Information Note on the Processing of Personal Data – Information Note pursuant to and in accordance with Article 13, Law Decree of the 30 June 2003 no. 196
In compliance with the Law Decree of the 30 June 2003 no. 196 (Privacy Code) as subsequently amended, we hereby provide the relative information due concerning the processing of personal data provided by you. The information note shall not apply to other websites accessed through links found on the internet websites of the Data Controller; for the sake of clarification, the latter shall under no circumstances be responsible for third party internet websites.
This information note is also provided in terms of Art. 13 of Law Decree no. 196/2003 – Protection of Personal Data Code . The information note is also inspired by Recommendation no. 2/2001 adopted by the European authorities for protection of personal data, during a meeting of the Group established by Art. 29 of Directive no. 95/46/EC on the 17th May 2001 for the identification of certain minimum requirements for the collection of personal data online and, in particular, the method, the time-frames and the type of information which the Data Controllers shall provide users when the latter access the website, regardless of the purpose of access thereto, as well as the provisions of Directive 2002/58/EC, as may have been updated by Directive 2009/136/EC, concerning Cookies.

1. The Data Controller shall, in terms of Article 28 of the Data Protection Code, be Torresin Titanio S.r.l., Via del Santo 246, 35010 Limena (PD), VAT n. IT04124040280, e-mail accounting@titanio.com, in the person of the pro-tempore legal representative.

2.Types of Data Processed
Personal and Identification Data
Personal Data, means any information regarding an, even indirectly, identified or identifiable physical person by reference to any other information, including a personal identification number; Identification Data, means the personal data that allow for direct identification of the data subject (such as, by way of example, name, surname, e-mail address, telephone number, etc…).
Navigation Data
IT systems and software procedures used for the functioning of this website acquire certain personal data during normal functioning, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects but, by its very nature, could allow the identification of the users by means of processing and association with data held by third parties. The following are included in this category of data: IP addresses or domain names of the computers used by the users that connect to the site, the URIs (Uniform Resource Identifiers) of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numeric code indicating the response status given by the server (successful, error, etc.) and other parameters relating to the operating system and the user IT environment. These data are used solely for the purposes of collecting anonymous statistical information on the use of the site and to check that it is functioning properly.
Defence during Legal Proceedings – The User’s Personal Data can be used for the defence of the Data Controller in legal proceedings or in the stages in preparation of the commencement of legal proceedings, and abuse of its use or of the relative services by the User. The data may be used to ascertain responsibility in the case of hypothetical computer crimes damaging the site.
Maintenance – The User’s Personal Data can be processed using alternative procedures and for other purposes relative to the maintenance of the systems.
Data provided voluntarily by the User
The optional, express and voluntary sending of e-mails to the addresses indicated on this website involves the subsequent acquisition of the sender’s address, necessary for responding to requests, and of any other personal data included in the communication. When required by the Privacy Code, Torresin Titanio S.r.l., shall request the User’s consent before processing the personal data.
Specific Information Notes – Specific Information Notes regarding particular services or processing of the Data provided by the User or the Interested subject may be published on the website.
System Log and Maintenance
For reasons concerning operation and maintenance, this website could have a system log, meaning files which record events and which could also contain Persona Data, such as the User IP Address.

3. Purpose of the processing consented to, when necessary (Articles 23, 24 of Law Decree 196/03)
Until withdrawal of consent, personal data provided voluntarily shall be processed for the following purposes:
– browsing on this internet website;
– replying to your e-mails and sending information requested;
– general administrative / accounting operations.
For the purposes of application of the law on protection of personal data, the processing carried out for administrative and accounting operations shall consist in organisational, administrative, financial and accounting work, regardless of the type of data processed. More specifically, this purpose shall include: internal organisational operations; activities performed in fulfilment of contractual and pre-contractual obligations and informational activities.

4. Processing Methods – Data Storage
The personal data gathered by Torresin Titanio S.r.l., is mainly processed using electronic, automated and telematic means, applying logic and procedures which are strictly related to the processing purposes indicated in the Privacy Policy, but could also be processed using manual means; provided this processing is limited to the time strictly necessary for attainment of the particular purposes pursued from time to time, in respect of the applicable law protecting personal data which includes the safety profile and the confidentiality obligations to which our work aspires. The data shall be processed in observance of the applicable provisions regulating safety in order to reduce to a minimum the risks of, even accidental, destruction and loss of data, unauthorised access, unauthorised processing or processing non-compliant with the purposes of data collection and the illegal or incorrect use of data, with particular (but not exclusive) reference to Appendix B of the Privacy Code (Technical Specifications in relation to Minimum Safety Measures). Furthermore, the computer systems and programs are programmed in such manner as to reduce to a minimum the use of personal and identification data which is not necessary to the particular processing purposes pursued from time to time.

5. Location for the processing of data collected
The Data are processed at the operational headquarters of the Data Controller and in any other place where the persons responsible for processing are situated.
The personal data processing operations relative to the activity of the Website and to the web services are performed at the headquarters of Torresin Titanio S.r.l., and at third parties engaged by Torresin Titanio S.r.l., for the management and operation of the Website and the activities performed through the Website.
For further information, please contact the Data Controller by e-mail: accounting@titanio.com

6. Sphere of Disclosure and Dissemination of Data
Your data, forming the subject of the processing, shall not be disclosed but could be transmitted to companies under contract with Torresin Titanio S.r.l. within the European Union, in compliance with the limits set by Art. 42 of Law Decree. no. 196/2003, in order to fulfil contractual obligations or relative purposes. The data could be disclosed to third parties where this is strictly required for execution of the service (mailing of material, provision of assistance, etc).
The data can be disclosed to third parties falling within the following categories:
– persons providing a service associated with the management of the computer system used by Torresin Titanio S.r.l., its telecommunication network, including electronic mail and management of internet websites:
– offices or companies providing assistance and consultancy services;
– third parties engaged by Torresin Titanio S.r.l., for the technical management of the website and for execution of the technical and organisational services required for fulfilment of the activities performed through the website and for the above-indicated purposes;
– competent authorities, in fulfilment of legal obligations and/or orders of public entities, upon request.
The processing relative to web services offered by this website shall be physically “hosted” by other companies.
For further information on the Provider/Maintainer please write to accounting@titanio.com
The persons falling within the above-indicated categories shall perform the function of Data Processors, or operate in full autonomy as distinct Data Controllers. The list of persons processing the data is constantly updated and available at the headquarters of Torresin Titanio S.r.l.
These persons are only given the information necessary for fulfilment of their relative work; they shall process the data in their capacity as Controllers, Processers charged with the processing, according to circumstances, for the same purposes indicated in this Privacy Policy. The User’s personal data shall not be disclosed.
Any other disclosure or dissemination shall only take place on attainment of your express consent.
The User’s personal data shall be accessible to our internal and external staff members charged with the processing for the above-described purposes and by the herein-indicated Data Processor.

7. Nature of the Provision and Refusal
Apart from that specified in the clause on navigation data, the User is free to provide personal data. The provision of personal data is optional; however, it does become necessary in order to reply to requests sent by mail. The non-provision of data could impair the fulfilment of the request or the use of the services offered by the Data Controller.

Data subject rights
The subjects to whom the personal data refer have the right to obtain, at any time, confirmation of the existence of such data and to know their content and origin, check their accuracy or request the supplementation, update or correction of the data (art. 7 of Italian Law Decree no. 196/2003). Pursuant to the aforementioned article, the data subject has the right to request the cancellation, conversion into anonymous form or freezing of data processed in breach of the law and to oppose the processing of the data for legitimate reasons.
Requests should be referred to Torresin Titanio S.r.l., Via del Santo 246, 35010 Limena (PD), VAT n. IT04124040280, e-mail accounting@titanio.com
Art. 7 of Law Decree no. 196 of 30 June 2003
1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in an intelligible form. 2. The data subject shall be entitled to obtain an indication of: a) of the source of the personal data; b) of the purposes and methods of the processing; c) of the logic applied to the processing, if the latter is carried out with the help of electronic means; d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative in the State’s territory, data processor or person in charge of the processing. 3. A data subject shall have the right to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. 4. The data subject shall be entitled to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

Should you wish to contact the Data Controller, kindly provide an electronic mail address, your name, address and/or your telephone numbers to enable the proper handling of the request.

8. Amendments to this Privacy Policy
The Data Controller shall, at any moment, be entitled to amend, update, supplement or remove parts of this privacy information note at its discretion. Any interested person may periodically check out any such amendments. In order to facilitate verification, the information note shall include the relative date of update. The use of the website after publication of the amendments shall constitute acceptance thereof.

Latest version released on the 9 december 2015.