PURPOSES AND PRINCIPLES OF DATA PROCESSING
In compliance with the relevant legal obligations (Legislative Decree 196/2003 and the EU General Data Protection Regulation no. 2016/679, so-called “GDPR”), this section describes the management procedures of the website www.frostitaly.it (“Site”) in relation to the processing of personal data of Users who browse it and interact with the remotely accessible web services.
We inform you that FROST ITALY S.R.L. shall use your personal data to manage the access to the portal and to the services included in it; the technical operation; to carry out all necessary or useful activities for the constant improvement of the provided service and to determine the responsibility in the event of crimes against the Site and/or illegal acts committed through the Site; and for marketing purposes.
Specific additional purposes relating to any particular data processing can be identified in detail through supplementary information within the various services included in the portal.
Browsing the Site may involve the processing of data relating to identified or identifiable persons. The personal data provided by Users who browse the Site are processed by the recipient of the communication for the sole purpose of following up on the requests received.

DATA CONTROLLER
The data controller is FROST ITALY S.R.L., in the person of (Dr. Elisa Pistillo).
Before communicating 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 guarantee their confidentiality in full compliance with the Applicable Law.

TYPES OF DATA PROCESSED
By filling in the forms available on the website www.frostitaly.it and by sending e-mails, no “special” personal data is acquired (enabling disclosure of racial and 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 enabling disclosure of health status and sexual orientation) nor “judicial” data (criminal record data, or regarding the status of accused or person under investigation, etc.).
The data that shall be acquired and processed can be of three general categories: (i) browsing data; (ii) data provided in active form by the data subject and (iii) data collected from third parties.

(i) Browsing data
The IT systems and the software procedures used to operate the Site may acquire during their normal operation some information that can be classified as “personal data”.
These include the hardware model, the operating system and its version, information about the mobile network and the country from which the login is made, the time of the request, the method used to submit the request to the server, the time of access, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (successful, error, etc.), the details of the path followed within the web pages with particular reference to the pages visited and other parameters related to the operating system and the IT environment of the User (browser used, version, geographical location, last page visited before accessing the services of the FROST ITALY S.R.L. Site).
These data are processed for the sole purpose of obtaining statistical information in aggregate and anonymous form on the usage of the site, to better understand the User’s browsing behavior in order to offer better and more efficient browsing experience; as well as to enable the technical features of the Site, to control and optimize its functionality, to improve the quality of the services offered by the Site, as well as to guarantee the maintenance of the related database and of the supporting IT infrastructure.
These browsing data shall be deleted within 24 months from the date of acquisition after the aforementioned processing in anonymous form.
The browsing data (especially the data regarding the pages of the Site visited by the User and the browsing time) may also be used together with the User’s personal data (e.g. name, surname, e-mail) to identify the most appropriate contact methods that FROST ITALY S.R.L. may use for marketing purposes.
The browsing data can also be used to determine responsibility in case of crimes against the Site or carried out through the Site (attempts of malware, spamming, unauthorized access to IT systems, etc.) and in this case FROST ITALY S.R.L. shall save data for as long as necessary to protect its own and/or third party rights.

(ii) Data voluntarily provided by the user
These data include:

  • information sent voluntarily by Users to the addresses indicated on the Site;
  • the personal data provided by Users to use the services accessible on the Site or to participate in initiatives promoted through the Site;
  • the personal data provided by Users who subscribe to newsletters and/or information material personal data provided by Users sending job applications (“curriculum vitae”, etc.); the data acquired through the Users’ requests for quotations.

(iii) Data collected from third parties
FROST ITALY S.R.L. may acquire some data concerning the data subject from third parties.
This acquisition may be done through commercial agents, training institutions, professional associations and/or other partners on the occasion of training events, as well as through web portals dedicated to the related business sector.
The data processing shall be carried out, with or without the aid of electronic tools, according to principles of correctness, lawfulness, transparency, in order to protect the privacy and rights of the data subject at all times, in accordance with the provisions of current legislation.

PURPOSE OF THE PROCESSING AND LEGAL BASIS
The acquired data shall be processed in order to execute the User’s requests related to the sending of information material or clarifications, to allow Users to register on the site and access services and/or purchase products/services, or to perform the service or supply the product requested by the User and to organize all the management and production activities (including relations with the suppliers) related to the aforementioned supply, as well as to fulfill the obligations required by law, regulations and/or EU legislation.
Only with the prior specific consent of the User, expressed through the acceptance of this policy, the acquired data shall also be used for direct marketing activities (market research, sending of commercial and promotional communications, newsletters, through any automated communication method: ordinary mail, e-mail, call center, text messages, chat messages, social networks, etc.).
This consent is to be understood as unique and inclusive of all possible processing methods used for marketing purposes (electronic/telematic, paper), as well as for all possible direct marketing purposes.
Finally, without having to acquire express consent, FROST ITALY S.R.L. may use the e-mail address provided by the User in the context of a previous purchase, to send via e-mail, any commercial communications and sales offers, as long as related to products and services similar to those already purchased.
Pursuant to art. 13, paragraph I, c) of the GDPR, the legal basis of the processing is the User’s wish.

PLACE OF DATA PROCESSING
The data processing related to the web services of this site is carried out at the headquarters of FROST ITALY S.R.L. in via Lago Trasimeno 46, 36015 Schio.

PROCESSING METHODS
The processing of personal data will occur in accordance with the art. 4, no. 2) GDPR and particularly: acquisition, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, erasure and destruction of data.
Your personal data are subjected to both paper and electronic and/or automated processing.
The Data Controller will process the personal data for the time required to fulfill the aforementioned purposes and in any case for a period not exceeding 10 years from the termination of the relationship for the service provision purposes and not exceeding 24 months from the collection of the data for marketing purposes.

COMMUNICATION AND DISSEMINATION OF DATA
Personal data voluntarily sent to the site www.frostitaly.it by filling in forms or by sending emails are disclosed to third parties only if strictly necessary in order to manage the requests.
The hosting service provider may potentially have access to the data exclusively for technical necessity and urgency, which require intervention to avoid loss of functionality and security. The browsing data are not disclosed or communicated to external parties.

PROFILING
The data controller does not use automated processes aimed at profiling.

DATA STORAGE
The personal data processed for the aforementioned purposes shall be stored for the duration of the contract and further for the entire period they must be stored by the Data Controller for tax purposes or for other purposes, as required by law or regulation.

COOKIE POLICY
Cookies are short strings of information (text files) regarding the User’s activity on the Website, which are stored, during the first browsing on the Website, on the user device (computer, smartphone or tablet), and retransmitted to the same sites at the same user’s next visit, allowing the Site to automatically recognize the User (or other users who use the same tool) and to improve the user experience. Their functionality depends totally on the user’s browser and can be enabled or disabled by the User himself.
The Site uses Google Analytics cookies.
Google Analytics is a web analysis service provided by Google Inc., for the purpose of visit timing, counting and browsing statistics.
Through Google Analytics features no strictly personal data is acquired but data on the age, gender, and visitor preferences are acquired in aggregate statistical form (in order to better evaluate the use of the Website and the activities carried out by the visitors and to re-target the services provided).
Information on Google Analytics cookies:
https://policies.google.com/technologies and https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

RIGHTS OF THE DATA SUBJECT
The following rights are granted to the User by the GDPR (art. 15-22) among others:

  • to request the access to your personal data and related information; the correction of inaccurate data or the completion of incomplete ones; the erasure of your personal data (upon the occurrence of one of the conditions indicated in art. 17, paragraph 1 of the GDPR and in compliance with the exceptions included in paragraph 3 of the same article); the limitation of your personal data processing (in the event of the possibilities indicated in art. 18, paragraph 1 of the GDPR);
  • to request and obtain – in case the legal basis of processing is a contract or consent, and the processing is performed by automated methods – your personal data in a structured and readable format by an automatic device, also in order to communicate such data to another data controller (so-called right to personal data portability);
  • to oppose at any time to the processing of your personal data in the event of particular situations concerning you;
  • to withdraw the consent at any time, in case in which the processing is based on your consent for one or more specific purposes and concerns common personal data (for example date and place of birth or place of residence), or special categories of data ( e.g. data revealing your racial origin, political views, religious beliefs, health status or sexual orientation). The processing based on consent and carried out prior to its revocation, however, maintains its lawfulness;
  • to lodge a complaint with a supervisory authority (Personal data protection authority – http://www.garanteprivacy.it/).
    Le eventuali richieste a riguardo devono essere rivolte a (FROST ITALY S.R.L.), in qualità di Titolare del trattamento dei dati.

    • POLICY MODIFICATION
    The conditions of this Notice may change from time to time. Any substantial changes to this Notice will be published through an appropriate communication on this website or by contacting the User through other channels.