Privacy policy

This Privacy Policy is defined on the basis of art. 13 of EU Regulation n. 679/2016 and applies only to all data collected through the Brelil.it website. This Privacy Policy is subject to updates that will be posted on the website on time. The present Privacy Policy and the Cookie Policy, establishes the basis on which the user’s personal data will be processed.

Data Controller
The Data Controller of this website is Brelil S.r.l., Via Solferino, 7 a Milano, email: privacypolicy@sodalisgroup.com.
mail DPO: stefano.modena@assiteca.it

Methods of personal data processing
The personal data provided or acquired are subjected to a treatment based on principles of correctness, lawfulness, transparency and protection of privacy pursuant to current legislation. The Data Controller processes the user’s personal data adopting appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of personal data. Data are processed by means of IT and/or telematics tools, by implementing organizational methods and strategies that are connected to the purposes of the activity.

Purposes for processing the collected data and legal basis
Personal data can be collected autonomously by the Data Controller or by third party. In this case, the computer systems and software used by the website acquire certain user’s personal data, IT related (for example, the IP address, the browser used, the operative system, the domain name and the websites addresses from which you have accessed or exit, etc.), whose transmission is inherent to the correct functioning of Internet. Such data can be processed for the sole purpose of obtaining anonymous statistical information on the use of the website and/or controlling its correct functioning; after their processing, they are immediately erased. The data the user choses to provide spontaneously are collected to allow the website to provide its services and for the following purposes:
a) to fulfil anykind of obligation required by current laws, regulations, associated regulations, commercial use and taxation/fiscal subjects. This processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
b) for other additional purposes or related to that indicated above and falling within the sphere of the activities of the website;
c) to act on specific requests made by the user to the Data Controller for informative communications related to the Data Controller’s services by e-mail or filling in contact forms and using other communication tools like phone or instant messaging services like WhatsApp Business, Messenger live etc. This processing is optional, and it is based on the user’s consent, nevertheless, the non-reporting of one or more data will cause the impossibility of responding to the information request and of using the services offered by the Data Controller;
d) for soft spam purposes to allow the Data Controller to send the user via e-mail promotional communication concerning Products and/or Services purchased without the need for the express and prior consent of the user, as required by art. 130, paragraph 4, Code of Privacy, and provided that the user does not exercise the right of opposition. This processing is based on art. 130, paragraph 4 of the Code of Privacy as told by Legislative Decree no.101 of 2018;
e) for carrying out statistical analysis on aggregated and anonymous data to analyse the user’s behaviour, improve the products and services provided by the Data Controller and meet the user’s expectations;
f) for profiling activities for marketing purposes. This processing is based on the consent freely expressed by the user;

Category of personal data processed
Among the personal data processed by this website, autonomously or by third party, there are common data like: Cookies, usage data, name, email, phone, tax data useful for purchasing and personal data useful for the delivery of the purchased product. The optional, explicit or voluntary transmission of emails by Contact Form or by the addresses specified on this website entails the successive acquisition of the sender’s address, which is necessary to answer the requests, and of any other personal data included in the email. The user’s consent to the provision of data is necessary to be inserted in the Data Controller’s database and in the interest of the establishment and correct functioning of what offered to users, as well as third party for the fulfilment of the single activity required. Therefore, failure to provide it will hinder the registration in the Data Controller’s database, the refinement of any contract, as well as their execution and that of any other activity.

Data communication
In some cases, in addition to Data Controller, may have access to data:
a) categories of persons specifically trained involved in the organization of the website (administrative staff, commercial staff, marketing staff, lawyers, system administrators);
b) external parties (like third party technical service providers, hosting provider, IT companies, communication agencies) also appointed as Data Processors by the Data Controller ex art. 28 GDPR. The updated list of Data Processors, if appointed, can always be requested from the Data Controller;
c) public or private entities that can access the data in compliance with legal obligations;
d) subjects that perform instrumental tasks with respect to the activity of the Data Controller;

Processing time
As expressly stipulated by art. 5, co. 1, lett. e) of the GDPR, data are stored for a period of time necessary to provide the service requested by the user, or for the time required for the purposes described in this document, particularly:
– The data collected for contractual obligations will be stored for the time necessary for the accomplishment of the mentioned purposes and in accordance with current legislation;
– The data collected for tax / administrative obligations will be stored for the time necessary for the accomplishment of the mentioned purposes and in accordance with current legislation;
– The data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is met; the user can obtain more information regarding the Data Controller’s legitimate interest contacting him/her;
– The data collected based on the user’s consent can be stored until the withdrawal of the consent;
The Data Controller can store the data for a longer time in accordance with a legal obligation or by order of an authority.
At the end of the storing time, personal data will be deleted and consequently access rights, deletion rights, rectification rights and data portability rights can no longer be exercised.

Cookies
This website uses Cookies. They are small text files that may be used by websites to make the user’s experience more efficient, to customize contents and advertisements, to provide the functions of the social networks and analyse the traffic. Cookie Policy

Place of processing and transfer of data abroad
The data are processed at the Data Controller’s operating office. For more information, contact the Data Controller. The data can be processed by natural persons and/or legal entities acting on behalf of the Data Controller, under specific contractual obligations and located in UE or non-UE countries. If the data are transferred outside the EEA, the Data Controller will adopt any contractual measure suitable to ensure an adequate data protection.

Tools used for personal data processing
CONTACT FORM
The user, filling in the contact Form with his/her data, agrees to their use to answer any request of information or any other purpose indicated by the form header. Personal data collected by the contact Form: email, name and surname.

EMAIL ADDRESSES MANAGING
These services permit to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the user. Furthermore, these services could permit to collect data related with user’s date and time of viewing of messages, as well as track user’s interaction with them, such as information on clicks on the links included in the messages.

REGISTRATION ON THE WEBSITE
With the registration service the user allows the website to identify her/him and give her/him access to the services dedicated. The registration and authentication services can also take place with the help of third parties. In that case, the application will be able to access some data stored by the third parties service used for the registration and identification.

STATISTICS
Statistics services allow the Data Controller only to monitor and analyse the traffic data and keep track of the user’s behaviour. This website uses the following services:
1) Google Analytics (Google Ireland Limited)
Google Analytics is an analysis service offered by Google Ireland Limited. Google uses the collected personal data with the aim of tracking and examining the use of this website, compiling reports and sharing them with other services developed by Google. Google may use the personal data collected to contextualize and personalize notices on its advertising network. Google can also transmit this information to third parties in case there are any legal requirements or in cases where such third parties process the information on Google’s behalf. On this website the function of anonymization of the IP address is active. The IP address transmitted by the browser for purposes connected to Google Analytics will not be embedded with other data that Google already possesses.
At the following link https://tools.google.com/dlpage/gaoptout?hl=it Google provides the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics. Personal data collected: Cookies and usage data. Place of processing: Ireland – Privacy Policy
2) Facebook Conversion Pixel monitoring (Facebook Ireland Ltd.)
Facebook Conversion Pixel monitoring (Facebook pixel) is a statistical service offered by Facebook. The Facebook pixel monitors conversions that can be attributed to Facebook ads. Personal data collected: Cookies and usage data. Place of processing: Ireland – Privacy Policy.

INTERACTION WITH SOCIAL NETWORKS
These services allow to interact with social networks directly from the website pages. The interactions and information acquired by this website are subject to the user’s Privacy Policy of each social network. If a service for interaction with social networks is installed, the site may collect traffic data about the pages, even if users do not use the service.
1) Facebook (Facebook Ireland Ltd.)
The Facebook buttons are services for interaction with Facebook, offered by Facebook Ireland Ltd. Personal data collected: Cookies and usage data. Place of processing: Ireland – Privacy Policy
2) Instagram (Facebook Ireland Ltd.)
The Facebook buttons are services for interaction with Instagram, offered by Facebook. Personal data collected: Cookies and usage data. Place of processing: Ireland – Privacy Policy

REMARKETING E RETARGETING
These services allow this website to communicate, optimize and serve advertising based on the past use of this website by the user. This activity is carried out by tracking of usage data and the use of Cookies. This website uses the following services:
1) Facebook Remarketing (Facebook Ireland Ltd)
Facebook Remarketing is a service of Remarketing and Behavioral Targeting offered by Facebook, that links the activity of this website with the Facebook advertising network. This website makes use of Facebook Pixel in order to measure conversions. Thanks to Facebook Pixel we can understand the actions people perform on this website. Data collected can be used for:
– making sure the ads are shown to the right people;
– creating public groups to use advertisements for;
– exploiting the additional advertising tools of the platform on which advertising is made.
Collected information is anonymous to the operators of this website and cannot be used to determine the identity of a single user. However, information is stored and analysed by Facebook, which might relate the action to a single profile and use this information for internal Facebook advertising purposes, as outlined by the Privacy Policy of Facebook. This will allow Facebook to show ads on both Facebook and third-party websites. The website owner does not have any control over the use of these data. For more information on how users can protect their privacy, refer to the Facebook Privacy Policy.
2) Instagram Remarketing (Facebook Ireland Ltd)
Instagram Remarketing is a service of Remarketing and Behavioral Targeting offered by Facebook, that links the activity of this website with the Instagram advertising network. This website makes use of Pixel in order to measure conversions and understand the actions people perform on this website. Collected information is anonymous to the operators of this website and cannot be used to determine the identity of a single user. However, information is stored and analyzed by Facebook, which might relate the action to a single profile and use this information for internal Facebook advertising purposes, as outlined by the Privacy Policy of Facebook. For more information on how users can protect their privacy, refer to the Instagram Privacy Policy.

CONTENTS HOSTED ON EXTERNAL PLATFORMS
These services allow to display contents hosted on external platforms directly from this website pages and to interact with them. If a service for interaction with social networks is installed, the website may collect traffic data about the pages, even if users do not use the service.
This website uses
1) Google Maps
Google Maps is a map display service managed by Google that allows this website to integrate those contents within its own pages. Personal data collected: Cookies and usage data. Place of processing: Ireland – Privacy Policy
2) YouTube (Google Ireland Limited)
YouTube is a video contents viewing service managed by Google that allows this website to integrate such content within its pages. Personal data collected: Cookies and usage data. Place of processing: Ireland – Privacy Policy
3) Google Fonts
Google Fonts is a font style viewing service provided by Google Ireland Limited that allows this website to integrate such content within its pages. Personal data collected: usage data; different kinds of data as specified in the privacy policy of the service. Place of processing: Ireland – Privacy Policy
4) Adobe Font (Adobe Systems Software Ireland Limited – Adobe Ireland)
Adobe Font is a font style viewing service provided by Adobe Systems Software Ireland Limited that allows this website to integrate such content within its pages. Personal data collected: usage data; different kinds of data as specified in the privacy policy of the service. Place of processing: Ireland – Privacy Policy

Exercise of the rights of the data subject
The data subject may exercise the rights as described in the artt. 7, 15-22 of the EU Regulation 679/2016. In particular, the right to withdraw his/her consent in any time and, simply asking the Data Controller, he/she may request access to personal data, receive the personal data provided by the Data Controller and, where possible, transmit them to another Data Controller of the processing without impediment (c.d. portability), obtain the update, the limitation of the processing, the rectification of data and the deletion of that processed in contrast with current legislation. The data subject has the right, for legitimate reasons, to oppose the processing of personal data concerning him/her the processing for purposes of sending advertising materials, direct selling and market research. The interested party also has the right to lodge a complaint with the Privacy Authority in its quality of supervisory authority. The data subject may exercise the rights by emailing the owner at: privacypolicy@sodalisgroup.com.

Changes to this Privacy Policy
The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving notice to users on this page. Therefore, it is recommended to consult this page very often, taking as reference the date of last modification indicated at the bottom. In case of non-acceptance of the changes made to this Privacy Policy, the user is required to cease the use of this website and may request the Data Controller to remove their personal data. Unless otherwise specified, the previous Privacy Policy will continue to apply to personal data up to that date collected moment. The Data Controller is not responsible for the update of the links displayable in this Privacy Policy, therefore, every time a link does not work and/or is not updated, users acknowledge and accept that they must always refer to the document and/or the section of the linked websites.