Personal Data Processing and Cookie Policy in accordance with art. 13 of Regulation (EU) 679/2016

With this document the Data Controller, as defined hereinafter, informs you of the purposes and methods used to process personal data collected via the domain www.pauselligroup.com and the user rights recognised by the above-mentioned regulation for the protection of natural persons with regard to the processing of personal data and on the free movement of such data. This policy may be modified, updated and integrated by specific policies should the user request additional services requiring different data processing.

1)- Definitions

For the purposes herein, without prejudice to the definitions in art. 4 Regulation EU 679/2016, the terms listed below are used with the following meaning:
a) domain: the domain reachable at the address http://www.pauselligroup.com
b) collection points: areas within the www.pauselligroup.com domain in which personal data are collected (e.g.: contact form, newsletter subscription box).

2)- Data Controller

2.a - The Data Controller is Pauselli s.r.l. (VAT N. and Tax Code: 01566820542) with headquarters in Città di Castello (PG) Italy, Via Antonio Mearelli - Zona Artigianale Cinquemiglia (email: privacy@pauselligroup.com – pec: pausellisrl@legalmail.it).

3)- Type of Data Processed

3.a - With regard to the data collected, please note that any data collected and processed after having obtained consent, where necessary, involve the following types of information:
I- Information to identify the Data Subject: The following data is collected in order to start the relationship and/or offer the relevant services: name, surname, headquarters, email address and any details required to meet the requests made by the user.
II- Specific data categories: Currently, the website does not collect or processes specific data. Should specific categories of personal data be collected via the domain, in accordance with art. 9 of Regulation EU 679/2016, you will be pre-emptively informed and given the chance to provide your consent.
III- Data concerning minors: unless stated otherwise, the provision of personal data at the collection points on www.pauselligroup.com is reserved exclusively to users who are 18 years old or over.
IV- Browsing data: The information technology systems and software procedures used by his website during the course of its normal operation acquire some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified users, but due to its nature, when elaborated and combined with data held by third parties, it may lead to their identification. This category of data includes: IP addresses, domain names of the computers used by users to connect to the site; the addresses in URI (Uniform Resource Identifier) format of the resources requested, the time when the request was made, 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 server (successful, error, etc.) and other parameters concerning the user's operating system and computer environment. This data is used solely to obtain anonymous statistical information on how the site is used and/or to make sure it is working properly. This data could be used to ascertain liability in the event of hypothetical cybercrimes.
V- Cookies: Cookies are tiny text files that are memorised by your device (PC, tablet, phone) when you access a website. They are mainly used to improve your browsing experience by saving information that can be used at a later stage, for example, to avoid having to log in again in a restricted area of the website.
This website uses both session cookies and persistent cookies. Session cookies, are deleted once the session is closed. Persistent cookies are used to personalise the browsing experience, for access statistics and for sharing purposes with certain social media websites. By using the website, you consent to the use of cookies. The website does not use technology to acquire directly personal details that identify the user.

Name Type Description Duration Domain
PHPSESSID Technical Session Session cookie Expires at the end of the browsing session www.pauselligroup.com
Google Analytics Technical Permanent Third-party cookies necessary for access statistics 12 months google.com
displayCookieConsent Technical Permanent Saves the consent to use cookies 12 months www.pauselligroup.com

This website uses the service "Google Analytics" provided by Google Inc., based in the United States, which has been set up by the Data Controller to collect users' data in anonymous format.
Data collected by Google Analytics include, for example, information regarding the time spent on the website, approximate geographical origin, access and exit pages, visitors origin, etc. Google will use this information to compile an activity report for the website and provide additional services linked to the use of the website and the Internet in general.
Data collected using these cookies will be used in aggregated format. "Aggregated format" means that the cookies and the system are never associated with individuals, only with browsing activities, so you cannot be associated with the websites you visit.
Furthermore, important details such as your IP addresses are "anonymised" for additional peace of mind, as explained below.
On the website, Google Analytics has been set up to guarantee that IP addresses are anonymous (IP Masking).
The user's IP address, i.e. the number assigned by the provider to the device used, is abbreviated and made anonymous by Google within European Union member countries or other countries based on the European Economic Area agreement. This way, the user profiles created by Google Analytics are "anonymised", making it impossible for the Data Controller to trace the user. Only in specific cases the full IP address is transmitted to a Google server and then abbreviated.
Furthermore, the anonymised IP address is not associated with other data held by Google. The transmission of this data to third parties via Google can only occur to comply with laws and regulations or as part of the data processing on behalf of a third party. Under no circumstance will Google associated personal data with other data collected by Google. Google complies with the principles set by the EU/US Privacy Shield Framework agreement, as disposed by the Department of Commerce of the United States in relation to the collection, use and retention of personal information from the European Union.
By using the website, you give your consent to the processing of the data collected by Google Analytics and the processing methods described above.
Personal Data collected: Cookies and Usage Data.
Place of processing : USA
Privacy Policy: https://policies.google.com/privacy
Opt Out: https://tools.google.com/dlpage/gaoptout?hl=en
You can prevent Google Analytics from collecting your browsing data on this website by following the steps in the guide available at:
https://support.google.com/analytics/answer/181881?hl=it.

This website can incorporate script shown as buttons or plug-ins to facilitate Social Network sharing.
This website makes use of third-party cookies on which it cannot have control, therefore the user must read the privacy policies directly on the websites of the companies that provide these services.

If you do not consent to the use of cookies, wish to block certain cookies or delete ones you have previously accepted, you may do so by changing the settings of your browser. To find out how, you may go to the "Help" section of your browser where you will find the instructions on how to change your cookie preferences, or follow the links to the instructions provided by the main browsers:

However, by blocking cookies, certain functionalities of the websites you visit may be compromised.

3.b - By optionally, voluntarily and explicitly sending emails to the addresses published on this website, the receiver automatically acquires your email address, required to reply to your requests, and any other details included in the emails. Specific summary information will be provided or displayed on the relevant website pages dedicated to particular services on demand. In any case, when required by law, you will be asked to provide your consent to the processing of your personal data.

4)- Purpose of data processing

4.a – The data provided will be used for the following purposes:
i) comply with pre-contractual, contractual and tax obligations derived from the relationship with the user;
ii) comply with the user's requests;
iii) comply with laws, regulations, European Community legislation or with an order issued by the Authorities;
iv) exercise the Data Controller's right of defence in court.

4.b – Subject to the user's specific and separate consent, personal data are treated for the following purposes: 
v) sending newsletters, commercial communications and/or advertising material and surveys about products and/or services offered by the Data Controller, via email, post, SMS or telephone;
vi) determine users' personal characteristics to analyse or anticipate their preferences, interests and behaviour, as well as improve the accessibility and usability of the website.

5)- Data processing modalities

5.a - Personal data processing is carried out using the modalities set in art. 4 of Legislative Decree 196/2003 and art 4 point 2) of Regulation EU 679/2016, and specifically: collecting, registering, organizing, retaining, consulting, processing, modifying, selecting, extracting, comparing, using, interconnecting, blocking, communicating, erasing and destructing data. 

5.b - Your personal data is processed in paper, electronic and/or automated format.

5.c - The Data Controller will process your personal data for the time strictly necessary to comply with the above-mentioned purposes, and in any case for no longer than 10 years after the end of the relationship, if the data was collected for the purposes in point 4.a, without prejudice to any terms set by law or tax regulations; the data collected for the purposes in point 4.b paragraph v) will be processed for no longer than 24 months from the date in which they were collected; data collected for the purposes in point 4.b paragraph vi) will be processed for no longer than 12 months.

5.d – Your personal data will be stored within the European Union and the relevant privacy policies are reviewed in compliance with Best Practices in the sector.

5.e – Without prejudice to the dispositions in point 3.4 paragraph V herein, the site does not carry out user profiling or other automated processing.

6)- Data provision

6.a – As a general rule, consenting to the processing of personal data is optional, however, in some cases it may be necessary in order to access the services and functionalities offered by the website.

6.b – The provision of certain personal data is necessary to comply with specific requests. Therefore, if you do not provide your consent, the Data Controller will not be able to satisfy your requests.

7)- Lawfulness of Processing

7.a – In accordance with the applicable regulation on personal data protection, the lawfulness of data processing is based on the following:
i) the data subject has provided specific, correct, informed and unequivocal consent;
ii) processing is necessary for the performance of a contract or in order to take steps at the request of the data subject prior to entering into a contract;
iii) processing is necessary for compliance with legal obligations to which the data controller is subject.

8)- Processors or categories of personal data processors

8.a – The personal data mentioned herein may be processed: i) by employees and collaborators of the Data Controller – as subjects designated or authorised by the Data Controller – strictly within the limits of their competences and duties, according to the tasks assigned and instructions received; ii) external subject specifically designated and subjects authorised by them, strictly within the limits of their competences and duties, according to the tasks assigned and instructions received.

8.b – For administration, accountancy and organisational purposes, subject to obtaining your consent, the Data Controller may transfer your personal data to third parties service providers following the modalities established by the law and all security measures, only to comply with requests. Third parties may include: i) postal service providers; ii) law firms and notaries; iii) consultants and other service providers; iv) other subjects for compliance with legal obligations (e.g. insurance companies, police, other authorities, etc.).

8.c – In no case will personal data be diffused.

9)- Data transfers abroad

9.a – The Data Controller does not willingly transfer personal data abroad. However, some third-party service providers may have servers located abroad. In these cases, the transfer of data abroad will be carried out in compliance with art. 44 and subsequent articles of Regulation EU 679/2016.

10)- Data Subject Rights

10.a – Within the meaning of art. 15 and subsequent articles of Regulation 679/2016, you have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning you is being processed, and if the case, have access to said data, and receive a copy of the data subject to processing. Additionally, you have the right to obtain the following information: purpose of data processing; categories of data processed, subjects or categories of subjects to whom personal data may be communicated; period of data processing and criteria used to determine it; right to request the correction or erasure of data; right to request the limitation or object to the treatment of the data; right to complain to the relevant Data Protection Authority; existence of any automated processing, including profiling, and if data is transferred abroad or to an international organization, for direct marketing purposes.

10.b – You also have the right to ask the Data Controller to rectify inaccurate personal data, integrate any incomplete data, delete your personal data (when applicable within the meaning of art. 17 of Regulation EU 679/2016), limit the purposes of the processing, revoke consent and request data portability, as well as exercise, at any time and without explanation, the right to refuse the processing of personal data for direct marketing purposes.

10.c - Any requests, in relation to the rights mentioned above or to any other information request about personal data treatment, may be sent via email to privacy@pauselligroup.com or by post to the Data Controller's address (see art. 2). To comply with these requests, the Data Controller reserves the right to ask for a valid ID.

11)- Data Processors

11.a - The list of the Data Processors is available upon request at the company's headquarters.

This mandatory information is subject to updates, to comply with any changes in the applicable law.