Purposes and Principles of Data Processing
In compliance with the legal obligations on this matter (Legislative Decree 196/2003 and European Regulation No. 679/2016, the so-called “GDPR”), this section describes how the website www.frostitaly.com (“Website”) is managed with reference to the processing of the personal data of Users who browse it and interact with the web services accessible electronically. We inform you that FROST ITALY S.R.L. will use your personal data to manage access to the portal and the services included therein; technical procedures; to carry out all activities necessary or useful for the continuous improvement of the service provided and for the ascertainment of liability in the event of crimes against the Website and/or unlawful acts carried out through the Website, as well as for marketing purposes. Additional specific purposes relating to individual processing activities may be identified in detail, through supplementary notices, within the various services included in the portal. Browsing the Website may involve the processing of data relating to identified or identifiable persons. The personal data provided by Users who visit the Website are processed by the recipient of the communication solely for the purpose of responding to the requests received.

Data Controller
The Data Controller is FROST ITALY S.R.L., represented by Dr. Elisa Pistillo. Before providing any personal data, the Data Controller invites you to carefully read this Privacy Policy, as it contains important information on the protection of personal data and on the security measures adopted to ensure confidentiality in full compliance with the Applicable Legislation.

Types of Data Processed
Through the completion of the forms available on the website www.frostitaly.com and through the sending of emails, no “special” personal data are acquired, namely data capable of revealing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade-union nature, as well as personal data capable of revealing health status and sexual orientation. Nor are “judicial” data acquired, such as data relating to criminal records or concerning the status of defendant or suspect, etc. The data that may be acquired and processed may fall into three general categories: (i) browsing data; (ii) data actively provided by the data subject; and (iii) data collected from third parties.

(i) Browsing Data
The IT systems and software procedures used to operate the Website may acquire, during their normal operation, certain information that can be classified as “personal data.” These include hardware model, operating system and version, information on the mobile network and the country from which access is made, the time of the request, the method used to submit the request to the server, access time, size of the file obtained in response, numerical code indicating the status of the response given by the server (successful, error, etc.), details relating to the path followed within the web pages, with particular reference to the pages visited, and other parameters relating to the User’s operating system and IT environment, such as the browser used, version, geographical location, and the last page visited before accessing the services of the FROST ITALY S.R.L. Website. These data are processed solely to obtain statistical information in aggregated and anonymous form on the use of the Website, to better understand the User’s browsing behavior in order to offer better and more efficient browsing; to enable the technical functions of the Website; to monitor and optimize its operation; to improve the quality of the services offered by the Website; and to ensure the maintenance of the relevant database and supporting IT infrastructure. Such browsing data, after the above-mentioned processing in anonymous form, are deleted within 24 months from the date of collection. Browsing data, particularly data relating to the pages of the Website visited by the User and browsing times, may also be used together with the User’s personal data, such as name, surname, and email address, to identify the most appropriate methods of contact by FROST ITALY S.R.L. for marketing purposes. Browsing data may also be used to ascertain liability in the event of crimes against the Website or carried out through the Website, such as malware attempts, spamming, unauthorized access to IT systems, etc. In such cases, FROST ITALY S.R.L. will retain the data for the time necessary to protect its own rights and/or those of third parties.

(ii) Data Voluntarily Provided by the User
These data include:

• information voluntarily sent by Users to the addresses indicated on the Website;
• personal data provided by Users in order to use services accessible on the Website or to participate in initiatives promoted through the Website;
• personal data provided by Users who submit requests to receive news and/or information material; personal data provided by Users who submit job applications, such as curricula vitae, etc.; data acquired through quotation requests submitted by Users. information voluntarily sent by Users to the addresses indicated on the Website; personal data provided by Users in order to use services accessible on the Website or to participate in initiatives promoted through the Website; personal data provided by Users who submit requests to receive news and/or information material; personal data provided by Users who submit job applications, such as curricula vitae, etc.; data acquired through quotation requests submitted by Users.

(iii) Data Collected from Third Parties
FROST ITALY S.R.L. potrà raccogliere presso terzi alcuni dati relativi all’interessato.
(iii) Data Collected from Third Parties
FROST ITALY S.R.L. may collect certain data relating to the data subject from third parties. Such collection may take place through commercial agents, training institutions, professional associations and/or other partners during training events, as well as through web portals dedicated to the relevant product sector. Processing will be carried out, with or without the aid of electronic tools, according to principles of fairness, lawfulness and transparency, in such a way as to protect the confidentiality and rights of the data subject at all times, in accordance with the provisions of the legislation in force.
Il trattamento sarà effettuato, con o senza l’ausilio di strumenti elettronici, secondo principi di correttezza, liceità, trasparenza, in modo da tutelare in ogni momento la riservatezza e i diritti dell’interessato, in conformità a quanto previsto dalla normativa vigente.

Purposes of Processing and Legal Basis
The data acquired will be processed in order to respond to the User’s requests relating to the sending of information material or clarifications, to allow Users to register on the Website and access services and/or purchase products/services, or to perform the service or provide the product requested by the User and to organize all related management and production activities, including relationships with suppliers, as well as to comply with obligations established by law, regulations and/or EU legislation. Only with the User’s prior specific consent, expressed through acceptance of this Policy, will the data collected also be used for direct marketing activities, such as market research, sending commercial and promotional communications and newsletters, through any automated means of communication: ordinary mail, email, telephone with operator, SMS, chat messages, social networks, etc. Such consent is to be understood as unified and inclusive of all possible means used for processing for marketing purposes, whether electronic/telematic or paper-based, as well as for all possible direct marketing purposes. Lastly, without the need to obtain any express consent, FROST ITALY S.R.L. may use the email address provided by the User in connection with a previous purchase in order to send, by email, commercial communications and sales offers, provided that they relate to products and services similar to those already purchased. Pursuant to Article 13, paragraph 1, letter c) of the GDPR, the legal basis for processing is the User’s will.

Place of Data Processing
Processing connected with the web services of this Website takes place at the registered office of FROST ITALY S.R.L., located at Via Lago Trasimeno 46, 36015 Schio.
I trattamenti connessi ai servizi web di questo sito hanno luogo presso la Sede di FROST ITALY S.R.L. in via Lago Trasimeno 46, 36015 Schio.

Processing Methods
Personal data will be processed as indicated in Article 4, No. 2 of the GDPR, namely: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, erasure and destruction of data. Your personal data are processed both in paper form and electronically and/or by automated means. The Data Controller will process personal data for the time necessary to fulfill the purposes indicated above and, in any case, for a period not exceeding 10 years from the termination of the relationship for Service Purposes and not exceeding 24 months from data collection for Marketing Purposes.

Communication and Disclosure of Data
Personal data voluntarily sent to the website www.frostitaly.com through the completion of forms or the sending of emails are communicated to third parties only where strictly necessary for the management of the requests submitted. The hosting service provider may potentially access the data exclusively for technical reasons of necessity and urgency, where intervention is required in order not to compromise functionality and security. Browsing data are not disclosed or communicated to external parties.

Profiling
The Data Controller does not use automated processes aimed at profiling.

Data Retention
Personal data processed for the purposes indicated above will be retained for the duration of the contract and, subsequently, for the period during which the Data Controller is subject to retention obligations for tax purposes or for other purposes established by laws or regulations.

Cookie Policy
Cookies are short strings of information, namely text files, relating to the User’s activity on the Website, which are stored, during the first browsing session on the Website, on the device used by the User to browse the Internet, such as a computer, smartphone or tablet. They are then sent back to the same websites upon any subsequent visit by the same User, allowing the Website to automatically recognize the User, or other users using the same device, after the first visit and thereby improve the user experience. Their operation depends entirely on the browsing software used by the User and may be enabled or disabled by the User. The Website uses Google Analytics cookies. Google Analytics is a web analytics service provided by Google Inc. for history, visit-counting and browsing-statistics purposes. Through Google Analytics functions, no strictly personal information is collected; rather, only data in aggregated statistical form are collected regarding visitors’ age, gender and interest preferences, for the purpose of better assessing the use of the Website and the activities carried out by visitors and better directing the services provided. Google Analytics cookie policy: https://policies.google.com/technologies and https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Rights of the Data Subject
Among the rights granted to the User by the GDPR, Articles 15–22, are the rights to:

• • request access to your personal data and to the information relating to them; rectification of inaccurate data or completion of incomplete data; erasure of personal data concerning you, when one of the conditions set out in Article 17, paragraph 1 of the GDPR applies and in compliance with the exceptions provided for in paragraph 3 of the same article; restriction of the processing of your personal data, when one of the cases indicated in Article 18, paragraph 1 of the GDPR applies;
  • request and obtain, where the legal basis for processing is a contract or consent and the processing is carried out by automated means, your personal data in a structured, machine-readable format, also for the purpose of communicating such data to another data controller, the so-called right to data portability;
  • object at any time to the processing of your personal data where particular situations concerning you apply;
  • withdraw consent at any time, limited to cases in which processing is based on your consent for one or more specific purposes and concerns ordinary personal data, such as date and place of birth or place of residence, or special categories of data, such as data revealing racial origin, political opinions, religious beliefs, health status or sex life. Processing based on consent and carried out before its withdrawal shall, in any case, remain lawful;
  • lodge a complaint with a supervisory authority, namely the Italian Data Protection Authority — http://www.garanteprivacy.it/. Any requests in this regard must be addressed to FROST ITALY S.R.L., in its capacity as Data Controller.

Changes to the Policy
The terms of this Policy may change from time to time. Any substantial changes to this Policy will be published by means of appropriate notice on this Website or by contacting the User through other channels.