Privacy policy

Privacy Policy of Molino Naldoni

For us your privacy and the safety of your personal data are very important, for this reason we collect and manage your personal data with the highest attention and we adopt specific measures in order to keep them safe.
Below you find the main information about our processing of your personal data regarding your surfing our website and using the offered services. In order to have detailed info about how we process your personal data, we invite you to read all our Privacy Policy.

Users may be subject to different levels of protection. Therefore, some Users are afforded greater protection. More information about the protection criteria can be found in the applicability section.

Holder of the Data processing

Molino Naldoni Srl, Via Pana 156, 48018 FAENZA
Email address of the Holder: naldoni@molinonaldoni.it
Interested parties to whom the data refer

Users and surfers of the website www.molinonaldoni.it, Customers and Potential Customers, Potential Customers and/or Suppliers contacted during a trade show or event.

Types of collected Data

Among the Personal Data collected by this Website, either independently or through third parties, are: first name, last name, company, phone, email, navigation data (cookies), Usage Data and various types of Data.

Full details of each type of data collected are provided in the relevant sections of this privacy policy or by means of specific information texts displayed prior to the collection of the data itself.

Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Website. Unless otherwise specified, all Data requested by this Website is mandatory for the performance of services (Contact Request and/or Newsletter Subscription).

What happens in case of refusal to provide Data

If the User refuses to communicate them, it may be impossible for this Web Site to provide the Service. In cases where this Website indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.

Users who may have doubts as to which Data is mandatory are encouraged to contact the Data Holder.
Any use of Cookies – or of other tracking tools – by this Website or by the owners of third party services used by this Website, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the specific Cookie Policy.
It should be noted that, for no reason, the data provided by the user, collected on this site or c/o the user himself, will be transmitted to third parties for purposes other than those specified in this statement (eg marketing or commercial communications).
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Website and warrants that he/she has the right to communicate or disseminate them, releasing the Owner from any liability towards third parties.

Method and place of processing of collected Data

Method of processing

The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

The treatment can be carried out both by computer and / or telematics and analogue, with organizational methods and logic closely related to the purposes indicated.

In addition to the Data Controller, in some cases, other subjects involved in the organisation of the Data Controller (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller, may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

Legal basis of the processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

• the User has given consent for one or more specific purposes;
• the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
• the processing is necessary for the performance of a legal obligation to which the Data Controller is subject;
• the processing is necessary for the performance of a task of public interest or for the exercise of public powers vested in the Data Controller;
• the processing is necessary for the pursuit of the legitimate interest of the owner or third parties (eg resulting from customer / supplier / partner)

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, provided for by a contract or necessary to conclude a contract.

Place

The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller. The User’s Personal Data may be transferred to a country other than the one in which the User is located. The Data are processed at the operational headquarters of the Owner and in any other place where the parties involved in the processing (i.e. Managers and/or Authorised) are located. The User’s Personal Data may be transferred to a country other than the country in which the User is located, such as with regard to Mailchimp’s Cloud Newsletter service whose servers are located in the USA.

Transfer of Data outside the EU

The Data Controller may transfer Personal Data collected within the EU to third countries (i.e., all non-EU countries) only in accordance with a specific legal basis. Therefore, such Data transfers are performed in accordance with one of the legal bases described below.
The User may request information from the Data Controller regarding the applicable legal basis concretely applicable to each individual service.

Transfer of Data to countries that guarantee European standards

Where this is the legal basis, the transfer of Personal Data from the EU to third countries takes place on the basis of an adequacy decision adopted by the European Commission. The European Commission adopts adequacy decisions with respect to individual third countries that it deems to ensure a level of protection of Personal Data comparable to that provided by European legislation on the protection of Personal Data. You may view the updated list of adequacy decisions on the European Commission’s website.

Transfer of Data under SCC Standard Contractual Clauses

Where this is the legal basis, the transfer of Personal Data from the EU to third countries takes place pursuant to an agreement that meets EU requirements for the transfer of Personal Data to data controllers or data processors outside the EEA, such as the standard contractual clauses approved by the European Commission.
In this regard, it is specified that the transfer of data to the U.S. for the services and purposes listed above (e.g. Mailchimp for the Newsletter service) takes place according to the standard contractual clauses adhered to by the provider indicated in the specific privacy policy and DPA (Data Process Agreement).

Transfer of Data based on explicit consent given by the user for a specific purpose

Where this is the legal basis, the transfer of Personal Data from the EU to third countries takes place pursuant to your express consent for one or more specific purposes.

In the event that one of the transfers just described takes place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting it at the contact details given at the beginning.

Storage period

Data is processed and stored for the time required by the purposes for which it was collected.
Therefore:

• Personal Data collected for purposes related to the execution of a contract or pre-contract (e.g. information request, contact) between the Data Controller and the User will be kept until the execution of such contract is completed;
• Personal Data collected for purposes related to the legitimate interest of the Owner (e.g. protection from SPAM) will be kept until the satisfaction of such interest;
• When the processing is based on the User’s consent (e.g. subscription to newsletters and optional cookies) the Data Controller will retain the Personal Data until such consent is revoked through the unsubscription services, or another right of the data subject is exercised (e.g. right to erasure of data or right to object);
• The Data Controller retains the personal data collected from the User for as long as such information is deemed relevant for commercial purposes on the basis of Legitimate Interest and, in any case, up to a maximum of 36 months from the last useful contact (including the opening or replying to an email) or until the User requests the deletion of their data by contacting the Data Controller at one of the addresses indicated in this policy;
• In addition, the Data Controller may be obliged to keep the Personal Data for a longer period of time in compliance with a legal obligation or by order of an authority, as in the case of processing for administrative/accounting obligations (indeed for 10 years).

At the end of the storage period or at the end of the purpose for which they were collected, the Personal Data will be deleted. Therefore, at the end of this period, the rights of access, cancellation, rectification and the right to Data portability can no longer be exercised.

Purposes of Data Processing

User Data is collected to enable the Owner to provide its Services, as well as for the following purposes:

• Manage addresses and send email messages;
• Contact and provide information to the User;
• Statistics;
• Interaction with social networks and external platforms;
• Interaction with data collection platforms and other third parties (cookies);
• SPAM protection;
• Transfer of Data outside the EU (only with consent when subscribing to the newsletter service);
• Website navigation data (cookies)

To obtain further detailed information on the purposes of processing and the Personal Data concretely relevant for each purpose, the User may refer to the relevant sections of this document.

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Mailing List or Newsletter (collected through this Website and/or from you, exhibition or event)

By registering for a mailing list or newsletter, the User’s email address is automatically added to a list of contacts to whom email messages containing information, including commercial and promotional information, relating to this Website may be sent. The User’s email address may also be added to this list as a result of registering with this Website or making a purchase.

Personal Data Collected: first name, last name, company, phone, mail. Contact form (via this Website and/or at the user, trade show or event)

The User who has filled out the contact form with his or her own data, either on the site or at the user’s premises or on other occasions, e.g. trade fairs or events, consents to their use in order to respond to requests for information, quotes, or any other nature indicated in the header of the form.
Personal data collected: name, surname, company, telephone, email,

Contact by phone (via this Website and/or at the user, trade show or event)

Users who have provided their telephone number either on the site or directly via voice or email, may be contacted for commercial or promotional purposes related to this Web Site, as well as to fulfill support requests.
Personal Data Collected: Phone Number.

Managing addresses and sending email messages

This type of service allows the management of a database of email contacts, telephone contacts or contacts of any other type used to communicate with the User. These services may also allow the collection of data relating to the date and time of viewing of messages by the User, as well as the User’s interaction with them, such as information on clicks on links included in messages.
The Data Processors for these services are:

E-MIND Via Ugo Lambertini, 1 Imola

E-MIND is a service that provides domain and management of sending, receiving and storing email

Personal Data collected: mail

Processing place: ITALIA – Privacy Policy

MailChimp (The Rocket Science Group, LLC.)

MailChimp is an address management and email messaging service provided by The Rocket Science Group, LLC.

Personal Data collected: email, name

Processing place: USA – Privacy Policy.

Hosting and facility backend

These types of services are intended to host Data and files that enable this Website to function, enable its distribution and provide a ready-to-use infrastructure to deliver specific functionality of this Website.

Some of these services operate through servers located geographically in different locations, making it difficult to determine the exact location where Personal Data is stored.

OVH Data Center – France

Personal Data collected: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service.

Processing place: https://www.ovh.it/aproposito/datacenter.xml

Interaction with data collection platforms and other third parties

This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Website in order to save and reuse data.

If one of these services is installed, it is possible that, even if the Users do not use the service, it collects Usage Data related to the pages where it is installed.

MailChimp widget (The Rocket Science Group, LLC.)

The MailChimp widget allows you to interact with the MailChimp email address management and message delivery service provided by The Rocket Science Group LLC.

Personal Data collected: name, surname, factory, mail

Processing place: United States – Privacy Policy. Privacy Shield adherent.

Interaction with social networks and external platforms.

This type of service allows you to interact with social networks, or other external platforms, directly from the pages of this Website.

Interactions and information captured by this Website are in each case subject to the User’s privacy settings for each social network.

If a service for interaction with social networks is installed, it is possible that, even if Users do not use the service, it will collect traffic data relating to the pages where it is installed.

Facebook Like button and social widgets (Facebook, Inc.)

The “Like” button and Facebook social widgets are services for interaction with the Facebook social network, provided by Facebook, Inc.

Personal Data collected: Cookie and usage Data.

Processing place: USA – Privacy Policy.

SPAM Protection

This type of service analyses the traffic of this Website, potentially containing Personal Data of the Users, in order to filter it from parts of traffic, messages and contents recognised as SPAM.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected in order to track and examine the use of this Website, compile reports and share them with other services developed by Google.

Google may use Personal Information to contextualise and personalise ads in its ad network.

Personal Data collected: Cookie and usage Data.

Processing place: Ireland – Privacy Policy – Opt Out.

User rights

Users may exercise certain rights with respect to the Data processed by the Data Controller.
In the case of superior protection, the User may exercise all the rights set out below. In any other case, the User may contact the owner to find out which rights are applicable in its case and how to exercise them.
In particular, the User has the right to:
a. Revoke consent at any time. The User may revoke the consent to the processing of their Personal Data previously expressed.
b. Oppose the processing of their Data. The User may object to the processing of his or her Data when it is done on a legal basis other than consent. Further details on the right to object are set out in the section below.
c. Access your Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing and to receive a copy of the Data processed.
d. Verify and request rectification. The User may verify the correctness of its Data and request its update or correction.
e. Obtain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than to preserve them.
f. Obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.
g. Receive their Data or have it transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party or contractual measures related thereto.
h. Propose a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.
Details of the right to object
When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users are reminded that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes data for direct marketing purposes, Users may refer to the respective sections of this document.
How to exercise rights
In order to exercise the User’s rights, Users may address a request to the contact details of the Controller set out in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any event within one month.
Applicability of the higher level of protection
While most of the provisions of this document apply to all Users, some are expressly subject to the applicability of a higher level of protection to the processing of Personal Data.

This higher level of protection is always guaranteed when the processing:
a. is performed by a Data Controller located in the EU; or
b. it concerns Personal Data of users located in the EU and is functional to the offering of goods or services to such users against payment or free of charge; or
c. concerns Personal Data of Users located in the EU and allows the Controller to monitor the behavior of such Users to the extent that such behavior takes place within the EU.
Information Security
The Data Controller, in line with the provisions of Recital 49 of the GDPR, processes, including through its suppliers (third parties and/or recipients), the Personal Data of the Data Subject related to traffic to the extent strictly necessary and proportionate to ensure network and information security, i.e. the ability of a network or an information system to resist, at a given level of security, unforeseen events or unlawful or malicious acts that compromise the availability, authenticity, integrity and confidentiality of the Personal Data stored or transmitted.
The Data Controller will promptly inform Data Subjects if there is a particular risk of a breach of their data without prejudice to the obligations arising from the provisions of Article 33 of the GDPR relating to personal data breach notifications.

Cookie Policy

This Website makes use of Cookies. To learn more and to view the detailed information, the User can consult the cookie policy.

More information about the treatment
Defense in court
The User’s Personal Data may be used by the Data Controller in legal proceedings or in the preparatory phases of such proceedings in order to defend the User against abuses in the use of this Website or related Services.
The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of public authorities.
Specific information
At the request of the User, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operational and maintenance purposes, this Website and any third party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User’s IP address.
Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
Response to “Do Not Track” requests
This Website does not support “Do Not Track” requests, i.e. those that require the suspension of data collection from a user browsing the site. To find out whether any third party services used support them, the User is invited to consult their respective privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details in the possession of the Data Controller. Therefore, please consult this page regularly, referring to the date of last modification indicated at the bottom.
If the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

This is information collected automatically through this Website (including by third party applications integrated into this Website), including: IP addresses or domain names of computers used by the User who connects with this Website, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.). ) the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User

The individual using this Website or otherwise providing data to the Data Controller, unless otherwise specified, is the same as the Data Subject.

Interested

The natural person to whom the Personal Data relates.
Data Processor (or Manager)
The natural person, legal entity, public administration and any other entity that processes Personal Data on behalf of the Data Controller, as set forth in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Web Site.
This Web Site (or this Application)
The hardware or software tool through which Users’ Personal Data are collected and processed.

Service

The Service provided by this Website as defined in the relevant terms (if any) on this site/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.

Cookie

Small portion of data stored within the User’s device.

Legal references

This privacy policy is written on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy applies only to this Website.
Last modified: August 3, 2021