I – INFORMATION ABOUT THE WEBSITE PRIVACY POLICY

1. This section contains information about the procedures adopted by Infermentum S.r.l. (hereinafter “Infermentum”, the “Owner” or the “Company”) in relation to the processing of personal data collected via the website www.infermentum.it (hereinafter the “Website”).
2. Detailed information notes about the processing of personal data are show when arriving at the Website and prior to the processing of personal data. This Policy defines the limits and methods of the processing of personal data for each service; where requested by specific legislation, the User will be placed in the condition to freely express consensus and eventually authorise the collection of information and its successive processing.
3. Unless otherwise specified, this Privacy Policy is also valid as an information note – pursuant to art. 13 of European Regulation n. 2016/679 (hereinafter the “GDPR”), relative to the protection of physical persons in relation to the processing of their personal data and the free circulation of this information – provided to anyone who interacts with the website www.infermentum.it (hereinafter the ’“User”).
4. This Policy is provided solely for the website www.infermentum.it and is not applicable to other website eventually consulted by the User.

 
II – DATA CONTROLLER. DATA PROCESSOR.

1. The Data Controller is Infermentum S.r.l., legally headquartered in Italy, Grezzana – fraz. Stallavena (VR) in Via N. Copernico 38, tel. +39 338 7025550, email privacy@infermentum.it.
2. Personal data is internally processed by the Data Controller’s organisation by authorised subjects and under the Data Controller’s responsibility for the purposes described herein.
3. Personal data can therefore be processed by external Data Processors who have stipulated specific agreements, conventions, protocols of understanding or contracts with the Data Controller to offer services that require the processing of the User’s personal data on behalf of the Data Controller. The external Data Processor is distinct from the Data Controller, and capable of ensuring the full respect of regulations governing the processing of personal data and the protection of the rights of the Interested Party.
4. To fulfil its role, the Data Controller works with subjects who present sufficient guarantees of specialised knowledge, trustworthiness and resources, to implement the technical and organisational measures necessary to satisfy the requisites of European Regulation 2016/679, and that all decisions respect applicable legislation.

 
III – TYPOLOGY OF DATA PROCESSED, PURPOSES AND REGULATIONS

1. During basic navigation of the Website the following personal data will be automatically gathered and processed:

1. the User’s navigation data (internet protocol (IP) address; type of browser and parameters of the device used to connect to the Website; name of the Internet Service Provider – so-called ISP; date and hour of the visit to the Website; the User’s arrival and departure website; possibly the number of clicks etc.).

2. Via the Website, what is more, personal data voluntarily provided by the User may be processed as specified below:

1. Requests for information. This processing regards the User’s email address and related navigation information and only eventually his or her name and telephone number. The processing of this information will serve to respond to the User’s request and, therefore, the legal basis for processing this information is the adoption of pre-contractual measures at the request of the User.

2. Newsletter and marketing. Requests will be made for an email address (mandatory), first and last name and province of residency (optional) and, in any case, navigation data will also be processed. The User’s information will therefore be processed for marketing purposes to periodically inform the User through commercial communications about products, events, promotional campaigns and services organised by the Data Controller, sent via email. The request for information relative to the User’s Province is related to the sending of commercial communications relative to events scheduled in the User’s area or related to it. The legal basis for this processing is the informed and free consensus provided by the User.
3. Registration to access e-commerce functions offered by the Website. To purchase products on the Website, the User must register by compiling a registration form that requires the User provide a first and last name, telephone number, country, province, shipping address (solely for the shipping of purchased products to this address), email address and password. This operation serves to create an account to access the reserved part of the Website that, other than the information provided during registration, also includes information about orders. The legal basis for this processing is the adoption of pre-contractual measures requested by the User.
4. Purchase of products and post-sales assistance. In the event of purchases by the User, personal data processed will include data provided during registration and eventually information relative to methods of payment. At the moment of purchase, the User can choose to personally pick-up the goods directly from the Company or request they be shipped to another physical address. In addition, the User may also request a commercial invoice; in this case, at the time of purchase the User must provide a physical shipping address and invoicing data. Once the sale has been perfected, information provided may be used by the Data Controller to proceed with requests for assistance or goods return and eventual reimbursements in favour of the Client. The legal basis for this treatment is the fulfilment of the contract to which the User is a party; additionally, some information may be processed after the sale is legitimised to guarantee that the Company respects its legal obligations (e.g. accounting and fiscal obligations) pursuant to art. 6, comma I letter C) of the GDPR.
5. Shipping of products to third parties and post-sales assistance. At the time of purchase it is possible to request the shipping or delivery of products to a third party recipient using the “Gift” function. In this case, data about this party provided by the User will also be collected, as required to proceed with this service and to ensure that the shipment or delivery is successful. Specifically, this information consists of the first and last name, address and telephone number of the recipient, used to inform the recipient of the delivery and complete the delivery itself.

The legal basis for this treatment is the legitimate interest of the Data Controller, in other words the legitimate interest to execute a contract with a third party to which the User is not party. This interest is suitably balanced with the rights of the User.
 
IV – COOKIE POLICY

1. The Website uses cookies. Cookies are small text files sent to the User’s terminal, where they are memorised, in order to be re-transmitted back to the Website during a successive visit.
2. There are various typologies of cookies:

1. Technical cookies: cookies necessary for the functioning of the Website or some of its parts or functions or cookies that serve to improve the User’s experience. There are numerous technologies employed to conserve data on the User’s computer, which are then collected by different websites. Among them, the most familiar and commonly used are known as HTML cookies. They are functional to online navigation and to facilitate access to and use of the Website by the User. They are necessary for the transmission of communications via electronic networks, or more precisely, for the provider to offer the services requested by the Client.
2. The User can manage or request the general deactivation or cancelation of cookies by modifying the settings of the Internet browser used. This deactivation may slow or impede access to some parts of the Website.

The use of technical cookies ensures the safe and efficient use of the Website and for this reason no consent is requested from the User.
Cookies inserted in a browser and retransmitted via Google Analytics, via the statistical services of bloggers or similar, are considered technical only when used to optimise the site directly by the Data Controller of the Website itself, which may collect data in aggregate form about the number of users and methods used when visiting the Website.
Under these conditions analytical cookies are subject to the same rules in relation to data processing and consensus as technical cookies.
With regards to duration, cookies can be either temporary session cookies (automatically cancelled at the end of a navigation session when a browser is closed and used to identify the User, avoiding the need to log in to each page visited) or persistent cookies (that remain active on a personal computer until they expire or are cancelled by the User).
Session cookies may be installed to consent access and permanence in the restricted area of the Website as an authenticated user and without the need to request consensus when necessary to correctly provide navigation services.
These cookies do not require prior consensus from the User, in accordance with art. 22 of Regulation (EU) 2016/679.

3. Third-party cookies: cookies characterised by their origin, as they are not sent by the website www.infermentum.it but by a different third party site (proprietary cookies installed directly by the owner and/or controller of the website). They tend to be tracking cookies whose purpose is to track online behaviour, understand interests and, consequentially, to offer users personalised advertising. The use of these cookies is disciplined by the aforementioned third parties, who must provide indications for managing and eventually disabling these cookies via their own website.

Installation of this typology of cookie requires the User’s consensus.

4. Profiling cookies: cookies designed to create a user profile to provide targeted marketing and specific marketing activities for the User.

Use of these cookies requires the User’s consensus in accordance with art. 22 of Regulation (EU) 2016/679.

3. In particular, the cookies utilised on the website www.infermentum.it belong to the following typologies:

• navigation or session cookies, that guarantee the normal navigation and fruition of the Website and to anonymously gather data about how users utilise the site and the number of visitors to the site, where they arrive from and other sites they have visited. As they are not memorised on the user’s computer, they are cancelled when the browser is closed;
• analytical cookies, such as, for example, those utilised by Google Analytics, used to gather and analyse statistical information, via computer and other devices, about the number of users of the Website, or the number of clicks made on the page during navigation, or the site from which users arrive and the pages visited.

4. The Website utilises exclusively the proprietary technical and third-party analytics cookies listed below:

 

5. The Website uses a cookiebot system that consents the User to express his/her consensus regarding the use of unnecessary cookies and to disable those that are necessary, once again with the consequence of possible improper functioning of the Website or parts thereof. Each unnecessary cookie is accompanied by a link to relative information about how personal data is processed and methods for eventually disabling these cookies. With regard to third-party cookies, the sole obligation of the Data Controller is to provide a link to the third-party’s website in this Privacy Policy. Instead, this subject is responsible for providing information and indications about the means for eventually granting consensus to the use and/or disabling of its cookies.
6. Cookies can be disabled by the User by controlling and/or modifying browser preferences following the instructions provided by relative suppliers using the links listed below.

∙ Internet Explorer
∙ Mozilla Firefox
∙ Google Chrome
∙ Apple Safari

7. The Website also incorporates plugins and/or buttons to consent the agile sharing of content on social networks preferred by the User. When the User visits a page on the Website that contains a plugin, the User’s browser connects directly to the server of the social network that loads the plugin; this server can track the visit to our Website and, eventually, associate this visit with the User’s social network account, in particular when the User is connected at the time of the visit or has recently navigated on a website containing social network plugins. If the User does not wish the social network to register data about the visit to our Website, it is necessary to logout of the social network account and, in all probability, eliminate cookies installed by the social network in the User’s browser.

This website features plugins with advanced functions for the protection of User privacy that do not send cookies or access cookies present in the User’s browser when the page is opened but only after clicking on the plugin.
The collection and use of data by third parties are regulated by their respective Privacy Policies, which we ask you to reference.
 
V – TRANSFER OF INFORMATION TO THIRD COUNTRIES

1. The Data Controller does not transfer personal data al outside the boundaries of the European Union.

 
VI – SUPPLY OF INFORMATION AND CONSEQUENCES OF FAILURE TO SUPPLY INFORMATION

1. The provision of personal data is always facultative and the only consequence of the failure to provide this data is the impossibility for the Data Controller to manage and respond to the User’s requests, to send commercial communications, and to carry out the activities for which the data was requested.
2. When data is requested to fulfil the contract to which the User is a party, or for pre-contractual measures, failure to provide this data will impede the provision of the service and any related activities.

 
VII – RECIPIENTS OR CATEGORIES OF RECIPIENTS

1. Personal data can be made accessible, brought to the attention of or communicated to the following subjects, who will be named, according to each specific case, as processors or authorised subjects:

• employees and/or collaborators, under any title, of the Data Controller as authorised subjects;
• public or private subjects, physical or legal persons, whose services the Data Controller uses to carry out activities instrumental to the purposes described above, or to whom the Data Controller is obliged to communicate personal data, in force of legal or contractual obligations.

2. In no case will personal data be divulged.

 
VIII – PERIOD OF CONSERVATION

1. Data will be conserved for the period of time necessary to execute the contract perfected on the Website and the successive maximum time equivalent to the period for the prescription of actionable rights by the Data Controller, as well as the time necessary to fulfil legal obligations in matters of conservation of fiscal and accounting documents. In the event of claims, data will be conserved until such claims have been resolved.
2. In the event of the processing of data in occasion of a response to requests for information by the User, data will be conserved for 2 years from the date of response, unless, following this response, a contract is not perfected with the User, in which case the period of conservation is as determined under point 1.
3. In the event of processing for purposes of marketing and newsletters, data will be conserved for the entire period during which the User intends to make use of the service and until the User requests cancelation of this data, which is possible at any moment.

 
IX – RIGHT TO ACCESS, CANCELATION, LIMITATION AND PORTABILITY

1. Interested parties benefit from the rights listed in articles 15 to 20 of the GDPR.

For example, interested parties may:

• obtain confirmation that their personal data is or is not being processed;
• in the event personal data is being processed, obtain access to this data and information relative to its processing and request a copy of this personal data;
• obtain the correction of inexact personal data and integration of incomplete personal data;
• obtain the cancellation of their personal data when any of the conditions foreseen in art. 17 of the GDPR subsist;
• obtain a limit on the processing of their data in the cases foreseen in art. 18 of the GDPR;
• receive their personal data in a common structured format, legible by automatic devices and request their transmission to another Data Controller, if technically feasible.

 
X – RIGHT TO OPPOSE

1. Any interested party has the right at any moment to oppose the processing of personal data for a legitimate interest of the Data Controller. In the event of opposition, personal data will no longer be processed, as long as there are no legitimate reasons to proceed with the processing of this data that prevail over the interests, rights and liberties of the User, or in order to ascertain, exercise or defend a right in a court of law.

 
XI – RIGHT TO REVOKE CONSENSUS

1. When consensus is requested for processing personal data, any interested party may also revoke at any moment consensus granted previously, without prejudice to the lawfulness of processing based on consensus granted prior to revocation. Consensus may be revoked by sending an email to: privacy@infermentum.it.

 
XII – RIGHT TO OPPOSE OR REVOKE CONSENSUS TO THE PROCESSING OF DATA FOR MARKETING PURPOSES

1. With reference to the processing of personal data for purposes of marketing, each interested party may at any moment revoke consensus eventually granted, or oppose their processing by sending an email to: privacy@infermentum.it. Opposition to processing exercised in this manner extends also to the sending of commercial communications via regular post or telephone calls, with the exception of the possibility to exercise this right in part, for example opposing solely the processing of data using automated methods of communication.

 
XIII – RIGHT TO PRESENT CLAIMS TO THE DATA PROTECTION AUTHORITY

1. Any interested party may forward a claim to Italian Data Protection Authority in the event he or she believes that his or her rights have been violated in accordance with the GDPR. Claims are to be made as indicated on the website of the Italian Data Protection Authority: www.garanteprivacy.it.

XIV – UPDATES

1. This Privacy Policy is subject to updates. Therefore, the Data Controller invites Users interested in understanding how personal data collected by the Website is processed to periodically visit this page.

 
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LEGAL NOTES
I – INFORMATION ABOUT THE OWNER

1. Infermentum S.r.l.
2. Legal address: Via Copernico 38 – 37023 Grezzana (VR), Italy
3. Business capital: €50,000.00
4. REA N.: VR411438
5. Tax – VAT – Verona Business Reg. n.: 04332780230

 
II - COPYRIGHT AND BRANDS

1. The website www.infermentum.it (the "Website") is the property of Infermentum S.r.l. ("Infermentum").
2. The name Infermentum, the names of Infermentum’s products and promotions presented on the pages of the Website (including relative logotypes) and all other distinctive signs, whether denominative, or figurative and related slogans, including packaging, are the exclusive property of Infermentum S.r.l. and in many cases the object of registration and related exclusive right; any use or reproduction of this material for any purpose or using any means is expressly and strictly forbidden and will be prosecuted by Infermentum S.r.l. to the fullest extent of the law.
3. The brands, logos and characters of third parties reproduced on the Website are the exclusive property of their respective owners, who have authorised their use: any reproduction is prohibited.
4. The web pages that make up the Website, and their content (including, for example: texts, images, graphics, audio), are protected by copyright held by Infermentum S.r.l. or include material whose use has been properly authorised; therefore, any reproduction, duplication, publication or transmission (in whole or in part) in any form or via any means is strictly prohibited.
5. No reproduction of the Website or its parts may be the object of sale or distribution for commercial purposes.
6. The downloading of material present on the Website is legal solely when expressly and specifically authorised on the web page; this authorisation regards exclusively the use of downloaded material for personal and non-commercial reasons, and any other form of use remains strictly prohibited. Nothing on the Website may be interpreted as express or tacit licence permitting third parties to make use of the Infermentum Brand, texts, images, graphics or audio and any other element subject to sole right as per the previous paragraphs.
7. Infermentum S.r.l. operates with the maximum possible diligence to select and update the content of its website; in any case, Infermentum S.r.l. declines any responsibility for eventual missing or incomplete information or errors of any nature.
8. Infermentum S.r.l. also declines any responsibility for eventual damages to Users and their property following access to the Website, the impossibility to access the Website or from downloading material present on the Website where consented, including damages to the User’s devices caused by viruses.