Privacy policy and cookie policy

The protection of your privacy is one of our main objectives.

This information is provided, in compliance with Articles 13 and 14 of EU Regulation 679/2016 (hereinafter referred to as the “Regulation”), to users: (“Users” or “User”) of the site www.minotticyprus.com in desktop and mobile version, (hereinafter referred to as the: “Website”) owned by Minotti Cyprus, as Controller of personal data (hereinafter referred to as  “Minotti” or the “Controller”) and has the purpose of describing the methods of management of the Website with reference to the processing of personal data, as well as allowing the Users of the Website to be aware of the purposes and methods of the processing of personal data by the Controller in case of their conferment.

This document will allow you to be aware of our privacy policy to understand how your personal information is handled when you use our services and to allow you, where appropriate, to give your express and informed consent to the processing of your personal data in the sections of the site where you are requested to provide personal data.

We remind you that in the various sections of the Website where we collect your personal data, specific information is published pursuant to Article 13 of the EU Regulation 2016/679 for you to review before providing the requested data. The information and data provided by you or otherwise acquired during the use of the various services of the Website, will be processed in compliance with the provisions of the Regulation and confidentiality obligations.

According to the Regulation, the processing carried out by Minotti will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimisation, accuracy, integrity and confidentiality.

INDEX

1. Data Controller
2. Personal data subject to processing
   1. Navigation data
   2. Data provided voluntarily by the data subject
   3. Data for registration
3. Purpose of the processing
4. Legal basis and mandatory or optional nature of the processing
5. Recipients of personal data
6. Existence of an automated decision-making process
7. Personal data transfers
8. Storage of personal data
9. Rights of the data subject
10. Contacts for the exercise of the rights of the data subject and for further information
11. Cookies
12. Social sharing buttons
13. Security measures
14. Use of the Website by minors
15. Applicable law
16. Changes and updates to the Privacy Policy

 

1. Data Controller

The Controller for the processing carried out through the Website is Minotti Cyprus, with registered office at 280 Strovolos Avenue and 2048 Nicosia, Cyprus.

The updated list of data processors and persons in charge of processing is kept at the registered office of the Controller.

2. Personal data subject to processing

Processing of personal data means any operation or set of operations carried out with or without the help of automated processes and applied to personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use,  disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We inform you that the personal data processed will consist of an identifier such as your name, email address, an identification number, location data, an online identifier and other data suitable to make you identifiable, depending on the type of services requested (hereinafter only “Personal Data”).

In particular, the Personal Data processed through the Website are as follows:

a. Navigation data

The computer systems and software procedures used to operate the Website acquire, during their normal operation, some 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 data subjects, but by its very nature could, by being processed and combined with data held by third parties, make it possible to identify Users. This category of data includes IP addresses or domain names of the computers used by Users who connect to the Website, URI (Uniform Resource Identifier) addresses of the resources requested, 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 relating to the User’s operating system and online environment. These data are used for the sole purpose of checking the correct functioning of the Website and identifying anomalies and/or abuse and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Website or third parties.

b. Data provided voluntarily by the data subject

The optional, express and voluntary sending of e-mails to the addresses indicated on the Website involves the subsequent acquisition of the Personal Data provided.

The inclusion of Personal Data to take advantage of the specific services offered by the Website (such as the contact form, subscription to the newsletter or the submission of an application) involves the acquisition of the Personal Data provided. In this case, the User will be provided with specific information pursuant to Article 13 of the Regulation in relation to the individual purposes and, where necessary, the specific consents expressed.

 

3. Purpose of the processing

The Controller informs you that the data collected will be processed lawfully pursuant to Article 6 of the Regulation, and with your specific consent where necessary, exclusively for the following purposes:

1. allowing the provision of the Services requested by you and the subsequent and autonomous management of your control panel, which you will access through the registration and creation of your User profile, including the collection, storage and processing of data for the purposes of establishing and subsequent operational, technical and administrative management of the relationship related to the provision of services and the provision of communications relating to the performance of the relationship established;
2. allowing the navigation and consultation of the Website;
3. responding to requests for assistance or information, which we will receive by e-mail, telephone or through the “Contact Us” page of our Website;
4. fulfilling legal, accounting and fiscal obligations;
5. sending you newsletters, advertising and informative material, commercial information or surveys to improve the service (“customer satisfaction”) via e-mail or text message, and/or via a telephone call with an operator and/or through Minotti’s official pages on social networks.

 

4. Legal basis and mandatory or optional nature of the processing

The legal basis for the processing of Personal Data for the purposes referred to in section 3 letter a), b) and c) is Article 6, paragraph 1, letter b of the Regulation regarding the processing necessary for the provision of the contracted services. The provision of Personal Data for these purposes is optional but failure to do so would make it impossible to activate the services requested.
The purpose referred to in section 3 letter d) represents a legitimate processing of Personal Data pursuant to Article 6, paragraph 1, letter c) of the Regulation. Once the Personal Data has been provided, the processing may be necessary for compliance with legal obligations to which Minotti is subject.
The processing operations carried out for marketing purposes described in section 3 letter e) are based on your consent pursuant to Article 6, paragraph 1, letter a) of the Regulation. The provision of your Personal Data for these purposes is entirely optional and does not affect the use of the Services.

Should you wish to object to the processing of your data for marketing purposes, you may do so at any time by sending a request to the following e-mail address info@minotticuprus.com.

The provision of Personal Data by the User is always optional, but is necessary regarding the data indicated as mandatory and marked with an asterisk (*) by means of request forms, as failure to provide such data would make it impossible for the User to send requests and for Minotti to perform them.

5. Recipients of Personal Data

The Personal Data provided may be known and used by Minotti’s employees and/or independent contractors, in charge of managing the Website and the Users’ requests, for the sole purpose of carrying out the activities that represent the reason for which the data was collected. The Personal Data of the Users may also be communicated to third parties in charge of the lawful processing on behalf of the Controller, acting as External Data Processors, such as providers of IT services and other services necessary for the normal operation of the Website, outsourcing service providers and consultants or freelance professionals who assist Minotti in the performance of the services requested or who organise on its behalf the management of commercial and marketing initiatives envisaged in the context of the consent received from the User. Users, by way of simple request addressed to the Controller in the manner communicated in the foreword, will be able to obtain the list of any External Data Processors in charge.

6. Existence of an automated decision-making process

There is no automated decision-making process. The data will not be subject to profiling.

7. Personal Data Transfers

Users’ Personal Data will not be transferred to foreign countries not belonging to the European Union, except in cases where the communication is required by law or is necessary for purposes provided for by law for which the consent of the data subject is not required and in any case in accordance with current legislation.

8. Storage of Personal Data

Personal Data processed for the purposes set forth in section 3 letters a), b) and c) will be stored for the time strictly necessary to achieve those purposes. In any case, since the processing is carried out for the provision of services, Minotti will process Personal Data until the time allowed by Italian law to protect its own interests (Articles 2946 of the Italian Civil Code ff.).
Personal Data processed for the purposes set forth in section 3 letter d) will be stored until the time provided for by the specific obligation or rule of applicable law.
For the purposes set out in section 3 letter e), your Personal Data will be processed until your consent is revoked or up to five years after registration on our systems.

Personal Data will be stored on servers located in Italy.

In order to ensure that your Personal Data is always accurate and up to date, however relevant and complete, we suggest that you update the Personal Data that you have entered in your account or by contacting us info@minotticyprus.com.

9. Rights of the data subject

The User, acting as a data subject in the processing of Personal Data (the “Data Subject”), may exercise the rights provided for in the Regulation, towards Minotti, with regard to the processing activities concerning your Personal Data.

In particular, the Data Subject has:

a) the right of access (Article 15 of the Regulation). The Data Subject may obtain confirmation as to whether or not Personal Data relating to him/her are being processed, as well as access to information on the purposes of the processing, the categories of Personal Data being processed, the recipients or categories of recipient to whom the Personal Data are or will be disclosed, the storage period envisaged, the existence of the right to request rectification, erasure or restriction of processing, the right to lodge a complaint with a supervisory authority, the existence of an automated decision-making process, including profiling;

b) the right to rectification (Article 16 of the Regulation). The Data Subject may obtain the rectification of inaccurate Personal Data concerning him/her, or the Data Subject may have incomplete Personal Data completed;

c) the right to erasure (‘right to be forgotten’) (Article 17 of the Regulation). The Data Subject may obtain the erasure of Personal Data concerning him/her, if:

i. the Data Subject withdraws the consent given for the processing of Personal Data;

ii. the Personal Data are no longer necessary for the purposes for which it was collected;

iii. the Personal Data have been unlawfully processed;

iv. for compliance with a legal obligation, the Personal Data must be erased;

d) the right to restriction of processing (Article 18 of the Regulation). The Data Subject has the right to obtain the restriction of the processing of Personal Data concerning him/her if:

i. the accuracy of the Personal Data is contested by the Data Subject, for a period enabling the Controller to verify the accuracy of the Personal Data;

ii. the processing is unlawful and the Data Subject opposes the erasure of the Personal Data and requests the restriction of their use instead;

iii. Minotti no longer needs the Personal Data for the purposes of the processing, but they are required by the Data Subject for the establishment, exercise or defence of legal claims;

iv. for the time necessary to assess the possible prevalence of the legitimate grounds of the Controller over those of the User, the User has opposed the processing of his/her personal data pursuant to point c which follows;

e) the right to data portability (Article 20 of the Regulation). The Data Subject has the right to receive the Personal Data concerning him or her provided to the Controller, in a structured, commonly used and machine-readable format , and has the right to transmit such data to another Controller without hindrance by Minotti, if the processing is carried out by automated means. If technically feasible, the Data Subject is also entitled to have his/her Personal Data transmitted directly from Minotti to another Controller;

f) the right to object (Article 21 of the Regulation). The Data Subject has the right to object at any time to the processing of Personal Data concerning him or her if such processing is carried out pursuant to Article 6.1 letter e) (i.e. for the performance of a task carried out for reasons of public interest to which the Controller is subject) or letter f) (i.e. to prosecute a legitimate interest of the Controller) of the Regulation, unless there are compelling legitimate reasons for the Controller to proceed with the processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims.

g) the right to withdraw at any time the consent given where given without prejudice to the lawfulness of the processing of the User’s Personal Data based on consent given before the withdrawal.

Any rectification or erasure of the User’s Personal Data or restriction of processing carried out at the User’s request – unless this proves impossible or involves a disproportionate effort – will be communicated by Minotti to each of the Recipients to whom the User’s Personal Data may have been transmitted in accordance with this Privacy Policy.

The exercise of the above rights is not subject to any formal constraint and is free of charge. Minotti may only require the User to verify his or her identity before taking further action following the User’s request.

10. Contacts for the exercise of the User’s rights and for further information

In order to exercise your rights and/or to obtain any information regarding this Privacy Policy you may send a written communication to: Minotti Cyprus, 280 Strovolos Avenue and 2048 Nicosia – Cyprus or an email to: info@minotticyprus.com.

11. Cookies

In order to allow the safe and efficient exploration of the Website, the Controller uses cookies. For more information about cookies and their use on the Website, please see our Cookie Policy which is an integral part of this policy.

12. Social sharing buttons

The Website may also contain Social sharing buttons. These are “buttons” that in particular depict social network icons, such as Facebook and Instagram, and allow Users – through a “click” on the icon – to reach and interact with the relevant social networks. With the support of these tools, you may, for example, share content or recommend products on the Website in social networks.

After clicking on the Social sharing buttons, the social network may collect data relating to your visit to the Website. As mentioned in the introduction, this privacy policy does not relate to the processing of the User’s Personal Data by social networks. The User must refer exclusively to the privacy policy provided by the social network.

Apart from cases in which the User spontaneously shares his/her browsing data with the social networks chosen by clicking on social buttons/widgets, the Controller does not share or disseminate any Personal Data of the User with the social network.

13. Security measures

Pursuant to Article 32 of the Regulation, Minotti and the persons appointed as data processors adopt adequate security measures in order to minimise the risks of destruction or loss – even accidental – of Personal Data, unauthorised access or processing that is not permitted or does not comply with the purposes of collection indicated in our Privacy Policy.

However, Minotti cannot guarantee its Users that the measures adopted for the security of the Website and the transmission of Personal Data and information on the Website limit or exclude any risk of unauthorised access or dispersion of Personal Data by devices belonging to the User.

It is always appropriate that the User’s device is equipped with appropriate software to protect the network transmission of Personal Data, both incoming and outgoing, and that its Internet service provider has adopted appropriate measures for the security of the transmission of Personal Data over the network.

14. Use of the Website by minors

The Website is intended for use and consultation by persons of legal age. Therefore, any requests from minors will not be taken into consideration.

15. Applicable law

This Privacy Policy is governed by Italian law and in particular by the regulations on data privacy, including the Regulation, measures, authorisations and guidelines adopted by the Privacy Supervisor governing the processing of Personal Data, where applicable.

 

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