to the Visitors of the website www.ufirst.com
1 Type of personal data and purposes of the processing
The IT systems and software procedures, that have been set up to operate this Website, collect personal data as part of their ordinary functioning; the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected in order to relate it to identified data subjects; however, in consideration of its nature, such information might allow the identification of the Visitors, through processing and matching with data held by third parties. This category of data includes IP addresses and/or the domain names of the computers used by the Visitors connecting with this Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the Visitor’s operating system and computer environment. These data are only used to obtain anonymous statistical information on Website use as well as to check its functioning; they are erased immediately after being processed. The data might be used to assess liability in case computer crimes are committed against the Website. U-First will process the browsing data for the purpose of its legitimate interest in order to ensure the Website’s security, to check its functioning and to obtain statistical information (Section 6, paragraph 1, letter f) of the Regulation).
Data supplied by the Visitors on a voluntary basis
The voluntary, explicit and optional sending of e-mail messages to the addresses indicated on this Website, as well as in the contact forms (i.e. the “Contact Us” form), implies the collection of the sender’s address, which is necessary in order to reply to any request, as well as of such additional personal data as is contained in the message(s) (Section 6, paragraph 1, letter b) of the Regulation).
Save as specified for the browsing data, the Visitor does not have an obligation to provide the data requested in the contacts forms on the Website. However, failure to provide such data may result in the impossibility to obtain what has been requested.
2 Other processing purposes: newsletter
Subject to the Visitor’s consent, U-First will process the personal data for purpose of sending newsletters, which consist of commercial communications and news on U-First’s services and promotions sent by email (Section 6, paragraph 1, letter b) of the Regulation). The Visitor may opt-out at any time from receiving further newsletters from U-First, by clicking the unsubscribe link which will be present in any newsletter the Visitor will receive or by contacting U-First as indicated below.
3 Processing means
Personal data are processed with electronic and non-electronic means, duly considering the relevant processing purposes, and in any case by ensuring the security and the confidentially of the data. The data will be processed and stored for the time necessary to pursue the purposes referred to in the previous paragraphs and in any case until the revocation of consent to the processing by the Visitor.
4 Persons to whom the data may be communicated and data dissemination
U-First’s employees or collaborators entitled to manage the Website and reply to the Visitors’ requests or send the promotional communications may have access to the Visitors’ personal data. Such individuals, who have been formally appointed by U-First as persons in charge of the processing, will process the Visitors’ personal data exclusively for the purposes indicated in this policy and in accordance with the provisions of the Privacy Code and the Regulation.
Furthermore, third parties appointed by U-First as external data processors, such as, by way of example, IT and logistic service providers for the operation of the Website, outsourcing and cloud computing service providers, professionals and advisors, marketing companies sending marketing communications, which process the Visitors’ personal data on behalf of U-First, may have access to the Visitors’ personal data.
The Visitors’ personal data will not be communicated to third-party data controllers nor disseminated.
6 Data subjects’ rights
The Visitors, free of charge and without any formality, will be able to exercise the following rights set forth in Sections from 15 to 22 of the Regulation: the right of access to their personal data (i.e. the right to obtain from the Company confirmation as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and the information set forth in Section 15 of the Regulation); the rights to rectification (i.e. the right to obtain from the Company the rectification of inaccurate personal data or the right to have incompleted personal data completed); the right to erasure (i.e. the right to obtain from the Company the erasure of personal data concerning them where one of the grounds indicated in Section 17 of the Regulation applies); the right to restriction of processing where one of the grounds indicated in Section 18 applies; the right to data portability (i.e. the right to receive personal data in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance). The Visitors also have the right to withdraw their consent at any time. The consent withdrawal will not affect the validity of the processing based on their consent before the withdrawal. The Users have the right to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them pursuant to Section 6, paragraph 1, letter e) or f) of the Regulation, including profiling based on these provisions. The above-mentioned rights can be exercised by contacting U-First by (i) registered mail to the address “Via Giovanni Amendola n. 46, 00185 Rome (Italy)” and/or a fax to the number +39 06 87811673, (ii) email to the email address firstname.lastname@example.org or (iii) lodging a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) (www.garanteprivacy.it).