Privacy Policy

par-2129 PURPOSE OF THIS STATEMENT
Privacy Policy Statement issued pursuant to Italian Legislative Decree 196/2003 and subsequent amendments and additions and Regulation (EU) 2016/679 General Data Protection Regulation
In accordance with the aforesaid legislation, data will be processed in a fair, lawful and transparent manner, safeguarding the user’s privacy and rights.
This privacy policy statement is issued, pursuant to Art. 13 of Legislative Decree 196/2003 and subsequent amendments and additions (Personal Data Protection Code), to users/visitors who interact with the Zenit website http://www.zenit.com and has been updated in accordance with Regulation (EU) 2016/679 concerning "the protection of natural persons with regard to the processing of personal data and on the free movement of such data" and legislation concerning Internet cookies and in particular Italian Data Protection Authority Measure dated 8 May 2014 "Simplified Arrangements to Provide Information and Obtain Consent Regarding Cookies" and the subsequent clarifications concerning the implementation of cookie regulations issued on 5 June 2015.
The statement refers only to the management procedures of the website of Zenit Italia s.r.l. a socio unico with regard to the processing of the personal data of users/visitors who consult it, and not those of external websites which users are able to consult by clicking hyperlinks provided on the site.
Additional information may be provided within specific sections.

THE "DATA CONTROLLER"
Visiting this site may lead to processing of the personal data of identified or identifiable natural persons.
The “data controller” with regard to their processing is Zenit Italian S.r.l. a socio unico, with registered office in Via dell’Industria 11 San Cesario sul Panaro (Modena) – Italy; pursuant to Art. 4 of Regulation (EU) 2016/679, the data controller hereby informs all those concerned that, pursuant to Art. 13 of the said regulation, during the conduct of its business it will process personal data manually and/or with the aid of digital media for the purposes listed below.

DATA PROCESSING LOCATION
The processing of data related to this site’s web services will take place at Zenit Italia s.r.l. aforesaid location, solely by the technical staff of the relevant Department, or any staff appointed to perform occasional maintenance work.
No data deriving from the web service are disclosed or disseminated.
The personal data supplied by users who request the dispatch of informative material (bulletins, Cd-roms, newsletters, annual reports, replies to queries, legal documents and measures, etc.) are used solely for the purpose of providing the service requested and are only communicated to third parties if necessary for the aforesaid purpose (service for the dispatch performed by a professional person appointed by the Data Controller).

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1. TYPE OF DATA PROCESSED AND PROCESSING PURPOSES

1.1. Navigation data
During their normal operation, the IT systems and software applications which operate this website acquire some personal data, the transmission of which is implicit in the use of Internet communications protocols.
These data are not gathered for association with identified subjects, but by their very nature, when processed or associated with data held by third parties, they might allow users/visitors to be identified. The data collected include the IP addresses or domain names of the computers used by users who log onto the website, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used when submitting the request to the server, the size of the file obtained in reply, the numerical code indicating the server’s response status (concluded successfully, error, etc.) and other parameters relating to the user’s operating system and IT environment.
These data are processed (for the time necessary for the achievement of the purposes for which they are collected) for the sole purpose of obtaining anonymous statistical information concerning use of the website (accesses to it) and to check that it is operating correctly.
The data might be used to identify those responsible in the event of IT crime against the site.
 
1.2. Data supplied voluntarily by the user
The sending of email messages to the addresses specified on this website (to request information, for example) implies the acquisition of the sender’s address, as well as of any other personal data included in messages. These data will be processed for the sole purpose of fulfilling the request and only disclosed to third parties if this is necessary for its fulfilment (e.g. service for dispatching of documentation requested).
In the event that users/visitors are required to provide their data in order to access particular services, a specific, detailed privacy policy statement with regard to the relative processing, pursuant to Art. 13 of Italian Legislative Decree 196/03, will be issued in advance on the pages relating to the individual services, stating the limits, purposes and procedures of the relative processing.
 
# 1.3. Cookies
Description of cookies
Cookies are small text files which the website visited sends to the user’s device (usually their browser), where they are saved in order to allow the device to be recognised at the user’s next visit to the site. In fact, the user’s device resends the cookies to the site at every subsequent visit.
However, cookies may be "installed" (to be more precise, saved and accessed) not only by the actual manager of the website the user visits (first-party cookies), but also by other sites which install cookies by means of the first site (third-party cookies), and are able to recognise them. This occurs because the website visited may contain items (images maps, sounds, hyperlinks to the webpages of other domains, etc.) which reside on servers different from that of the site visited.
Cookies subdivide into technical cookies and profiling cookies, depending on their purposes.
Technical cookies are "installed" for the sole purpose of "transmitting a message on a digital communications network, or for no longer than is strictly necessary to transmit a communication or provide a specific service as requested by a subscriber or user" (see Art. 122, comma 1 of Italian Legislative Decree 196/2003 - Personal Data Protection Code - as amended by Legislative Decree 69/2012). They are normally used to allow efficient navigation between pages, save users’ preference (e.g. font size, language, country, etc.), save information about the users’ specific configurations, manage their login, etc. Some of these cookies (known as strictly necessary), such as the session cookies used to manage the shopping cart on e-commerce sites, allow functions without which no operations would be possible. Under the aforesaid Art. 122, comma 1 of the Italian Personal Data Protection Code, users’ consent is not required for technical cookies.
There are other categories of cookies considered as equivalent, for data protection purposes, to technical cookies (meaning that neither users’ consent nor further regulatory compliance is required for their installation). These are “analytics” cookies, used to monitor users’ use of websites for the purpose of their optimisation, if used directly by the first-party site (i.e. without the involvement of third parties), and analytical cookies produced and made available by third parties and used by the first-party site for purely statistical purposes, provided suitable measures are used to reduce their identifying power (for example, the masking of significant portions of the IP address) and the third party specifically undertakes not to cross-check the data contained in the said cookies with other data at its disposal.
Profiling cookies are used to trace users’ navigation and analyse their behaviour for marketing purposes, and are intended for the creation of user profiles, to enable the sending of advertising messages in line with the preferences expressed by the user when browsing the web. These cookies may not be installed on users’ terminals unless they have expressed their consent by the procedures specified in the Measure.
Cookies are subdivided on the basis of their duration into persistent cookies, saved on the user’s device until removed by the latter, and session cookies, which are not persistently saved on the user’s device and disappear when the browser is shut down. Profiling cookies are usually persistent cookies.
Cookies used on the Zenit website http://www.zenit.com
This website uses:
technical cookies:
to provide website users with the most effective, efficient navigation experience possible. These are therefore cookies strictly necessary to allow the website to be viewed correctly in relation to the technical services offered. These cookies will therefore always be used and sent, unless users modify their browser settings (which would interfere with viewing of the website’ pages).
Their duration may vary depending on their use: from duration simply of the working session (they are deleted when the browser is shut down) up to a maximum of 30 days, when they are useful for offering the user information and/or services contained on the portal more quickly, and thus more efficiently, at a return visit.
 
Third-party analytical and/or service cookies:
The Zenit website includes some components sent by Google Analytics, a web traffic analytics service provided by Google, Inc. (“Google”). They are third-party cookies collected and managed anonymously to monitor and improve the host website’s performance (performance cookies).
Google Analytics uses cookies to collect and analyse data on behaviours relating to use of the Zenit website (including the user’s IP address) in anonymous form. Google Analytics collects and processes these data in order to issue reports for Zenit staff concerning activities on the website.
This site does not use (or allow third parties to use) the Google analytics tool to monitor or collect identifying personal data. Google does not associate the IP address with any other data that Google possesses, or attempt to link an IP address to a user’s identity. Google may also disclose this information to third parties if required by law or if these third parties process the aforementioned information on behalf of Google.
For further information, please use the link below:
https://policies.google.com/technologies/partner-sites?hl=en
Users can selectively disable the action of Google Analytics by installing the opt-out component supplied by Google on their browser. For instructions on disabling the action of Google Analytics, go to:
https://tools.google.com/dlpage/gaoptout?hl=en
 
The Zenit website does not use profiling cookies.
 
How to delete cookies
Almost all web browsers are set by default to accept first-party cookies automatically. However, users can modify the preset configuration using their browser settings, although disabling, blocking or deleting cookies could preclude optimal use of the website or some of its areas. The way in which cookies are managed depends on the type of browser used and often its specific release. Normally, however, users will need to access the browser’s Settings and modify the preset rules, deciding which types of cookies to disable and/or which existing ones to remove. Detailed information on the cookie setting configuration procedure can be found in the help pages for the browser used (generally accessible from a PC using the F1 key, or by clicking the question-mark icon usually provided inside the browser itself). The deletion instructions for the main browsers are also available online, on their respective producers’ websites .
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2. PROCESSING PROCEDURES

Personal data are processed using automated tools (e.g. using electronic procedures and media) and/or manually (e.g. on paper media) for the time strictly necessary to achieve the purposes of which they were collected, and, in all cases, in compliance with the relevant legal requirements.

The data will also be processed with the application of organisational and processing principles strictly correlated to the said purposes, and in all cases in a manner which guarantees the security, integrity and confidentiality of the data in accordance with the organisational, physical and logical measures required by the relevant legislation.
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3. OPTIONAL NATURE OF PROVIDING DATA

Except as specified above for navigation data and cookies, visitors are free to decide whether or not to supply their personal data, for example in the case of requests for information or contacts sent by email, or requests to access freely chosen services, utilities and applications. Failure to supply data may make it impossible to provide the service requested and may preclude Zenit Italia S.r.l. from fulfilling its contractual obligations.
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4. DATA CONTROLLER, DATA PROCESSOR AND CATEGORIES OF PERSONS IN CHARGE OF DATA PROCESSING

The Data Controller is:
Zenit Italia S.r.l. a socio unico
with registered office in:
Via dell’Industria n. 11  – 41018 S. Cesario Sul Panaro (MO)-Italy .

Data processing related to this site’s web services is only performed by technical staff in charge of the processing.
As well as the Data Processor’s employees, some personal data processing operations may also be carried out by third parties, which the company assigns to manage/maintain the website. In this event, these entities will be designated as Data Processors.
Pursuant to Art. 4 of Regulation (EU) 2016/679, the data controller hereby informs all those concerned that, pursuant to Art. 13 of the said regulation, during the conduct of its business it will process personal data manually and/or with the aid of digital media for the purposes already listed above.

Information concerning the data processors can easily be obtained by sending an email to info.it@zenit.com or writing to Zenit Italia S.r.l. a socio unico Via dell’Industria n. 11 – 41018 S. Cesario Sul Panaro (Modena) - Italy
The data will not be disseminated.
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5. RIGHTS OF DATA SUBJECTS

The subjects to whom personal data refer are entitled, at any time, to obtain confirmation as to whether or not these data exist and to be informed of their contents and origin, check their accuracy or request their supplementation, updating or rectification (Art. 7 of Italian Legislative Decree n. 196/2003). Pursuant to the same article of law, data subjects are entitled to request the erasure, anonymization or freezing of data relating to them held in breach of the law, and to object to their use, on legitimate grounds. Pursuant to Art. 13 of the EU GDPR, data subjects are always entitled to be informed of the identity and the contact details of the data controller and, where applicable, of the controller’s representative, the contact details of the data protection officer, the purposes of the processing for which the personal data are intended as well as the legal basis for the processing, the legitimate interests pursued by the data controller or by a third party designated as data controller, the recipients or categories of recipients of the personal data, if any, the period for which the personal data will be stored, and the fact that the controller intends to transfer personal data to a third country or international organisation.

Pursuant to Art. 13 of EU GDPR 679/2016, at any time data subjects may also exercise the right to:
  • access the personal data;
  • obtain their rectification or erasure or restriction of the processing of the data which refer to them;
  • object to the processing of the data;
  • use the portability of the data;
  • withdraw consent at any moment, without prejudice to the lawfulness of the processing based on the consent given prior to the withdrawal;
  • lodge a complaint with a supervisory authority, for Italy the Data Protection Authority;
  • to be informed whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;
  • to be informed of the existence of automated decision-making, including profiling, and, in those cases, to receive meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject
Pursuant to Art. 14 EU GDPR in the event that the data have not been obtained from the data subject:
1
The Data Controller Zenit Italia S.r.l. a socio unico shall provide the data subject with the following information:
  1. the identity and the contact details of the controller and, where applicable, of the controller’s representative;
  2. the contact details of the data protection officer, where applicable
  3. the purposes of the processing for which the personal data are intended as well as the legal basis for the processing
  4. the categories of personal data concerned
  5. the recipients or categories of recipients of the personal data, if any
  6. where applicable, that the controller intends to transfer personal data to a recipient in a third country or international organisation and the existence or absence of an adequacy decision by the European Commission, or in the necessary cases, reference to the appropriate or suitable safeguards and the means to obtain a copy of them or where they have been made available.
2
In addition to the information in section 1, the Data Controller Zenit Italia S.r.l. a socio unico shall provide the data subject with the following information necessary to guarantee fair, transparent processing in relation to the data subject:
  1. the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period
  2. the legitimate interests pursued by the controller or by a third party
  3. the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability
  4. the existence of the right to withdraw consent at any moment, without prejudice to the lawfulness of the processing based on the consent prior to the withdrawal
  5. the right to lodge a complaint with a supervisory authority, for Italy the Data Protection Authority
  6. from which source the personal data originate, and if applicable, whether it came from publicly accessible sources
  7. the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject
3
The Data Controller Zenit Italia S.r.l. a socio unico supplies the information referred to in sections 1 and 2:
  1. within a reasonable period after obtaining the personal data, but at the latest within one month, having regard to the specific circumstances in which the personal data are processed;
  2. if the personal data are to be used for communication with the data subject, at the latest at the time of the first communication to that data subject; or if a disclosure to another recipient is envisaged, at the latest when the personal data are first disclosed.
4
Where the controller intends to further process the personal data for a purpose other than that for which the personal data were obtained, the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information as referred to in paragraph 2.

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