Prometeo S.r.l. Unipersonale complies with the EU General Data Protection Regulation 2016/679. Prometeo S.r.l. Unipersonale, as Data Controller, is attentive to your privacy and the security of your personal data as it is aware that privacy is an important aspect for users and visitors of the site. Personal data are essential and are therefore collected and managed by Prometeo S.r.l. Unipersonale with the utmost care and with the adoption of specific measures to keep them safe. The following is the primary information on the processing by Prometeo S.r.l. Unipersonale of your personal data concerning your navigation on the website https://www.hsnetworkmanager.com and use of the services offered on the site. The owner invites you to read this Privacy Policy with particular attention before sending your personal data and to check it periodically as this document is subject to updates and changes that will be highlighted in the appropriate sections of the site. In any case Prometeo S.r.l. Unipersonale invites you to check this Privacy Policy periodically.

The information does not apply to other websites that may be consulted via links on the domain websites of the owner, who is not responsible in any way for the websites of third parties.
The information is also based on Recommendation no. 2/2001 that the European authorities for the protection of personal data, meeting in the Group established by Art. 29 of Directive no. 95/46/EC, adopted on 17 May 2001 to identify certain minimum requirements for the collection of personal data online and, in particular, the methods, timing and nature of the information that data controllers must provide to users when they connect to web pages, regardless of the purpose of the connection, as well as the provisions of Directive 2002/58/EC, as updated by Directive 2009/136/EC, on Cookies and the provision of the Italian Data Protection Authority “Identification of simplified procedures for the provision of information and the acquisition of consent for the use of cookies – 8 May 2014 (Published in the Official Gazette no. 126 of 3 June 2014)” and subsequent clarifications.
Below are some key concepts for clarity:

Personal Data (Art. 4 GDPR): any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, by reference in particular to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity; (Recital 26, C Recital 27, C Recital 3 of the GDPR).
Specific disclosures: specific disclosures may be presented on the pages of the Site in relation to particular services or processing of the Data provided.

Cookies: for more information on the cookies used by this website, see the Cookies Policy at the following link https://www.hsnetworkmanager.com/cookie-policy/.

pROCESSING OWNER

The processing of your personal data collected through the website is carried out by Prometeo S.r.l. Unipersonale – Via Roma, 61 -31010 Fonte (TV) Italy, as Data Controller. The processing operations connected to the web services of this site take place only at the registered office of Prometeo S.r.l. Unipersonale and are carried out only by personnel authorised to their treatment. For any clarification, question or need related to your privacy and the processing of your personal data, you can contact us at any time by sending a request to our Customer Service or by writing to the address of the registered office of Prometeo S.r.l. Unipersonale The owner’s contact email is amministrazione@prometeo.com.

DATA PROTECTION OFFICER

Currently Prometeo S.r.l. Unipersonale does not require the appointment of a DPO. However, the owner has appointed an internal contact person and an external contact person who can be contacted at the head office.

DATA PROCESSED AND PURPOSE OF PROCESSING

Prometeo S.r.l. Unipersonale informs that it will process data that by their nature can be qualified as personal. The personal data that Prometeo S.r.l. Unipersonale processes are those that you provide when you request a quote, place an order, purchase goods and those that we collect while you are browsing or when you use the services offered on the site. The personal data processed through the site are the following and for the following purposes

purpose A:

Browsing data: in the normal operation of the site, computer systems and software procedures acquire certain personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified interests, but by its 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 the names of the computers used by users who connect to the site, addresses in URI (Uniform Resource Identifier) notation, 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 and other parameters relating to the user’s operating system and computer environment.
Common data: in order to access certain services of the site, the provision of common personal data may be required. Such personal data could be, by way of example only, personal details, e-mail address, telephone number.
Special categories of personal data: the processing of data identified by art.9 of Regulation no.679/2016, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership as well as genetic data, biometric data intended to uniquely identify a person, data concerning health or sex life or sexual orientation will be processed with the express and specific consent of the person concerned. Prometeo srl Unipersonale informs that it will not process these data and in the event that you voluntarily provide us with them they will be deleted and not used.

The personal data you provide are processed for the following purposes:

• conclude and execute contracts for the purchase of goods offered on the site or in stores;
• provide you with commercial marketing services such as newsletter subscription, sending newsletters;
• enable you to register on the Site and use the services reserved for registered users;
• manage your requests forwarded to our Customer Service;
• carrying out administrative-accounting activities in general.

These are the processing of personal data connected with the performance of activities of an organisational, administrative, financial and accounting nature. In particular, internal organisational activities, those functional to the fulfilment of contractual and pre-contractual obligations and information activities pursue these purposes. In the aforementioned cases, the processing of your personal data is legitimate insofar as it is necessary to perform a contract concluded with you or to provide you with the service you have expressly requested from us. We also conduct statistical surveys and analysis using aggregate data to understand how users interact with and use the Site, and to improve our offer and services.

Only with your express consent, however, do we process your personal data for:

purpose B) to carry out commercial communication activities
purpose C) for profiling activities, to enable us to process your profile and analyse your consumption habits and choices and purchasing behaviour (if any), in order to improve the commercial offer and services proposed and to enable us to send you communications that may be of interest to you. The processing of personal data may concern customer care activities, consisting in offering personalised services during and after sales and courtesy services. These purposes are also pursued by including them in the company’s CRM.

PERSONS AUTHORISED TO PROCESS DATA

Your personal data are processed by trained and authorised personnel of our company and will not be disclosed. The data may only be communicated to authorised persons, a list of whom can be found at the head office of Prometeo S.r.l. Unipersonale.

DATA RETENTION DURATION

We keep your personal data for a limited period of time depending on the purpose for which it was collected, after which your personal data will be irreversibly deleted or otherwise anonymised. The retention period differs depending on the purpose of the processing. Data collected during the purchase of goods are processed until all administrative and accounting formalities are completed, then stored in accordance with local tax regulations (ten years), while those used to send you our newsletters until you ask us to stop sending them.

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE DATA

The data of a personal nature provided will be communicated to recipients, who will process the data in their capacity as data processors (art. 28 of EU Reg. 2016/679) and/or as authorised persons acting under the authority of the Data Controller and Data Processor (art. 29 of EU Reg. 2016/679), for the purposes listed above. Precisely, the data will be communicated to companies contractually linked to Prometeo S.r.l. Unipersonale, to associated and/or subsidiary companies within the European Union and in non-EU countries, in accordance with the regulations in force, including through management companies. The data may be communicated to third parties belonging to the following categories:

• to the sales/distribution network in the territory;
• subjects that provide services for the management of the information system used by Prometeo S.r.l. Unipersonale and telecommunications networks (including e-mail, CRM database management and mailing lists, e-commerce platforms, APP suppliers, call centres, etc.)
• third parties to support on-line purchases and related administrative-accounting activities, shipments and possible returns (e.g. banks, insurance carriers);
• firms or companies in the context of assistance and consultancy relationships;
• competent authorities to fulfil legal obligations and/or provisions of public bodies, upon request.

The subjects belonging to the above-mentioned categories perform the function of Data Processor, or operate completely independently as separate Data Controllers. The list of Data Processors is constantly updated and available at the head office of Prometeo S.r.l. Unipersonale – Via Roma, 61- 31010 Fonte (TV) Italy, by writing to amministrazione@prometeo.com .

TRANSFER OF DATA TO A THIRD COUNTRY AND/OR AN INTERNATIONAL ORGANISATION AND GUARANTEES

To manage its e-commerce activities, Prometeo S.r.l. Unipersonale may use cloud platforms provided by third party operators as sub-processors. In this regard, we would like to inform you that your personal data acquired on the basis of this notice may also be stored on servers located in the United States of America. The United States of America does not benefit from an adequacy decision of the EU Commission, therefore the transfer will take place on the basis of the standard contractual clauses approved by the Commission or by virtue of other appropriate data transfer mechanisms provided for by the legislation in force. For information about the guarantees inherent in the transfer of data outside the EU please write to amministrazione@prometeo.com .

DATA RETENTION PERIOD OR CRITERIA FOR DETERMINING THE PERIOD

The processing will be carried out in automated and manual form, using methods and tools designed to guarantee maximum security and confidentiality, by persons specifically appointed for this purpose. Please note that no automated decision-making activities are carried out.

In compliance with the provisions of Article 5 paragraph 1 letter e) of EU Reg. 2016/679, the personal data collected will be stored in a form that allows the identification of the data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The retention of data of a personal nature provided depends on the purpose of the processing:

• navigation on this website (see the cookie policy at https://www.hsnetworkmanager.com/cookies-policy/ ;
• per contact request (maximum 1 year);
• per registered/login restricted area (maximum 2 years);
• receiving newsletters or promotional communications in general by e-mail (maximum 24 months)
• online sales (10 years).

Interested parties may obtain information on the timeline by writing amministrazione@prometeo.com

RIGHTS OF THE INTERESTED PARTIES

Prometeo S.r.l. Unipersonale guarantees the respect of the data subject’s rights enshrined in EU Reg. 2016/679 in articles 15-21. You may, therefore, at any time: revoke your consent to the processing; find out what personal data we hold about you, where they come from and how they are used; request that they be updated, corrected or supplemented; and, in the cases envisaged by the provisions in force, request that they be deleted, limited in their processing or oppose their processing. If you wish, you can request to receive the personal data in the possession of Prometeo S.r.l. Unipersonale concerning you in an electronically readable format and, where technically possible, we may transfer your data directly to a third party indicated by you. If you believe that your personal data has been processed unlawfully, you may lodge a complaint with one of the competent data protection supervisory authorities. In Italy, the complaint may be lodged with the Garante per la Protezione dei Dati Personali (http://www.garanteprivacy.it ). You may assert your rights as expressed in EU Regulation 2016/679 by contacting the Controller, by sending an email to amministrazione@prometeo.com or by writing to the Controller’s head office:

Prometeo S.r.l. Unipersonale – Via Roma, 61- 31010 Fonte (TV) .

You have the right, at any time, to ask the Data Controller for access to your personal data, to rectify or erase them, or to restrict their processing or to object to their processing based on legitimate interest. In addition, you have the right to data portability. If the processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on the consent given before the revocation. As an alternative to the automatic cancellation systems provided for e-mails only, to stop receiving automated direct marketing communications (e-mails, SMS, MMS, social networks) you may write to amministrazione@prometeo.com with the subject line ‘cancellation from automated‘. To stop receiving traditional direct marketing communications (telephone calls with operator, paper mail) you can write to amministrazione@prometeo.com with the subject “unsubscribe from traditional“. To stop receiving direct marketing communications you can write to amministrazione@prometeo.com with the subject “unsubscribe marketing“. To opt out of profiling you may write to amministrazione@prometeo.com with the subject “no profiling“.

Remember that you always have the right to lodge a complaint with a supervisory authority.

NATURE OF CONFERMENT AND REFUSAL

Refusal to provide the necessary data for purpose A) will make it impossible to use the services of the Data Controller. The provision of and consent to the processing for purposes B) or C) is optional. Any refusal to grant consent(s) for the purposes set out in points B) and/or C) above shall not entail any negative consequences with regard to the purposes set out in point A). Profiling and marketing activities are only possible and will only be carried out with the specific consent of the person concerned, should he/she decide to consent to the profiling of his/her data by entering them into CRM. Entering data into the CRM is optional and will automatically entail the visibility of such data by those who have access to them, i.e. the data processors and persons in charge of processing, who are present at points of sale around the world.

CHANGES TO THE PRIVACY POLICY

The Controller reserves the right to change, update, add or remove parts of this privacy policy at its own discretion and at any time. The data subject is required to periodically check for any changes. In order to facilitate this verification, the notice will contain an indication of the date on which the notice was updated.