PRIVACY POLICY According to ART. 13 of GDPR 2016/679

We take the protection of our users’ (“User/you/your”) personal data very seriously and strictly comply with applicable data protection laws and regulations. In our privacy policy below (“Privacy Policy”) we provide you with an overview of what data we collect for what purpose and how we ensure the protection of the data.

Controller

The data controller is Torggler Srl via Prati Nuovi 9, 39020 Marlengo (BZ), Italy, VAT no. 00851700211. It can be contacted at the e-mail address info@torggler.com or by phone at 0473/282400. A third party company has also been identified with the task of carrying out the technical management/maintenance of the website and setting up the chatbot service:

• Wunderfarm: technical management and maintenance of the website
• Intercom: chatbot service

According to the Terms and Conditions between Customer and us, such Customers are responsible for the (personal) data included by them on our Website, including but not limited to required consents by the affected individuals.

Nature of the processing

The data processed through the website are personal data of a common nature (by way of example and not exclusive to e-mail, personal data, etc.) and in general all those data that are necessary to perform the service as well as to respond to requests received. Under no circumstances will our structure process without prior consent data of a particular nature defined by art. 9 of European Regulation 2016/679 (e.g. health conditions, political opinions, sexual orientation, etc.) or personal data relating to criminal convictions or crimes, art. 10 of the same European Regulation.

Purpose and Methods of processing 

The data processing will be finalized in order to respond to the requests received, as well as to proceed to the eventual subscription to newsletters or to the execution of the staff application procedure. This information is intended to inform users about the processing of data concerning the exercise of the right of access. The data provided will also be processed for legal, fiscal and accounting purposes and to allow the management of the business relationship between the parties. For these purposes the provision of data is to be understood as mandatory, and failure to provide it will make it impossible to implement the above.

Subject to your consent, the data may also be used to keep you up to date with our promotional and marketing activities. In this case the provision of data is optional, and a refusal to provide the data will not entail any consequences. in any case, your data will not be disclosed to third parties for marketing purposes. With regard to the management of cookies, please refer to the following sections. The data collected will be processed on paper and with electronic instruments, configured to guarantee an adequate level of security of the data.

Data processing via chatbot

The data you provide us with using the chat are processed for the following purposes:

• to carry out market research, aggregating and anonymising the data, aimed at detecting the level of satisfaction with our events and the level of knowledge of our brand.
  Data processing for the above purposes will be carried out in compliance with the Privacy Regulations and all specific sector regulations.

The data provided by you will be processed mainly by computer under the authority of the Data Controller, by persons specifically appointed, authorised and trained to do so in accordance with Articles 28 and 29 of the Privacy Regulations.

Providing your personal data is optional, and failure to provide them for the purposes indicated above will not prevent you from continuing your conversation with the Chatbot. To this end, you will be free to decide whether or not to give your consent for this purpose as well, without this preventing you from accessing the site or other services on it.
Specifically, the Chatbot will collect your consent to the processing of your personal data for the purpose of sending you newsletters.

Your data will be used for the purposes of the Website

• to implement this privacy policy and carry out the contractual relationship (§§ 14, 15 TMG or Art. 6 (1) b. GDPR),
• for providing our services on the Website, to contact you in matters regarding our services (also by means of emails and messaging) and to ensure the technical functionality of our services fulfillment of contractual or pre-contractual obligations ((§§ 14, 15 TMG or Art. 6 (1) b. GDPR),
• for fraud prevention (§§ 14, 15 TMG, Art. 6 (1) b. and f. GDPR),
• to analyze your use of our services and improve our services (§§ 14, 15 TMG, Art. 6 (1) b. and f. GDPR),
• with your express consent or instruction to carry out our business activities or sent you newsletters (Art. 6 (1) a. GDPR),

Applicable legal provisions are in particular those of the regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016, repealing the directive 95/46/EC, on the protection of individuals with regard to the processing of personal data, on the free movement of such data (“General Data Protection Regulation”, GDPR).

Regarding the data processing based on Art. 6 (1) f. GDPR we wish to achieve the legitimate interests of quality assurance, marketing and fraud prevention.

Data Storage

The data will be kept for the period necessary for the performance of the service or assignment conferred as well as for any other storage obligation provided by law.

Communication of data to third parties

The data will not be disclosed in any way, where disclosure means to give knowledge to unspecified subjects through any means. The data may also be communicated to specific subjects such as:

• persons in charge within the structure in order to carry out the processing operations
• tax consultants, labour consultants, credit institutions, forwarding agents who perform services ancillary to those provided by the Data Controller
• other external parties identified as partners and specifically appointed as data processors
  By virtue of the participation of these subjects in the activity of the Data Controller for the provision of the service, the communication of data is mandatory. A lack of communication would in fact make it impossible to perform the task or the agreed performance.

Transfer of data to third parties 

The data collected through the website will in no way be transferred or communicated to third countries outside the European Union.

Automated decision-making process (“Profiling”)

We inform you that your data is not included in automated decision-making processes. In general we do not process any data via “profiling” or in form of automated decision making via the our website or our online-shop. However, such profiling may happen by third party providers through the Website. If this is the case we will inform you in the privacy policy (if possible).

Transfer of Data outside of the EU

In the course of data processing by us data will be transferred to third countries, i.e. countries outside the EU. This may happen via implementation of third party providers such as cloud services and external service partners which process data controlled by us. For details please refer to our privacy policy.

Your Rights

• You have the right to withdraw your consent relating to the use of data according to this privacy policy at any time with effect for the future. In the event of withdrawal the stored data shall not be processed any more and shall be deleted without hesitation. However, such data may, for example, still be used if these are still necessary for ceasing the contractual relationship.
• You are entitled to access the data stored by us and are also entitled to amend or rectify your data if such data are incorrect.
• You are entitled to request the erasure of your data. However, this shall not apply, in particular, if the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims.
• You are entitled to receive information about the stored data (in a structured, current and machine-readable format) at any time and to request the correction or deletion of the data in case of incorrect data storage.

To enforce your rights you may reach us through the contact details set above.

Data acquired through navigation 

During navigation, the website acquires the necessary information to allow a correct and safe browsing experience, such as IP addresses, MAC addresses, domain names of computers used by users connecting to the site and any other technical information implicit in the use of Internet communication protocols. These data are not associated with directly identifiable Users and are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to verify its proper functioning, only for the time strictly necessary to perform these operations.

Period for Storing Data; Deletion

The data is deleted if such data is no longer necessary for the purpose of processing.

What is Personal Data?

Personal Data and Consent Personal data are any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Personal data includes e.g. name, email address or telephone number. Personal data also includes information about hobbies, memberships or websites viewed by someone else.We will only collect, use and/or pass on personal data if this is permitted by law or if the User consents to processing their data.Consent of the data subject means any freely given, specific, informed and unambiguous indication of the person’s (data subject) wishes by which they, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them.

How are my Data used when visiting the Website?

Visiting the Website: We (or the webspace provider) collect data about each visit of the Website (so-called server logfiles) (“Access Data”)

Access Data includes the following: Name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, User’s operating system, referrer URL (the previously visited page), IP address and the requesting provider

When using a mobile device Access Data also contains: Country code, language, device name, operating system and version name

We use these Access Data only for statistical analysis for the purpose of operation, security and optimization of our Website. However, we reserve the right to check these Access Data retrospectively if there is a justified suspicion of illegal use based on concrete indications. These data are then stored because this is the only way to prevent the misuse of our Website, if necessary, allow us to investigate any crimes committed. The storage of these data is necessary in order to protect us as the person responsible for processing the data. As a matter of principle, these data will not be passed on to third parties unless there is a legal obligation to pass it on or the transfer of data serves criminal prosecution purposes.

This data processing is based on Art. 6 (1) f. GDPR and we wish to achieve the legitimate interests of stabilizing and improving our Website, quality assurance and fraud prevention.

• Contacting us: When contacting us (e.g. by email), the User’s details are stored for the purpose of processing the enquiry and, if applicable, follow-up questions based on your consent (legal basis Art. 6 (1) a. GDPR).
• Newsletter: With the newsletter we inform the user about the Websites, our services and us.When registering for the newsletter, a User has to provide an email address. This email address will be transmitted to and stored by us (or a provider as specified below).After registration, the user will receive an email to confirm the registration (“double opt-in”). Via clicking the registration link you have given your consent to the processing of your personal data for receiving our newsletter according to Art. 6 (1) a. GDPR and we may process such data accordingly. In case of registration for the newsletter we (or our provider as specified below) also store the IP address, the device name, the mail provider as well as the user’s first and last name and the date of registration.

Use of Mailchimp; Transfer of Data outside the EU

The mail provider “Mailchimp” by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA receives and processes on our behalf the data necessary for the order, in particular email address, IP address, device name. These data are processed on servers in the USA. MailChimp is certified according to “Privacy Shield”. The “Privacy Shield” is an agreement between the European Union (EU) and the USA to ensure compliance with European data protection standards in the USA.

Mailchimp is a service with which the dispatch of newsletters can be organized and analyzed. With the help of Mailchimp we can analyze our newsletter campaigns. When you open an e-mail sent with Mailchimp, a file contained in the e-mail (so-called web beacon) connects to the Mailchimp servers in the USA. This allows you to determine whether a newsletter message has been opened and which links have been clicked on. In addition, technical information is recorded (e.g. time of registration, IP address, browser type and operating system). This information cannot be assigned to the respective newsletter recipient. They are used exclusively for statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients.

If you do not want Mailchimp to analyze your data, you must unsubscribe from the newsletter. For this purpose, we provide a respective link in every newsletter.

Details on Mailchimp and its privacy policy can be found here: https://mailchimp.com/legal/privacy/

The data are stored for the purpose of newsletter subscription and will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers as well as from the servers of MailChimp after you unsubscribe from the newsletter. Data stored by us for other purposes remain unaffected.

Each User can withdraw their consent to the storage of data, the email address and their respective use for sending the newsletter at any time. This can be done free of charge (except for the transmission costs) and via a link in the newsletter itself or notification to us or, if applicable, to Mailchimp.

What kind of Cookies, Web-tools or Third Party Providers does the Website use and how?

Our website uses cookies to ensure the correct use of the website and to improve the user experience. This Policy provides information about the types of cookies used, their purpose and how they are used only on this website.

What are cookies? 

The provision on cookies d.d. 8 May 2014 defines cookies as “small text strings that the sites visited by the user send to his terminal (usually to the browser), where they are stored and then retransmitted to the same sites the next time the same user visits. During navigation on a site, the user may also receive cookies on his terminal which are sent by different sites or web servers (so-called “third parties”), which may contain certain elements (such as, for example, images, maps, sounds, specific links to pages of other domains) present on the site he is visiting”.

Cookies can be used for various purposes such as for example to perform computer authentication, storage of information related to configurations of the machines accessing the server, favorite websites, etc. . The different types of cookies are illustrated below.

Types of cookies: 

• Technical cookies: Technical cookies are those cookies that are essential for navigation and can be either temporary (stored only for the duration of navigation, once closed the browser these cookies will be deleted) or persistent (stored for a longer period and will not be deleted once navigation is complete). These cookies, precisely because they have technical characteristics, are not subject to prior consent by users.
• Profiling cookies: these are used to identify the user’s preferences and on the basis of these preferences, to send advertising messages or commercial offers. For this reason they require the user’s prior consent for their installation.
• Analytical cookies: these are cookies used to monitor visits and use of the web page statistically. One of the main services used by the websites is the one provided by Google Inc. called “Google Analytics”, through which it is possible to have statistical data about the navigation on the website. This type of cookies is considered as profiling cookies, unless the IP address is totally or partially anonymized, thus eliminating the sharing of information with Google (in this case considering them technical cookies).

The types of cookies described above can be divided into “first-party” cookies, processed and managed directly by the Website Owner, or “third-party” cookies, processed and managed by third parties other than the Website Owner (think for example Facebook, Twitter, Linkedin, Google+ etc.).

• Cookies: OPT-OUT: You can deactivate the use of Cookies in the settings of your internet browser at any time. To find out how to change the settings, please consult the help function of your internet browser. You may also deactivate and manage Cookies via AboutAds (US-website-provider) or YourOnlineChoices (EU-website-provider).
• Google Analytics: The service offered here uses Google Analytics a web analytics tool offered by Google LLC, Mountain View, CA, USA (“Google”). This analysis service uses so-called “cookies”. For analysis, text files will be stored on your device. The information stored in the corresponding files about the use of this website are generally transmitted and stored in Google server in the USA. As the IP anonymization is active on this Website, your IP address will be shortened by Google within the member states of the European Union (EU). This information will be used to evaluate your use of the services offered here and enable us to analyze your website activity and provide other services associated with the Website. The IP address transmitted from your browser, as part of Google Analytics will not be merged with other data from Google.OPT-OUT: It is possible to prevent the acquisition and processing of data generated by the “Cookies” in relation to the use of this website, by downloading and installing the browser plugin.  Google LLC, USA is certified according to the EU-US agreement “Privacy Shield”. The “Privacy Shield” is an agreement between the European Union (EU) and the USA to ensure compliance with European data protection standards in the USA.

Below is a list of the cookies used by the website:

The banner on the first access, located on the home page, provides summary information on how to manage cookies on the site, referring to the full privacy policy.

The user can express his or her consent to the use of cookies, including profiling cookies, through the “OK” button on the Banner. These data relating to the user’s choice regarding the management of cookies are stored through a technical cookie for a period of 4 months.

How to disactivate cookies

Internet Explorer

https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies

Google Chrome

https://support.google.com/accounts/answer/32050?hl=it

Mozilla Firefox

https://support.mozilla.org/it/kb/Eliminare%20i%20cookie

Apple Safari

https://support.apple.com/kb/PH5042?locale=en_US

Linkedin:

• https://www.linkedin.com/legal/cookie-policy
• http://it.linkedin.com/legal/privacy-policy

Google Analytics, Google+ e Youtube:

• https://www.google.it/intl/it/policies/privacy/
• http://www.google.it/intl/it/policies/technologies/cookies/
• http://www.google.it/intl/it/policies/technologies/managing/

Twitter:

• https://twitter.com/privacy?lang=it
• https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter

Facebook:

• https://it-it.facebook.com/privacy/explanation
• https://it-it.facebook.com/help/cookies/?ref=sitefooter

You may contact the Data Controller and/or the Data Protection Manager (info@torggler.com) for any information as well as for the exercise of your rights provided for by law (access to data, cancellation, rectification or limitation of processing). You may also contact the supervisory authority if you believe that your data has been processed unlawfully or incorrectly.