PRIVACY POLICY IN ACCORDANCE WITH ART. 12 ET SEQ OF EU REGULATION 679/2016 (GDPR)

Shorr Kan IT Engineering s.r.l. with registered office in Turin, Via Sestriere 28/a, Italy, (hereinafter referred to only as “SK-IT”), (hereinafter referred to only as the “Data Controller”), being the data controller of the personal data in accordance with the GDPR and the regulations that come under the personal data protection code (not in conflict with EC legislation) acknowledges the importance of the protection of personal data and considers said protection to be one of the objectives of its activities.

SK-IT requests you read this Privacy Policy carefully before sending any personal data, as it contains important information on the protection of personal data and on the security measures taken to guarantee confidentiality in full compliance with the Applicable Law (EU Regulation 679/2016 also referred to as the GDPR) and Legislative Decree 101/2018 as amended on 19 September 2018 for subsequent implementation in Italy. Furthermore, this Privacy Policy is provided only for the website www.shorr-kan.com (the Website) and does not apply to other websites that may be consulted using external links; said policy is understood to be a privacy policy provided in accordance with Art. 13 of the Applicable Law to persons interacting with the Website.

SK-IT informs you that your personal data will be processed on the basis of the principles of lawfulness, fairness and transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality. Therefore your personal data will be processed in accordance with the statutory provisions of the Applicable Law and the confidentiality obligations provided for therein.

The contents of this Privacy Policy can be referred to below so you can easily find the relevant information on how your personal data is processed.

Data Controller and Data Protection Officer

With reference to the Applicable Law, please note that the Data Controller is SK-IT. SK-IT’s details are available on the Contact page, on the Home Page and/or on other web pages of the SK-IT website.

SK-IT’s Data Protection Officer is Cristiano Michela, Corso Siccardi 11 bis, 10122 Turin.

Personal data processed

“Personal Data” means any information relating to an identified or identifiable natural person with particular reference to an identifier such as a name, an ID number, location data, an on-line identifier or one or more characteristic elements of his or her physical, physiological, psychic, economic, cultural or social identity.

The following Personal Data are collected by the Website:

Browsing data

The Website’s IT systems collect some Personal Data the transmission of which is implicit in the use of Internet communication protocols. This information is not gathered to be specifically associated with you, but due to the very nature of the same could, by being processed and through association with third party data, make it possible to identify you. This includes the IP addresses or domain names of devices used by users to browse the Website, the 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 numeric code indicating the status of the server’s response (connected, error, etc.) and other parameters on your operating system and IT environment.

The data are used to obtain anonymous statistical information on Website use and to check it is functioning correctly; to allow, considering the architecture of the systems used, the various functions you requested to be provided correctly and for security reasons, said data are retained by the Data Controller of the website for the period strictly necessary and in any case in compliance with current regulatory provisions on personal data protection.

Data provided voluntarily

You may voluntarily provide Personal Data such as your name and email address to contact SK-IT using the Website “Contact us” form or other similar services. Users are free to provide their personal data or not, but failure to provide said data may make it impossible to obtain the requested service. SK-IT will process this data in compliance with the Applicable Law, assuming they refer to you or third parties who have specifically authorized you to provide said data on an appropriate legal basis that legitimises the processing of the same. In this hypothesis, you assume the role of autonomous data controller, with all the related legal obligations and responsibilities. In this sense, you hold SK-IT harmless against any disputes, claims or requests for compensation for damages related to data processing, etc. third parties may make against SK-IT, when their Personal Data have been processed as a result of your use of the Website in violation of the Applicable Law.

Cookies and similar technologies

SK-IT collects Personal Data using cookies.

Purpose, legal basis and mandatory or optional nature of the processing

The Personal Data you provide using the Website will be processed by SK-IT for the following purposes:

1. Purposes related to the performance of a contract in which you are a party or pre-contractual measures adopted at your request (e.g. contact request using the Contact form or email, subscription to the newsletter);
2. Purposes related to statistical research/analysis on aggregate or anonymous data, that does not therefore identify the user, to measure how the Website functions, measure traffic, evaluate usability and interest;
3. Purposes related to the fulfilment of a legal obligation SK-IT is obliged to comply with;
4. Purposes necessary to ascertain, exercise or defend rights in a court of law or before any authority holding jurisdiction over a case;

The legal basis for processing Personal Data for the purposes referred to in point a) is to provide a service or respond to a request, which does not require consent in accordance with the Applicable Law. The purpose referred to in point b) does not involve the processing of Personal Data, while the purpose referred to in point d) represents the legitimate processing of Personal Data in accordance with the Applicable Law because, when the Personal Data has been provided SK-IT must process the same to comply with a legal obligation. Providing your Personal Data for the above purposes is optional, but failure to provide said data may make it impossible to process your request or fulfil SK-IT’s legal obligation.

Processing procedure

Tools and logic. In relation to the above purposes, data is processed using manual, IT and computer tools on the basis of logic strictly related to the above-mentioned purposes and, in any case, in a way that guarantees data security and confidentiality, for the purpose of which you should promptly inform us in the case of any corrections, modifications or updates. Said processing may also be done on behalf of the Data Controller for the purposes and in the way described above, in compliance with suitable criteria guaranteeing security and confidentiality, by companies, firms, bodies and external collaborators nominated Data Processors only for the specific data processed by the same. Special data categories. None of your personal data processed or stored by the Data Controller come within the scope of “Special categories of personal data” as defined by Art. 9 of EU Regulation 2016/679.

Recipients

Your Personal Data may be shared, for the specified purposes, with:

1. Subjects when necessary to provide the services offered by the Website, including but not limited to sending emails and analysing Website functions and performance. Said subjects are usually SK-IT data controllers;
2. Persons authorised by SK-IT to process Personal Data who agree to keep the same confidential or who are legally obliged to do so; (e.g. SK-IT employees);
3. Courts or other authorities holding jurisdiction for matter that come under their competence when required by the Applicable Law.

(a. and b. are collectively “Recipients”);

Transfers

Some of your Personal Data is transferred to Recipients who may be located outside the EU. SK-IT guarantees that your Personal Data is processed on electronic and printed medium by the Recipients in compliance with the Applicable Law. Data is transferred on the basis of either an adequacy decision or Standard Model Clauses approved by the European Commission.

Data storage

SK-IT processes your Personal Data only for the time strictly required for the specified purposes. Without prejudice to the above, SK-IT processes your Personal Data for the time permitted by Italian law to protect its interests (Art. 2947(1)(3) of the Italian Civil Code).

Your rights

Within the limits of the Applicable Law, you have the right, at any time, to ask SK-IT to gain access to your Personal Data, to rectify or delete or not consent to the processing of the same, to limit the scope of the processing and obtain a copy of your data in a structured, commonly used, device-readable format.

Requests should be sent by email to: privacy@shorr-kan.com

Pursuant to the Applicable Law, you have in any case the right to file a complaint with the competent supervisory authority (Personal Data Protection Watchdog) if you believe your Personal Data is being processed in violation of the laws in force.

Modifications

This Privacy Policy is valid from 01/05/2019. SK-IT reserves the right to modify or simply update part or all off the content, also in the case of changes to the Applicable Law. SK-IT will notify you of said changes as soon as they are made which become binding when published on the Website. SK-IT therefore requests you visit this section regularly to familiarize yourself with the latest, updated version of the Privacy Policy so you are always up to date on the data collected and how SK-IT processes it.