Etifor S.r.l. Benefit Company with registered office in Padua, Piazza De Gasperi, 41; e-mail: privacy@etifor.com (the “Data Controller” or the “Company“).

• browsing data (the transmission of which is implicit in the use of internet communication protocols, about which more information is available in the special section on Cookies);
• name, surname and contact data, as well as any additional personal data included in the communication, in the event that the user voluntarily decides to send messages to the Data Controller through the contact form present in the section “Contact us” of the web site and/or via e-mail or in the event that the user decides to subscribe to the newsletter. In addition, should the user decide to respond to any questionnaires that may be sent by the Owner and/or found on the Site, the information included in the relevant responses will also be processed.

• If you subscribe to the newsletter or receive promotional communications via email, additional data relating to the use of emails sent by the Data Controller, such as: information on whether the emails have been opened (date and time, number of times opened), on interaction with the content of the emails (e.g. clicks on links or buttons), as well as certain technical data relating to the device and email client used (e.g. IP address, browser/email client type, operating system). This information is collected by embedding a small, invisible image (known as a ‘tracking pixel’) or equivalent technical tools into each email message, as described in more detail in the following paragraph.

• Name, surname, address, e-mail and credit card and/or PayPal account details, language preference for communications from the Data Controller and country where the user intends to register and join one of the Services provided by Etifor. If the user selects the “gift” option when finalizing the order it will also be asked to enter the name, mobile number and e-mail of the gift recipient. With this the user confirms that he/she has informed the third party recipient of the gift of the processing of his/her personal data referred to in this information. However, it is understood that the Data Controller will subsequently inform the recipient of the gift in accordance with the articles 13 and 14 GDPR for the purpose of finalizing and executing the requested Service.

We will process browsing data:

• to enable the user to use web services;
  Processing for the aforementioned purpose does not require the user’s consent. These data are kept for the time strictly necessary to achieve this purpose. More information is available in the Cookie policy section.
• To derive statistical information about the use of the website;
• to create profiles on users and send advertising messages in line with the preferences revealed by users while browsing the website.
  Processing for the aforementioned purposes requires the user’s consent. Such data are kept for the time strictly necessary to achieve those same purposes. More information is available in the Cookie policy section.

We will process user’s personal data:

• to acknowledge any requests.
  This type of processing does not require the user’s prior consent (as “processing necessary for the execution of pre-contractual measures taken at the request of the data subject”). Data in this case are kept for the time strictly necessary to respond to the user’s request;
• to allow the Data Controller to carry out surveys to which the user has voluntarily and optionally adhered and to manage the activities connected with and instrumental to the realization and execution of surveys.
  Such data (where not anonymous) will be kept limited to the duration corresponding to that necessary to carry out the survey organized by the Owner;
• for the purpose of contract execution or required pre-contractual measures. It should be noted that the execution of the contract will involve the periodic sending of e-mails by the Controller to update the data subject regarding the supported environmental project. It is also specified that if the user selects a Service that he intends to purchase and inserts it into the electronic “shopping cart”, he will receive reminder communications if he temporarily leaves the selected items in storage;
• to fulfill administrative, accounting and tax obligations required by current legislation for the management of the contractual relationship.
  The legal basis for processing is the execution of the contract or pre-contractual measures and the fulfillment of legal obligations. Data are retained for the duration of the business and contractual relationship and for an additional ten years in order to fulfill administrative, tax and accounting legal obligations.

• Only with the user’s prior consent will we also process their data for marketing purposes, namely to enable our Company to send newsletters, information and promotional communications by email concerning services, offers and announcements of events – including networking events – organised by the Company. To manage these communications, we use email marketing platforms which insert a small, invisible image (known as a ‘tracking pixel’) or equivalent technical tools into each message, enabling us to detect whether and when an email has been opened, how many times, whether links or other content have been clicked, and to collect certain technical data relating to the device and email client (e.g. IP address, type of email client, browser or operating system). This information is used to measure the effectiveness of our campaigns and to improve the content of our communications.

• Only subject to the user’s further consent may we also process certain data relating to their behaviour and habits as demonstrated during registration on the Website and/or during the purchasing process (e.g. type of services purchased, frequency of purchases, any interests indicated), as well as data relating to the opening and interaction with emails collected via tracking pixels, to enable the Data Controller to personalise the aforementioned communications and send content more closely aligned with your interests. In this case, processing is based on consent and the data is retained until such time as consent is withdrawn and, in any event, for a period not exceeding 12 months, without prejudice to any further retention periods for contractual purposes or to respond to the user’s requests.
  Data processed for marketing purposes will be retained for 24 (twenty-four) months, without prejudice to the right to withdraw previously given consent at any time. Consent to receive marketing communications also includes the use of tracking pixels in emails for the purposes set out above. 

• We would also like to point out that, in accordance with applicable legislation and without prejudice to your right to object easily, we may use your email address – without the need for your consent – to offer services similar to those covered by the contract (“soft spam”). In this case too, you may object at any time to the sending of such communications or to the use of tracking pixels alone, as set out below.
  You may at any time withdraw your consent to receiving marketing communications and/or to the personalisation of such communications, as well as, on a granular basis, withdraw your consent solely to the use of tracking pixels in emails, whilst continuing to receive communications without such markers. Withdrawal or objection may be exercised easily and free of charge, for example by clicking on the relevant link at the bottom of each email received or by writing to privacy@etifor.com. Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

Lastly, it should be noted that in the event that any spontaneous request from the user is aimed at registering for an event organized by the Data Controller, the user-applicant is hereby made aware of the fact that as part of such events, photos and/or videos may be taken and/or made by the Data Controller and/or parties appointed by the Data Controller and/or partners involved in the organization of the event, having as their object the event and for purposes of promoting it and the activities of the Data Controller and/or partner, mainly within the social channels and websites of the latters. 

The legal basis for such processing is the legitimate interest of the Data Controller and/or third parties (the partners involved in the organization of the event and/or to whom the Company has a contractual obligation having to do with the event).

Since these will be mainly group images from which it will not be possible to extrapolate and/or delete the image of the individual, the user is invited, as of now, not to register for the event where he/she does not wish to be portrayed within the context of such images and/or videos.

It is the user’s responsibility to also inform any companions at the event of this circumstance.

The above data will be kept for the period deemed strictly necessary for the above purpose.

With the exception of what has been specified with reference to browsing data and/or data in case of user participation in events organized by the Data Controller and/or its partners, the user is free to provide his/her data for the purposes mentioned in the previous paragraph.

However, in case of failure to provide it, it will not be possible to follow up on his/her requests.

 The provision of data for marketing purposes, the receipt of personalised communications and consent to the tracking of email opens and interactions via tracking pixels is always optional. Failing this, the user will not receive promotional communications, will not be informed of new events or initiatives promoted by the Data Controller and/or will not receive personalised communications, and their interactions with emails will not be monitored; however, this will not affect their ability to access the Website and use the Services in any way.

Recipients of the data

• employees and/or collaborators in any capacity whatsoever of the Data Controller, adequately trained and authorized for processing;
• subjects the Data Controller uses to carry out activities instrumental to the achievement of the above-mentioned purposes (by way of example only: IT and application service providers – including providers of email marketing and automation platforms used to send communications and track opens and interactions via tracking pixels – consultants, etc., consultants, etc.) or to whom the Data Controller is required to disclose the data in accordance with legal obligations.
• any partner companies of Etifor or European granting authorities/institutions within the scope and management of specific projects.
  These subjects will process the data as autonomous data controllers or as data processors, duly appointed by the Company.

In carrying out its ordinary activities, the Data Controller may make use of some providers (mostly IT services, e.g. e-mail provider mail server) operating outside the European Union.

We specify that, in any hypothesis of transfer outside the European Union, the guarantees provided by the Regulation in Articles 44 et seq. of the Regulation will be adopted.

User to whom personal data refer may exercise the following rights: access their personal data, correct, remove or export them. The user will also have the right to restrict the processing of his/her own personal data. Where collection or processing is based on consent, he/she may withdraw his/her consent at any time. In addition, he/she will be able to receive his/her personal data in a commonly used, machine-readable structured format and ask us to transmit such data to another data controller where technically feasible. He/She may object to the processing of his/her personal data when the processing is based on the legitimate interest of the Data Controller (or third parties) and if his/her personal informations are used for direct marketing purposes. Finally, the user may lodge a complaint with the Data Protection Authority (www.garanteprivacy.it.) if he/she believes that his/her rights have been violated.

If the user wishes to exercise any of these rights, he/she may send an e-mail to privacy@etifor.com.

The Data Controller reserves the right to make changes to this policy and any changes will be made available through this website.