Latest Update: 2022 August, 30
Table of Contents
Privacy Policy
Versione del 08-2021
In compliance with the provisions of the European Regulation 2016/679, also known as EU GDPR (General Data Protection Regulation) regarding personal data, we are hereinafter to provide the User with the necessary information regarding the processing of your personal data.
This directive is not valid for other websites that may be consulted through links on the websites in the domain of the Owner, who is not to be considered in any way responsible for third parties websites.
This is an information that is provided pursuant to article 13 of EU GDPR Regulation (General Data Protection Regulation for personal data, 2016/679) and is also inspired by the provisions of Directive 2002/58/EC, as updated by the Directive 2009/136/EC, in matter of cookies, as well as the provisions set out by the Italian Personal Data Protection Authority (2014/05/08).
1. Data Controller
In pursuing articles 4 and 24 of EU GDPR 2016/679, Data Controller is PENNELLIFICIO OMEGA S.p.A. Via Larga 13, 40138 Bologna Italy VAT No. 02116679379 (hereinafter Data Controller) which carries out the treatments described in this policy on www.omegabrush.com website (hereinafter referred to as the Website).
2. Types of Processed Data
Personal data
Any information concerning an identified or identifiable natural person (hereinafter referred to as the data subject); the identifiable natural person shall be deemed to be the natural person who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location data, an online identifier or one or more characteristic elements of its physical, physiological, genetic, psychological, economic, cultural or social identity (C26, C27, C30).
Browsing data
The computer systems and software procedures used to operate this website acquire, during their normal operations, some personal data whose transmission is implicit in the use of the Internet communication protocols.
This information is not collected to be associated with identified data subjects, but, by their very nature, could, through processing and association with data held by third parties, allow Users to be identified.
This category of data includes IP addresses or domain names of computers used by Users who connect to the Website, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the User’s operating system and computer environment.
Legal defence
The User’s Personal Data may be used for the defense in court by the Owner or in the stages leading to its possible establishment, from abuse in the use of the same defense or the related services by the User. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Website.
Maintenance
The User’s Personal Data may be processed with additional methods and purposes related to maintenance.
Voluntarily provided data
The optional, explicit and voluntary sending of e-mails to the addresses indicated on the Website and/or the compilation of data collection forms, involves the subsequent acquisition of the sender’s address, necessary to respond to requests, and any other personal data entered.
Specific directives
Specific directives may be presented on the Website pages in relation to particular services or User’s data processing.
Cookies
See the cookies policy in the specific paragraph of this policy.
3. Purpose and legal basis of data processing
The User’s personal data provided will be processed in compliance with the conditions of lawfulness pursuant to article 6f) EU GDPR 2016/679 for the following purposes, until opposition:
- browsing the Website;
- any contact and information request by the User;
- administrative and accounting activities in general. For the purposes of applying the provisions on the protection of personal data, the processing carried out for administrative and accounting purposes shall be those related to the performance of activities of organisational, administrative, financial and accounting nature, regardless of the processed data nature. In particular, the internal organisational activities, those functional to the fulfillment of contractual and pre-contractual obligations, information activities pursue these purposes.
- marketing activities, including, for example, the sending of regular news on promotional or customized offers. The data subject can unsubscribe from marketing communications at any time quickly and easily by clicking on the “Unsubscribe” link in each newsletter.
The processing of data with regard to the purposes in question is based on Article 6, paragraph 1, letter f): (recital 47), having regard to the User’s reasonable expectations at the time and in the context of the collection of the personal data that processing for that purpose may take place.
4. Recipients or categories of data recipients
User’s data, which is the subject of processing, will not be disclosed except within the limits expressed in the following statement of consent and may be disclosed to contractually related to companies abroad within the European Union, in accordance with and within the limits set out in art. 44 and following of EU GDPR 2016/679, in order to comply with contracts or related purposes.
Data may be communicated to third parties belonging to the following categories:
- subjects providing services for the management of the used information system and telecommunications networks (including e-mail);
- firms or companies in the context of assistance and consultancy;
- competent authorities for compliance with legal obligations and/or provisions of public institutions on request.
Subjects belonging to the aforementioned categories perform the function of Data Processor, and/or as natural persons acting under the authority of the Data Controller and the Data Processor (article 29 of EU GDPR 2016/679), for the purposes listed above or operate in total autonomy as separate Data Controllers. The list of designated Data Processors is constantly updated and available at the headquarters of the Data Controller. Any further communication or dissemination will take place only with your explicit consent.
5. Data transfer to third countries and/or international organisations and safeguards
The personal data provided, at present, will not be transferred to countries outside the EU or international organisations.
6. Data retention period or relevant criteria
The data processing will be carried out in automated and/or manual form, with methods and tools aimed at ensuring maximum security and confidentiality, by subjects specifically appointed for this purpose. Data will be kept for a period not exceeding the purposes for which they were collected and subsequently processed. To be precise:
- browsing the Website (session);
- any contact request, with the sending of information requested by the User (max. 12 months);
- administrative and accounting activities in general (10 years or a different term provided by law);
- marketing activities (max. 10 years).
7. Nature of the provision
Apart from what is specified for navigation data, the User is free to provide personal data in the dedicated areas on the Website. A failure to provide personal data may preclude from providing the services offered on the Website by the Data Controller.
8. Data subject’s rights
The user can assert their rights as expressed by the EU GDPR 2016/679, by contacting the Data Controller, filling out the template for Exercising the Rights of the User and sending it to the e-mail address privacy@omegabrush.com or by mail to the registered office of the aforementioned Data Controller. In particular, these rights include: the right to obtain confirmation whether or not your personal data is being processed, and, if so, the right to access such data and other information, such as: the type of personal data; the recipients or categories of data recipients; the retention period of the data or the criteria used to determine it; the right to request rectification, erasure, restriction of processing of personal data; the right to object to data processing; the right to lodge a complaint with the supervisory authority; if data are not collected from the data subject, all information about their origin; the existence of an automated decision-making process (also profiling ex. article 22 EU GDPR); the necessary safeguards in case of transfer of data to a third countries or international organisations ex. articles 44 EU GDPR and following; the right to obtain a copy of the personal data being processed.
If the User shall contact the Data Controller, they should provide the e-mail address, name, address and/ or telephone numbers, in order to allow the correct management of the request.
Cookie Policy
This page describes how to manage the Website with reference to cookies and the related processing of personal data of Users browsing it.
Data Controller is PENNELLIFICIO OMEGA SPA Via Larga, 13 (pursuant to Articles 15-22 of EU GDPR 2016/679).
Cookies are small text files that the Website send to the User’s terminal (desktop, tablet, smartphone, notebook), where they are stored, and then be retransmitted to the same Website on the next visit. They are used to perform computer authentication, session monitoring and storage of site information (without the use of “technical” cookies some operations would be very complex or impossible to perform). While browsing a site, the User can also receive on his terminal cookies that are sent from different sites or web servers (aka “third parties”), on which may reside some elements (such as, for example, images, maps, sounds, specific links to pages of other domains) on the site that the same is visiting.
Cookies are divided into two categories: technical cookies and profiling cookies.
TECHNICAL COOKIES
Technical cookies allow easy use of the site and easier retrieval of information, simplifying the connection and transmission of data between the User and the Website.
We use:
- navigation or session cookies: they ensure normal browsing and use of the Website allowing, for example, the saving of the User’s preferences and session management;
- functionality cookies: they allow normal browsing according to a set of selected criteria, for example, the selection of a box or the customization of a page in order to improve the service rendered.
These types of cookies can be both temporary and persistent depending on the need for use.
The User can authorize, restrict or block cookies through their browser settings, however, if the User sets their device to reject these cookies, some services of the site may not be displayed properly or may not work optimally. The User’s cookie preference expressed in the proposed banner at the first visit to the Website, is tracked by a technical cookie that can not be deleted as it is strictly necessary to comply with the cookie legislation.
PROFILING COOKIES
Profiling cookies. These are permanent cookies used to identify (anonymously and not) theUser’s preferences and improve his browsing experience.
THE WEBSITE COOKIES
Activities strictly necessary to ensure the functioning of the Site
WordPress CMS
CMS cookies have the exclusive function of recognizing users who have logged in, allowing navigation of the site even in restricted areas.
The Site also installs:
- functionality cookies to store which cookies the visitor users accept on their first visit or in their subsequent navigation
- security cookies to provide protection against hackers
- security cookies to save preferences relating to the language selected for navigation on the site.
Third Party Tracking Tools
OVH Hosting
OVHcloud is a hosting and backend service provided by OVH Srl.
Provider:
OVH Srl
Personal data processed:
Usage data
Place of processing: Italy
Privacy Policy: https://www.ovhcloud.com/en/
Google Analytics Version GA4
The Site uses this type of web analysis service provided by Google Inc. to obtain aggregate statistical information useful for evaluating the use of the website and the activities carried out by the visitors. Google stores the information collected by its cookies on servers that can also be located in the United States. Google reserves the right to transfer the information collected with its cookies to third parties where this is required by law or where the third party processes information on its behalf.
How GA4 works
Google Analytics 4 uses a measurement model based on events and parameters, no longer on sessions and pageviews as in the previous version (Universal Analytics).
An event allows you to measure any user interaction on the Site.
Events can be collected automatically: parameters that are collected by default or those customized, that is, created according to the requirements of the site.
Some examples are:
- language
- URL of the page
- URL of the previous page
- page title
- user screen resolution
Advanced measurement events allow you to measure interactions with Site content.
Some examples are:
- scroll
- click out
- search on the Site
- videos engagement
There are also events recommended by Google itself, to help measure additional behaviors, and therefore functionalities, to generate more detailed analysis reports.
Pending the additional technical security measures required by the Data Protection Authorities, to date – August 2022 – not yet identified, to avoid their possible transfer to the United States, the Italian Guarantor requires that these measures be directly identified by the Data Controllers.
We have therefore decided to continue to use the service offered by Google by limiting the collection of data, even knowing that we will face a loss of data that is important and necessary for us in order to offer our Users our best service.
So far we have carried out the following actions:
- IP address anonymization, already applied manually with the previous version, now by default.
We emphasize that GA4 uses the IP address only at the time of collection to determine the location information and deletes it before the data is recorded on a server. - preventive blocking of GA4 scripts
- deactivation of Google Signals based on the geographical area
- deactivation of the collection of granular data, such as city, latitude, longitude, device and screen resolution
Provider:
Google LLC (United States)
Google Ireland Limited (Ireland)
Purpose:
Statistics
Personal data processed:
Aggregated data such as
- usage data
- number of users
- session statistics
- tracking tools
Description:
Google Analytics is a statistics service provided by Google LLC or by Google Ireland Limited, depending on how Google handles data processing. Google uses the Personal Data collected for the purpose of tracking and examining the use of this Site, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the advertisements of its own advertising network.
Place of processing: Ireland
Privacy Policy: https://policies.google.com/privacy
Opt Out: https://tools.google.com/dlpage/gaoptout?hl=en
Place of processing: United States
Privacy Policy: https://policies.google.com/privacy
Opt Out: https://tools.google.com/dlpage/gaoptout?hl=en
Third Parties Cookies
While visiting the Site the User may notice some cookies not related to the Website. When browsing a page that contains content from, for example, Google Maps, Vimeo or Youtube, cookies from these websites may appear. The Site is not able to control the dissemination of these cookies.
For more information on these cookies, the User shall consult the relevant websites.
- Google Maps
- Place of processing: United States
- Privacy policy: https://policies.google.com/privacy?hl=en
- YouTube
- Place of processing: United States
- Privacy policy: https://policies.google.com/privacy?hl=en
- Vimeo
- Place of processing: United States
- Privacy policy: https://vimeo.com/privacy/
- Google ReCaptcha
- Place of Processing: United States
- Privacy Policy: https://policies.google.com/privacy
- Google ReCaptcha
- Place of Processing: Ireland
- Privacy Policy: https://policies.google.com/privacy
Sharing cookies and social networks
The Website sometimes uses Youtube and Vimeo videos, social content from Twitter, Facebook, Google+ and in general embeddable content from other platforms. The Website can not control the cookies that these third-party sites provide. It is recommended to inquire directly at each third party to have more control over these cookies. Here are some useful links to the cookie policies of the mentioned third parties:
- Facebook
- Place of processing: United States
- Privacy policy: https://www.facebook.com/help/cookies/
- Twitter
- Place of processing: United States
- Privacy policy: https://twitter.com/privacy?lang=en
- Instagram
- Place of processing: United States
- Privacy policy: https://about.instagram.com/it-it/safety
Other activities that involve the use of Tracking Tools
Provider:
This site
Purpose:
Contact the user
Personal data processed:
- First name
- Last name
- Company name
- Country
- Website
Description:
By filling in the contact form with their data, the User consents to their use to respond to requests for information, quotes, or any other nature indicated by the form header.
How to control cookies
The User can control and/or verify cookies as they wish – to learn more, go to aboutcookies.org. The User can delete cookies already present on their computer and set almost all browsers in order to block their installation. If the User chooses this option, they will need to manually change some preferences each time they visit the Website as some services or features may thus not be available.
COOKIES AND BROWSER SETTINGS
In this section the User will find information to disable cookies on their browser. Disabling cookies some parts of the Website may not work properly. If your browser is not in the list below, please consult the instructions on your browser regarding the management of cookies.
Internet Explorer version 6 or more recent
- Select “Tools” in your browser bar
- Select “Internet Options”
- Select “Privacy” and then click on “Advanced”
- Select “Replace automatic cookie management”
- Disable “Cookies of the displayed websites” by selecting “Block”
- Disable “Third parties cookies” by selecting “Block”
- Disable “Session cookies” deselecting “Always accept session cookies”
- Click on “OK”
Firefox version 9 or more recent
- Select “Tools” in your browser bar
- Select “Options”
- Select “Privacy”
- In “History” choose from the drop-down menu the option “use custom settings”
- Disable cookies by deselecting the item “Accept cookies from sites”
- Click on “OK”
Google Chrome version 24 or more recent
- Select “Chrome menu” in your browser bar
- Select “Settings”
- Select “Show advanced setting”
- In the “Privacy” section click on “Content setting”
- Disable all cookies by selecting “Prevent sites from setting data” and “Block third-party cookies and site data”
- Click on “OK”