Privacy Policy

PERSONAL DATA PROCESSING AND PROTECTION

HTS S.r.l., with registered office at Via Cubito 39, 10077, Ceretta di San Maurizio Canavese (TO), VAT No. 11869580016, as owner of the website www.hts-srl.it (hereinafter the “Website” and the “Services“), hereby provides this privacy notice pursuant to Article 13 of EU Regulation 2016/679 of 27 April 2016 “GDPR” (hereinafter the “Regulation” or the “Applicable Legislation”).

This Privacy Policy informs you of the following:

• Who the Data Controller and the Data Protection Officer are
• How data is collected
• What types of data are processed
• Purposes of processing
• Methods of processing
• Data retention periods
• Scope of data communication and disclosure
• Rights of data subjects

This notice applies solely to this Website and not to any other websites, portals, sections, pages or spaces linked via hyperlinks; for those, please refer to their respective privacy notices.

WHO IS THE DATA CONTROLLER

The Data Controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

The Data Controller for personal data on this Website is:

HTS S.r.l. (hereinafter “HTS”) Via Cubito 39, 10077, Ceretta di San Maurizio Canavese (TO)

You may contact us by email at: info@hts-srl.it

APPOINTMENT OF THE DATA PROTECTION OFFICER (DPO)

HTS has appointed Mr Nicola Lioce as Data Protection Officer in accordance with Articles 37 et seq. of the GDPR. He may be contacted at the email address: info@hts-srl.it

HOW WE COLLECT YOUR DATA

We collect personal data when users share it with us, specifically when:

• the User completes a contact form on our Website
• the User requests information about a product or our Services
• the User applies for a job by submitting their CV
• the User communicates with us by sending an email or providing their details by telephone or fax

Additional data is automatically recorded by our IT systems during Website visits. This data consists primarily of technical information (e.g. web browser, operating system or time of access to the Website).

TYPES OF DATA PROCESSED AND PURPOSES

Users’ personal data will be lawfully processed by HTS pursuant to Article 6 of the Regulation. The following types of data are processed:

a) Data voluntarily provided by users

1. Contact Form

Where requests are submitted via our contact form, the information entered in the form and all contact details provided therein will be stored by us for the purpose of handling the User’s request and in the event we have further questions. We will not share this information without the User’s consent.
The processing of data entered in the contact form is carried out exclusively on the basis of the User’s consent (Article 6(1)(a) GDPR). The User has the right to withdraw any consent previously given at any time by sending us an informal notification by email. This does not affect the lawfulness of any data collection carried out prior to the withdrawal.
Information entered in the contact form will remain in our records until the User requests its deletion, withdraws consent to its storage, or the purpose for which the information is stored no longer exists (e.g. after we have concluded our response to the request). This is without prejudice to any different data retention periods required by law.
We will never request health data or, in general, special categories of personal data as referred to in Article 9 of the GDPR (sensitive, biometric, genetic or criminal data).

2. Enquiries by Email, Telephone or Fax

If the User contacts us by email, telephone or fax, their request — including all related personal data (first name, last name, content of the request) — will be processed and stored by us for the purpose of handling that request. We do not transmit this data without the User’s consent.
The processing of such data is based on Article 6(1)(b) GDPR where the request relates to the performance of a contract or is necessary in order to take pre-contractual steps. In all other cases, processing is based on the User’s consent (Article 6(1)(a) GDPR) and/or on the basis of legitimate interest (Article 6(1)(f) GDPR), as we have a legitimate interest in the efficient handling of enquiries addressed to us.
Personal data provided by the User by email, telephone or fax will remain in our records until the User requests its deletion, withdraws consent to its storage, or the purpose for which the information is stored no longer exists (e.g. after we have concluded our response to the request). This is without prejudice to any different data retention periods required by law.
We will never request health data or, in general, special categories of personal data as referred to in Article 9 of the GDPR (sensitive, biometric, genetic or criminal data).

1. b) Browsing Data (Server Log Files)

The provider of this Website automatically collects and stores information contained in so-called server log files, which your browser transmits to us automatically. This information includes:

• browser type and version;
• operating system used
• webpage visited
• time of the server request
• IP address

Such data will not be associated with any other personal data.

The aforementioned personal data is collected on the basis of Article 6(1)(f) GDPR. The website operator has a legitimate interest in the correct and optimised functioning of the website, for which purpose the collection of server log files is necessary.

COOKIES

This Website uses cookies to improve your browsing experience.
Cookies are small text files that websites visited by the user send directly to their device (usually the browser), where they are stored and subsequently retransmitted to the same websites on the user’s next visit (so-called first-party cookies). While browsing a website, the user may also receive on their device cookies from different websites or web servers (so-called third-party cookies).
Cookies may be limited to a single browsing session (so-called session cookies), in which case they are automatically deactivated when the user closes the browser; or they may have a predetermined expiry date, in which case they remain stored and active on your hard drive until that expiry date, continuing to collect information across different browsing sessions (so-called persistent cookies).
Cookies serve a number of functions. Some are necessary to allow you to browse the website and use its features (so-called technical cookies). Others are used to obtain statistical information, in aggregated or non-aggregated form, on the number of users accessing the Website and on how the Website is used (so-called tracking or analytical cookies). Others are used to build a consumer profile and display advertisements on the Website that may be of interest to you, based on your preferences and browsing habits (so-called profiling cookies).
For further details on these different categories of cookies, how they work and how to consent to or prevent their use, please read our Cookie Policy.

METHODS OF PROCESSING

HTS will process Users’ personal data using both manual and electronic tools, with logic strictly related to the purposes themselves and in any event in a manner that ensures the security and confidentiality of the data. However, internet-based data transmissions may, in principle, present security gaps; therefore, absolute protection cannot be guaranteed. For this reason, data subjects are free to transmit their personal data to us by alternative means, e.g. by telephone.

DATA RETENTION PERIODS 

Users’ personal data will be retained for the period strictly necessary to fulfil the purposes described in this Privacy Policy, or as required by law and/or as necessary to protect the civil interests of both Users and the Data Controller.

In particular, HTS undertakes to delete from its systems the data provided:

• data submitted in connection with requests made through the website or customer service: 10 years from the date of submission
• data processed for the execution of a sale and management of services: 10 years from the date of the last purchase or the last interaction with HTS

In any event, HTS undertakes to process data in accordance with the principles of adequacy and data minimisation, verifying on an annual basis the necessity of retaining data for a period no longer than necessary to achieve the purposes for which it was collected and processed.
HTS may retain data in order to comply with regulatory obligations or to establish, exercise or defend legal claims.
Once the purposes for which the data was collected and processed have been fulfilled, HTS will take appropriate measures to anonymise it so as to prevent identification of the data subject, while retaining the option to continue using the data in anonymous form.

SCOPE OF DATA COMMUNICATION AND DISCLOSURE

Users’ personal data may be accessed by employees and/or collaborators of HTS responsible for managing the website and all services connected to the provision of services, including marketing activities. Such parties, who have been duly instructed by HTS pursuant to Article 29 of the Regulation, will process Users’ data exclusively for the purposes set out in this notice and in compliance with the Applicable Legislation.
Users’ personal data may also be accessed by third parties who may process personal data on behalf of HTS as “Data Processors”, including, by way of example, providers of IT and logistical services necessary for the operation of the website and/or services, outsourcing, hosting or cloud computing service providers, and HTS’s professional advisors and consultants.
In addition, personal data may be disclosed to judicial or supervisory authorities, public administrations, bodies and organisations (national and international), in accordance with applicable law and following a formal and legitimate request from such parties.
The personal data collected will not in any event be subject to general dissemination, without prejudice to disclosures made in fulfilment of legal obligations.
Users have the right to obtain a list of any Data Processors appointed by HTS and may submit such a request in the manner described in the following section.

RIGHTS OF DATA SUBJECTS

Users may exercise the rights guaranteed to them under the Applicable Legislation by contacting HTS as follows:

• By sending a registered letter with acknowledgement of receipt to HTS’s registered office
• By sending an email to info@hts-srl.it

HTS will fulfil Users’ requests relating to the processing operations for which it acts as Data Controller.
Pursuant to the Applicable Legislation, HTS informs Users that they have the right to obtain: (i) information on the origin of their personal data; (ii) the purposes and methods of processing; (iii) the logic applied in the case of processing carried out with the aid of electronic tools; (iv) the identification details of the Data Controller and Data Processors; (v) the identity or categories of parties to whom personal data may be communicated or who may become aware of it in their capacity as Data Processors or authorised persons.

Users also have the right to obtain:

1. access to, updating, rectification or, where they have an interest, completion of their data
2. erasure, anonymisation or blocking of data processed in breach of the law, including data whose retention is no longer necessary for the purposes for which it was collected or subsequently processed
3. confirmation that the operations referred to in points 1 and 2 above have been brought to the attention of those to whom the data has been communicated or disclosed, including as regards their content, except where such fulfilment proves impossible or involves a manifestly disproportionate effort relative to the right being protected

Users also have:

1. the right to withdraw consent at any time, where processing is based on their consent
2. where applicable, the right to data portability (the right to receive all personal data concerning them in a structured, commonly used and machine-readable format), the right to restriction of processing and the right to erasure (“right to be forgotten”)
3. the right to object:

• in whole or in part, on legitimate grounds, to the processing of their personal data, even where it is relevant to the purpose of collection
• in whole or in part, to the processing of their personal data for the purpose of sending advertising or direct marketing material, or for the conduct of market research or commercial communications
• at any time, where personal data is processed for direct marketing purposes, to the processing of their data for such purposes, including profiling to the extent that it is connected to such direct marketing
• where they consider that the processing concerning them infringes the Regulation
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4. the right to lodge a complaint with a supervisory authority (in the Member State in which they habitually reside, work, or in which the alleged infringement occurred). The Italian supervisory authority is the Garante per la protezione dei dati personali, with offices at Piazza Venezia 11 – 00187 – Rome (http://www.garanteprivacy.it/).

COPYRIGHT

This Website and all decorative, graphic, printed materials, texts, photographs, packaging and technical specifications (“Content”) contained therein are protected by copyright and are the property of HTS S.r.l. ©. All rights reserved.
No part of this Website or its Content may be reproduced, republished, translated or distributed in any form without the prior written authorisation of the owner, unless the User makes a copy or downloads it to a local hard drive solely for personal, non-commercial use.
Any legally and duly shared copy of the content is made available by the owner exclusively on the condition that the user does not alter or modify such content, nor remove or modify any proprietary notices contained therein.

AMENDMENTS TO THIS PRIVACY POLICY

The Data Controller reserves the right to make changes to this Privacy Policy at any time, informing Users on this page and, where possible, on this website, and where technically and legally feasible, by sending a notification to Users through the contact details held by the Data Controller. Users are therefore invited to consult this page regularly.

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HTS is not responsible for keeping all links contained in this Privacy Policy up to date. Should any link be inactive and/or outdated, Users acknowledge and agree that they must refer directly to the relevant document and/or section of the websites referenced by such link.