Hesplora Srl, with its headquarter at Viale Augusto Righi 43, Florence, tax code and VAT No. 03488811203, represented by its legal representative pro tempore (hereinafter “Hesplora”), as the data controller pursuant to Article 13 of the European Regulation (EU) 2016/679 (the “GDPR”), as well as Legislative Decree 196/2003, as amended by Legislative Decree 101/2018 (the “Code”), hereby provides the following information.
Hesplora, as the controller of personal data (hereinafter referred to as the “Controller”), shall adhere to the following rules when processing personal data during its business activities.
1.1 Automatically collected data. The computer systems and applications dedicated to the operation of the website www.hesplora.it detect, as part of their standard functionality, certain data (the transmission of which is implicit in the use of Internet communication protocols) that may be associated with identifiable users. The data collected includes the IP addresses and domain names of the computers used by users who access the site, the Uniform Resource Identifier (URI) notation 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 numerical code indicating the status of the response given by the server (successful, error, etc.), and other parameters regarding the operating system, browser and computer environment used by the user. These data are processed for the sole purpose of obtaining statistical information on the use of the site and to check its regular operation. It is imperative to note that the provision of this data is mandatory, as it directly impacts the web browsing experience.
1.2 Data voluntarily provided by the user. The voluntary and spontaneous sending of paper communications, faxes and e-mails to our addresses for the purpose of requesting information regarding the services offered by the Owner does not require the prior collection of consent. Instead, any completion of the form on our website involves the necessary reading of this information and the subsequent acquisition of user data necessary to respond to requests for information and/or provide the requested service. In this case, specific summary information will be reported or displayed in the pages of the site prepared for particular services on request. Therefore, the user must explicitly consent to the use of the data in these forms in order to send the request with respect to the described purposes.
The personal data of the interested party (hereinafter referred to as the “Interested Party”) may be collected and processed for the purposes indicated below. This data may include personal and contact information.
2.1 The Data Subject should be provided with the requested information. The collection and processing of personal data is intended to respond to the requests made by interested parties to Hesplora. These requests are made by completing the relevant online form, which details the services offered by Hesplora. Completion of the form will enable the fulfilment of the requested service.
2.2 Legal obligations and accounting and administrative requirements. The company is committed to fulfilling all of its accounting and administrative obligations, as well as the requirements stipulated by the sector regulations applicable to the type of service provided to the interested party. These regulations encompass laws, regulations, EU legislation, provisions issued by authorities empowered to do so by law, and directives issued by supervisory and control bodies. The data may be communicated to public administrations that are the recipients of fulfillments provided for by the sector regulations. These may be, for example, the Ministry of Economic Development, the Supervisory Authority for the Protection of Personal Data and other databases of public administrations. In such cases, the communication of the data is mandatory, in accordance with the request of the aforementioned administrations.
2.3 Business and marketing activities related to Hesplora. If the Data Subject gives his/her consent, the processing may also be directed to the transmission of communications in electronic and paper format, for the performance of advertising and marketing activities by Hesplora as owner and/or on behalf of the same by external parties (in Italy and/or abroad) appointed by the owner to carry out the promotional activity. These activities may be carried out both by traditional means (e.g. sending newsletters and advertising material, direct sales, carrying out market research, commercial communications, operator calls) and by non-traditional means (e.g. automated calling systems without the intervention of an operator, electronic mail, telefax, messages of the type Mms “Multimedia Messaging Service” or SMS “Short Message Service” or other).
The processing of the Data Subject’s data is conducted as outlined below: (i) With regard to the purpose specified in point 2.1 above, this is based on the execution of pre-contractual and contractual measures. (ii) With regard to the purpose specified in point 2.2 above, this is due to the fulfilment of related legal obligations, including those of a regulatory nature. (iii) With regard to the purpose specified in point 2.3 above, this is based on any specific consent given by the Data Subject.
The provision of the data subject’s personal data is:
We would like to inform you that the personal data received by Hesplora may be disclosed to the following categories of subjects: - Partners with whom Hesplora has collaboration agreements in place for the performance of the provision of the requested services; - Internal employees or external collaborators of Hesplora; - Professional firms; - Companies that carry out marketing activities on behalf of Hesplora; and - Private companies operating as suppliers that carry out technical, support, software supply, telematic and computer services tasks on behalf of Hesplora.
The Data Subject’s data will not be disseminated in any way.
In general terms, data collected is not subject to transfer abroad, apart from data voluntarily provided by the data subject. This data is received by Hesplora through requests for information sent using special means of communication, such as instant messaging (e.g. WhatsApp) or social networks. In such cases, data processing is governed by the data protection policies applied by the managers of the relevant services.
The personal data provided by the Data Subject will form the subject of processing operations in compliance with the aforementioned legislation and the obligations of confidentiality that inspire the activity of the Data Controller. The data will be processed both with computer tools and on paper media as well as on any other type of suitable media, in compliance with the adequate security measures pursuant to Article 5 par. 1 lett. f) of the GDPR.
The data collected will be kept for a period not exceeding the achievement of the purposes for which they are processed (“principle of limitation of storage,” Art.5, GDPR) or in accordance with the deadlines stipulated by legal regulations. Specifically:
Verification of the obsolescence of retained data in relation to the purposes for which they were collected is carried out periodically.
No DPO was appointed, as the legal requirements were not met.
In line with GDPR guidelines, data subjects have the right to request access to their data, rectification or erasure of data, restriction of processing, the option to object to processing, to request data portability, and to withdraw consent to processing by asserting these rights and others. To exercise these rights, please liaise with the Data Controller, Hesplora, at the following addresses:
Hesplora Srl – Viale Augusto Righi 43, 50137 Firenze
E-mail: info@hesplora.it
Phone number: +39 055287863
The data subject may also complain to a data protection supervisory authority.