The data provided to Xilopan S.p.a. in connection with the establishment of the contractual relationship with the same Xilopan S.p.a. and/or through the website that can be reached at www.xilopan.com (hereinafter “Site”) when registering to the Site and/or for the use of the services provided from time to time by Xilopan S.p.a., including those accessible in the restricted area of the Site (hereinafter the “Services”) will be processed in compliance with the provisions on the protection of personal data. Xilopan S.p.a. informs the user/customer of the following.
- Data controller
1.1 The Data Controller of personal data is Xilopan S.p.a. (hereinafter “Xilopan” or Data Controller”), with registered office in Loc. San Giuseppe,1\3 27040 Cigognola (PV).
- Nature of data processed and purpose of processing
2.1. Personal data are processed, where personal data means any information relating to a natural person, identified or identifiable even indirectly by reference to any other information. The data being processed are:
- (a) the data provided to the Data Controller in connection with the contractual relationship with Xilopan;
- (b) the data provided when requesting the provision of the Service, such as, for example, first and last name, e-mail address, residence or home address, tax code, telephone, fax, bank details, IP address;
- c) the data provided for the purpose of sending one’s application for job positions offered by Xilopan itself through the appropriate section of the Site, such as personal data (first name, last name, gender, date of birth, nationality, postal address, telephone number, e-mail), data related to the user’s education, professional experience, computer and language skills;
- d) data those conferred by the user during other contacts with the Holder (first name, last name, e-mail address, professional position);
- (e) data collected by Xilopan while browsing the Site, such as IP address, information acquired through cookies.
2.2 The processing of personal data of the user/customer, has the following purposes:
- a) for the performance and continuation of the contractual relationship existing with Xilopan, for example, to enable the management of the contractual services requested, the invoicing of the services provided, as well as for the fulfillment of the obligations required by law, regulation or EU legislation and for the exercise of its rights in court; b) for sending, via e-mail and hard copy mail of the user/customer, business proposals related and/or connected to the Services of Xilopan, for sending advertising material related exclusively to the aforementioned products or services, the Xilopan newsletter-newsletter, invitations to conferences, information related to the field of intellectual property, communications related to market opportunities related to the management of intangible assets (such as trademarks, patents, models) and/or for carrying out market research.
- Mandatory/optional nature of providing data
3.1 The provision of data requested at the time of the establishment of the contractual relationship with Xilopan and/or at the time of registration on the Site or activation of the Services for the purposes referred to in section 2.2a above, is mandatory, as it is strictly functional to the performance of the contractual services, the Services themselves and for the execution of legal obligations. Any refusal to provide the data will result in Xilopan being unable to fulfill its contractual services, to complete the registration process on the Site and/or thus to provide the Services.
3.2 The user/customer may at any time deny consent to the processing of data for the purposes mentioned in Section 2.2B above, either by using the opt-out system included in each communication or by sending an e-mail to firstname.lastname@example.org
3.2 The user/customer may at any time deny consent to the processing of data for the purposes mentioned in Section 2.2B above, either by using the opt-out system included in each communication or by sending an e-mail to email@example.com Therefore, the user/customer will, in any case, be able to take advantage of Xilopan’s benefits and Services.
- Method of treatment
4.1 User/customer data are collected electronically and or through physical media, when establishing the contractual relationship with Xilopan, registering on the Site, activating the Services, including by cross-referencing data or parts of data, as well as through the use of the e-mail service.
4.2 User/customer data will be processed by means of recording, consultation, communication, storage, and deletion operations, carried out with the help of electronic and manual means, ensuring the use of appropriate measures for the security of the processed data and guaranteeing their confidentiality.
4.3 User/customer data, stored on electronic/magnetic/informatic media, are kept and archived on a server located in Italy; personal data stored on paper media will be kept in special registers and/or cards, the preservation of which will be implemented with storage in special containers, kept in special premises. Xilopan declares that the data stored on the server and/or in appropriate premises are protected against the risk of intrusion and unauthorized access, and that it has also taken appropriate security measures to ensure the integrity and availability of the data as well as the protection of the areas and premises relevant to their safekeeping and accessibility.
4.4 Personal data will be processed by collaborators and/or employees of Xilopan in a responsible capacity, or within the scope of their respective functions and in accordance with the instructions given by Xilopan. The list of responsible parties is available upon request from the data subject.
- Disclosure of personal data
5.1 The personal data in question may be disclosed to specific parties, for the execution of the contractual relationship with Xilopan, for the performance of the Services requested and for the fulfillment of regulatory obligations. The data processed will not be subject to dissemination.
- Rights of the data subject
6.1 The data subject has the right to obtain, at any time, confirmation of the presence of his/her personal data, and the purposes for which the data are processed. The data subject also has the right to request that the data be updated, corrected, deleted or blocked and to object to its processing in whole or in part.
6.2 The data subject’s privacy rights are outlined below. In particular:
6.2.1 The data subject has the right to obtain confirmation as to whether or not personal data concerning him or her are being processed, and to obtain access to the personal data and the following information.
6.2.2 The data subject has the right to obtain the indication:
- (a) of the origin of personal data;
- (b) of the purposes and methods of processing;
- (c) of the logic applied in the case of processing carried out with the aid of electronic instruments;
- (d) the identification details of the data controller, as well as the data controller’s manager and representative if any;
- e) of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, managers or appointees.
6.2.3 The data subject has the right to obtain:
- (a) updating, rectification or, when interested, supplementation of data;
- b) the deletion of personal data without undue delay, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
- (c) certification that the transactions referred to in the preceding paragraphs. a) e (b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where this proves impossible or involves the use of means manifestly disproportionate to the right protected.
6.2.4 The data subject has the right to object, in whole or in part:
- (a) for legitimate reasons for the processing of personal data concerning him/her, as well as relevant to the purpose of collection;
- b) to the processing of personal data concerning him/her for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.
6.2.5 The data subject also has the right:
- (a) to file a complaint with a supervisory authority (Privacy Guarantor);
- (b) to receive in a commonly used and easily readable format the personal data concerning him or her provided to Xilopan and has the right to transmit such data to another data controller without hindrance;
- (c) to obtain from the data controller a restriction of processing operations.
6.3 In order to exercise the above rights, as well as to receive information regarding the parties to whom the data are communicated or the parties who, also in their capacity as data processors, may become aware of the data, the interested party may contact Xilopan by sending a request to the latter using the contact details indicated above.
- Duration of treatment
7.1 The processing of personal data with reference to the purpose referred to in section 2.2.A will have a duration equal to that of the contractual relationship established with Xilopan, to which must be added the additional period (10 years) provided for in compliance with the civil, tax and fiscal obligations in force.
7.2 The processing of personal data with reference to the purpose set forth in Section 2.2.B will have a duration of 24 months starting from the date of giving consent.
7.3 At the end of the data processing period, the data should be deleted, or permanently anonymized.
- Legal basis for processing
8.1 The legal basis for processing is the contractual relationship, the legitimate interest of the Data Controller and the provisions of the law.
- Transfer abroad
10.1 The data subject’s personal data will not be transferred to countries outside the EU.