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Introduction
Sipcam Benelux takes the processing of the personal data of visitors to its website www.sipcam.com/bx/en (hereinafter the “Website”) very seriously, and undertakes to act in accordance with the provisions Article 13 of Regulation (EU) 679/2016 (the General Data Protection Regulation – subsequently referred to as the “GDPR”).
By this policy statement, Sipcam wishes to provide users with information on the processing of their personal data while browsing the Website and using the various functions and services made available within it.A) Data Controller
The Data Controller of your personal data is Sipcam Benelux, with headquarters at Rue Théodore De Cuyper, 100, B-1200 Brussels, Woluwe-Saint-Lambert, Belgium, VAT No. BE 0842.152.119 (hereinafter the “Data Controller”).
You may contact the Data Controller with any questions, requests or clarifications relating to this Policy or the processing of your personal data in general at the following addresses:email address (indicating “Privacy” in the subject line): privacy@sipcambnl.com
B) What data we process
When you access the Website, your browser will transfer certain data to our web server. This is necessary for technical reasons and to provide you with the information you request. In particular, the Data Controller processes the following categories of personal data during your browsing of the Website and use of its functions/services:
information and data on your browsing on the Site and the devices used to browse the Website and use its functions and services (for example, information on the pages and sections of the Website visited, your actions on the Website, the time spent on individual pages and sections of the Website, your IP address, browser used, type of device used, and information from cookies or similar tools sent from the pages of the Website);
if you intend to contact Sipcam by email at the addresses indicated in the “Contacts/Locations” section of the Website (http://www.sipcamitalia.it/it/sedi), the personal data and information necessary to manage your communication (such as your name, surname, email address for any reply, as well as the content of the information or requests you send).
The personal data indicated in point a) is collected automatically during your browsing on the Website. This data is not collected and processed in order to be traced back to identified physical persons. However, by its very nature it could, through processing and cross-referencing with other data (possibly held by third parties), enable the identification of natural persons.
Personal data in all other categories is provided directly and voluntarily by you.
C) What happens if Personal Data is not provided
The processing of personal data indicated in point a) of section B) above is necessary in order for the Data Controller to provide you with the best possible browsing experience, and to ensure you can access all functions and services provided through the Website. However, the processing of such personal data can be limited through the use of certain functionalities made available on the Website (with particular reference to the transmission of cookies or similar tools - on this point, see the Website's cookie policy) or through your navigation device or browser/application. In this case, your browsing on the Website may be restricted and some of its functions/services may be inaccessible
The processing of the personal data indicated in category d) of section B) above is necessary in order to use the services and functions of the Website.
If the said data is not provided, it will not be possible for the Data Controller to provide Website functions and services that you have requested.
D) Purposes of processing and relevant legal basis
Your personal data will be processed for the following purposes, and on the following legal bases.
Purpose | Legal basis |
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Enabling browsing on the Website, access to its pages and sections, use of its functions and services | Processing necessary on a contractual basis (Article 6(i)(b) of the GDPR) |
Enabling your enrolment/registration in the Reserved Area and use of the services offered to registered users | Processing necessary on a contractual basis (Article 6(i)(b) of the GDPR) |
Enabling the Data Controller to respond to requests by administrative, jurisdictional or public security authorities (pursuant to, by way of example, but not limited to Article 210 of the Italian Code of Civil Procedure and 248 of the Italian Code of Civil Procedure) | Processing necessary for compliance with legal obligations to which the Data Controller is subject (Article 6(i)(c) of the GDPR) |
Responding to your requests for contact or information through interaction with the “Locations” section of the Site | Processing necessary for the pursuit of the legitimate interests of the Data Controller (Article 6(i)(f) of the GDPR) |
Enable the Data Controller to ascertain, exercise or defend its rights in or out of court, or in the event of any claim or dispute (brought by you, the Data Controller, third parties, or by judicial or administrative authorities) | Processing necessary for the pursuit of the legitimate interests of the Data Controller (Article 6(i)(f) of the GDPR) |
Monitor the functioning of the Website, making any necessary interventions and updates in order to provide a better browsing experience | Processing necessary for the pursuit of the legitimate interests of the Data Controller (Article 6(i)(f) of the GDPR) |
With specific reference to the purposes of processing indicated in points 4, 5 and 6., please note as follows:
Purpose | Legitimate interests pursued |
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Responding to your requests for contact or information through interaction with the “Locations” section of the Site | The interest of the Data Controller in following up requests for contact by users of the Website |
Enable the Data Controller to ascertain, exercise or defend its rights in or out of court, or in the event of any claim or dispute (brought by you, the Data Controller, third parties, or by judicial or administrative authorities) | The Data Controller’s interest in protecting its rights in the event of disputes |
Monitor the functioning of the Website, making any necessary interventions and updates in order to provide a better browsing experience | The Data Controller’s interest in improving the Website to provide users a better browsing experience |
If you require further or more specific information on the Data Controller's assessment of the balance between its legitimate interests and the interests or fundamental rights and freedoms of data subjects, please contact the Data Controller at the addresses indicated in Section A).
E) Who can access processed personal data
In order to fulfil the purposes indicated above, your personal data will also be processed by third parties other than the Data Controller.
These entities will process your personal data on behalf of the Data Controller (therefore in the capacity of data processors), and as autonomous data controllers, following specific notification from the Data Controller.
In particular, the following categories of recipients will process your personal data:
service providers necessary for the proper functioning of the Website and its functions/services (e.g. ICT service providers, hosting service providers, providers of IT platforms and applications);
judicial, administrative and/or public security authorities, in accordance with legal provisions, for the purpose of investigating and prosecuting offences, preventing and protecting against risks or threats to public security and order, and for any reason related to the protection of the rights and freedoms of individuals;
communication and marketing service providers (e.g. communication agencies);
companies belonging to the corporate group to which the Data Controller belongs (parent companies, subsidiaries, associates and affiliates), to enable the provision of some of the Website's services.
F) How long we keep your personal data
Your personal data will be stored for a period that varies according to the type and purpose of processing. The retention periods for personal data are as follows:
data and information on contacts with the Data Controller: it will be stored until your requests are processed and fulfilled;
If at the end of the said period, personal data must be processed for specific purposes (e.g. to protect the rights of the Data Controller in the context of a dispute), it will be retained until such purposes have been fulfilled (e.g. until the dispute is resolved).
At the end of the retention periods indicated above, your personal data will be deleted, or otherwise rendered unintelligible by the Data Controller.
G) Processing of personal data by automated decision-making
No provision is made for the processing of your personal data by automated decision-making processes (including profiling pursuant to Article 22, paragraphs 1 and 4, of the GDPR), except as provided for in the Cookie Policy.
H) Users’ rights
You are entitled to request access to your personal data from the Controller, pursuant to Article 15 of the GDPR.
By exercising the right of access, you may request information on:
- the purpose of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data has or will be communicated, in particular if they are recipients in third countries or international organisations;
- where possible, the proposed period for which the personal data will be retained or, where this is not possible, the criteria used to determine that period;
- the existence of a right to request the Data Controller to correct or erase personal data, to limit the processing of personal data concerning you, or to object to its processing;
- the right to lodge a complaint with a supervisory authority,
- where the personal data has not been collected from you, all available information on its origin;
- the existence of an automated decision-making process, including profiling as provided for in Article 22, paragraphs 1 and 4 of the GDPR and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences for you of such processing.
You are also guaranteed the following rights:
- the right to revoke the consent given for the transmission of cookies to your terminal equipment while browsing the Website, as described in greater detail in the Cookie Policy;
- the right to obtain from the Data Controller the rectification of inaccurate personal data, or the supplement of incomplete personal data, as provided in Article 16 of the GDPR;
- the right to obtain from the Data Controller the deletion of personal data, as provided in Article 17 of the GDPR. The exercise of this right may not be guaranteed by the Data Controller (or the Controller may respond to requests only partially) insofar as the processing of personal data subject to the request for erasure is required in order to comply with legal obligations or for the establishment, exercise or defence legal claims;
- the right to obtain from the Data Controller a restriction on processing, as provided in Article 18 of the GDPR;
- within the limits established in the legislation, the right to obtain from the Data Controller the portability of personal data processed following consent, or on a contractual basis, as provided in Article 6, paragraph 1, letters a) and b) of the GDPR. If you exercise this right, the Data Controller will be responsible for providing you with all data concerning you that was obtained with your consent or in execution of a contractual obligation, in a structured and interoperable format. Where technically possible, such personal data may also be transferred, in the same manner, to third parties selected by you and indicated in a specific request;
- the right to object to the processing of your personal data as provided in Article 21 of the GDPR, unless the Data Controller demonstrates, on receipt of a request to this effect, that there are compelling legitimate grounds to proceed with the processing that override your interests, rights and freedoms, or for the establishment, exercise or defence of a legal claim.
Any requests as indicated above must be made to the addresses indicated in section A).
The Data Controller will respond to any such requests without undue delay.
If you do not receive a reply, or receive a negative, untimely or unsatisfactory reply to your request, or in any case it is believed that the Data Controller is processing your data in an unlawful or non-transparent, you may refer the matter to a supervisory authority.
If you are an Italian citizen, usually reside or work in Italy, or believe that a potential violation by the Data Controller involving the processing of your personal data has taken place in Italy, you may contact the Italian Data Protection Authority – www.garanteprivacy.it – to obtain adequate protection of your rights.
If you are a citizen of another EU Member State, usually reside or work in in another EU Member State, or believe that a potential violation by the Data Controller involving the processing of your personal data has taken place in another EU Member State, you can visit the following web page http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm for information on the competent supervisory authority.
I) Amendments and updates to the Policy Statement
We may update our privacy policy statements from time to time. The updates will be published on our Website. Any changes take effect after they are posted on our website. We therefore recommend that you regularly consult the policy statement section of the website in order to be informed of any updates.
COOKIE POLICY
What are cookies?
This site uses so-called "cookies". Cookies are small text files stored in the memory of your terminal device via your browser. They store certain information (e.g., your preferred language or site settings) which your browser may (depending on the lifetime of the cookie) send back to us on your next visit to our Website.
What cookies do we use?
We distinguish between two categories of cookies: (1) technical cookies, without which the functionality of our website would be reduced, and (2) optional cookies, used for site analysis and marketing purposes.
Technical cookies do not require the user’s consent and are installed automatically upon accessing the site.
Cookies for which user consent is required
Cookies other than those indicated above are installed or activated only after the express consent of the user the first time he or she visits the website.
General consent may be given by selecting the consent options contained in the Short Cookie Policy Statement (or even by continuing to browse the website), or may be withheld or given selectively, according to the instructions below.
Cookies managed by third parties
The third party websites that install cookies on your device while you are browsing this site are set out in this section, along with links to privacy notices and consent forms for each.
Google Analytics – http://www.google.it/intl/it/analytics: this website uses a web analytics service provided by Google, Inc. (“Google”), in order to evaluate the performance of the site and the traffic on it. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored on Google servers in the United States. Google will use this information for the purpose of tracking and evaluating your use of the website, compiling reports on website activity for website operators and providing other services related to website activity and internet usage. Google may also transfer this information to third parties where required by law to do so, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
Link to privacy policy: https://support.google.com/analytics/answer/6004245
Link to installed cookies description page: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage;
Link to a download page for a tool to disable the installation of such cookies: https://tools.google.com/dlpage/gaoptout
Changing browser settings
It is also possible to disable the receipt of cookies through the settings of the user’s browser.
In most browsers, settings can be changed as follows:
select “Options” or “Preferences” in the “Tools” menu or the “View” or “Edit” menu;
Select “Privacy” or “Protection” or “Download files” and select your preferred settings.
The following list sets out direct links to the cookie setup screen of the main browsers:
Microsoft Internet Explorer: http://windows.microsoft.com/it-it/internet-explorer/delete-manage-cookies#ie=ie-10
Mozilla Firefox: https://support.mozilla.org/it/kb/Manage%20of%20cookies
Google Chrome: https://support.google.com/chrome/answer/95647?hl=it & ref_topic=14666
Apple Safari: https://support.apple.com/kb/PH19214?viewlocale=it_IT & locale=it_IT
Apple Safari (mobile devices): https://support.apple.com/it-it/HT201265
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