockets Layer, abbreviated to SSL. SSL technology codifies the information before it is exchanged via the Internet between your computer and Ponzi's central systems, making it incomprehensible to unauthorised parties and thereby guaranteeing the confidentiality of the information sent.
To pursue the purposes indicated above, your data may be transferred in Italy and abroad, even outside the European Economic Space if this is necessary to pursue the cited purposes. In that case, the data recipients will be subjected to obligations of protection and security equivalent to those guaranteed by the Controller. In any case, only data necessary to pursue the set purposes will be communicated and the guarantees applicable to the transfer of data to third countries will be applied, where necessary. In addition to the Ponzi Group companies, associates, subsidiaries and/or parent companies, we may also communicate your personal data to our providers of commercial services, for marketing reasons, appointed for that purpose as external processors. In addition, the personal data may be communicated to the competent public bodies and authorities for requirements of fulfilling regulatory obligations or for ascertaining liability in the case of computer crimes in detriment to the website, as well as being communicated to third parties which provide IT and electronic services (e.g. hosting services, website management and development) and used by Ponzi for carrying out duties and activities even of technical and organisational nature, instrumental to the Website functioning. The entities belonging to the categories cited above may act as autonomous data controllers or, when necessary, as processors duly appointed by Ponzi.
The personal data may also become known by Ponzi employees/consultants specifically appointed as processors or officers.
The updated list of Processors can be consulted by sending a request to Ponzi at the contact details indicated above.
You may exercise at any time the rights recognised by the personal data protection regulations, including that of:
For processing based upon your consent, you may withdraw consent at any time. In any case, the withdrawal of consent will not prejudice the lawfulness of the processing carried out until that time.
To exercise your rights, contact the Data Protection Officer at the contact details indicated in the paragraph below.
Data Controller, in accordance with existing regulations, is Ponzi S.p.A., based in Milano, Corso Monforte, 9, 20122.
To contact the Data Protection Officer, write to:
FAO Data Protection Officer
Corso Monforte, 9
E-mail address: firstname.lastname@example.org
This document will be subject to updates (the various versions of the same will in any case be available). You are therefore invited to visit this section of our website periodically to view any changes or additions.