European Regulation on the protection of personal data

1) Introduction

Benussi Marine S.r.l. takes users’ privacy seriously and is committed to respecting it. This Privacy Policy (“Benussi Marine S.r.l. Policy”) describes the personal data processing activities carried out by Benussi Marine S.r.l. through the website http://www.benussimarine.com/.

Benussi Marine S.r.l. may process the user’s personal data when the user visits the Website and uses the services and features available on it. In the sections of the Website where the user’s personal data are collected, a specific notice pursuant to Articles 13/15 of Regulation (EU) 2016/679 is usually published. Where required by Regulation (EU) 2016/679, the user’s consent will be requested before processing their personal data. If the user provides personal data of third parties, the user must ensure that communicating such data to Benussi Marine S.r.l. and the subsequent processing for the purposes specified in the applicable privacy notice comply with Regulation (EU) 2016/679 and the applicable laws.

2) Controller’s identification details

Controller: Benussi Marine S.r.l., Via Olivetti No. 50/A13, 30025 Fossalta di Portogruaro (VE) – Tel. +39 0421 248303 - Fax +39 0421 478977 - info@benussimarine.com - www.benussimarine.com

3) Types of data processed

Visiting and browsing the Website generally do not involve the collection and processing of the user’s personal data, except for browsing data and cookies as specified below. In addition to so-called “browsing data” (see below), personal data voluntarily provided by the user may be processed when the user interacts with the Website’s features or requests to use the services offered on the Website. In compliance with the Privacy Code, Benussi Marine S.r.l. may also collect the user’s personal data from third parties in the course of its business activities.

4) Cookies and browsing data

The Website uses “cookies”. By using the Website, the user agrees to the use of cookies in accordance with this Privacy Policy. Cookies are small files stored on the user’s computer hard drive. There are two main categories of cookies: technical cookies and profiling cookies. Technical cookies are necessary for the proper functioning of a website and to enable user navigation; without them the user may not be able to view pages correctly or use certain services.
Profiling cookies are used to create user profiles in order to send advertising messages consistent with the preferences expressed by the user while browsing.

Cookies can also be classified as:

• “session” cookies, which are deleted immediately when the browser is closed;
• “persistent” cookies, which remain in the browser for a certain period of time. They are used, for example, to recognize the device connecting to a website, facilitating authentication operations for the user;
• “first-party” cookies, generated and managed directly by the operator of the website the user is browsing;
• “third-party” cookies, generated and managed by entities other than the operator of the website the user is browsing.

5) Cookies used on the Website

The Website uses the following types of cookies:

1) first-party cookies, session and persistent, necessary to allow browsing of the Website, for internal security purposes and system administration;
2) third-party cookies, session and persistent, necessary to allow the user to use multimedia elements on the Website, such as images and videos;
3) third-party persistent cookies used by the Website to send statistical information to Google Analytics, through which Benussi Marine S.r.l. can perform statistical analyses of accesses/visits to the Website. The cookies used pursue exclusively statistical purposes and collect information in aggregated form. Through a pair of cookies—one persistent and one session (expiring when the browser is closed)—Google Analytics also stores a log with the start and end times of the visit to the Website. You can prevent Google from detecting data via cookies and processing such data by downloading and installing the browser plug-in available at the following address: https://tools.google.com/dlpage/gaoptout?hl=it.
4) third-party persistent cookies used by the Website to include social network buttons (Facebook, Twitter and Google+) on its pages. By selecting one of these buttons, the user can publish the contents of the Website page they are visiting on their personal page of the relevant social network.

The following table provides a detailed overview of the cookies present on the Website.

Below are, for each technical cookie that may be used, the name, purpose, and type/duration.

Below are, for each analytics cookie used, the name, purpose, type/duration, and origin.

Below we provide the names of third-party cookies that may be installed via the Website, their purpose, the third party’s name, and the link to the third party’s website.

In any case, users can manage their online behavioural advertising preferences via the website www.youronlinechoices.com/it, which lists the main behavioural advertising providers. Through that website, users can disable or enable all companies or alternatively set their preferences individually for each company.

The Website may contain links to other websites (so-called third-party websites). Benussi Marine S.r.l. does not access or control cookies, web beacons, and other user-tracking technologies that may be used by third-party websites that the user can access from the Website; Benussi Marine S.r.l. also does not control content and materials published by or obtained through third-party websites, nor their methods of processing the user’s personal data, and expressly disclaims any related liability. The user is required to review the privacy policies of the third-party websites accessed through the Website and to inform themselves about the conditions applicable to the processing of their personal data. This Privacy Policy applies only to the Website as defined above.

6) How to disable cookies in browsers

The procedures for disabling cookies for the following browsers—Chrome, Mozilla Firefox, Internet Explorer, Safari, Opera—are as follows: by default, almost all web browsers are set to automatically accept cookies.
However, it is possible to change these default settings through the browser settings. Disabling/blocking cookies or deleting them may prevent optimal use of certain areas of the Website, prevent the use of some services, and slow down browsing. Cookie management settings depend on the browser used. Usually, cookie settings are configured from the “Preferences”, “Tools” or “Options” menu.
Below are links to the guides for managing cookies in the main browsers:
Internet Explorer: https://support.microsoft.com/kb/278835
Internet Explorer [mobile version]: https://www.windowsphone.com/en-us/how-to/wp7/web/changing-privacy-and-other-browser-settings
Chrome: https://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647
Safari: https://docs.info.apple.com/article.html?path=Safari/5.0/en/9277.html
Safari [mobile version]: https://support.apple.com/kb/HT1677
Firefox: https://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies
Android: https://support.google.com/mobile/bin/answer.py?hl=en&answer=169022

7) Retention of personal data

Personal data are stored and processed through IT systems owned by Benussi Marine S.r.l. and managed by Benussi Marine S.r.l. or by third-party technical service providers; for further details, please refer to the section “Scope of accessibility of personal data” below. Data are processed exclusively by specifically authorized personnel, including staff tasked with performing extraordinary maintenance operations.

8) Purposes and methods of data processing

Benussi Marine S.r.l. may process the user’s ordinary and sensitive personal data for the following purposes: enabling users to use the services and features available on the Website, managing requests and reports from users, sending newsletters, managing job applications submitted through the Website, etc. In addition, with the user’s further and specific optional consent, Benussi Marine S.r.l. may process personal data for marketing purposes, i.e., to send the user promotional material and/or commercial communications related to the Company’s services, to the contact details provided, either through traditional means (such as postal mail, calls with an operator, etc.) or automated means (such as internet communications, fax, email, SMS, mobile device applications—so-called apps—social network accounts (e.g., via Facebook or Twitter), calls via automated operator, etc.).
Personal data are processed both on paper and electronically and entered into the company information system in full compliance with Regulation (EU) 2016/679, including security and confidentiality aspects, and in accordance with the principles of fairness and lawfulness of processing. In compliance with Regulation (EU) 2016/679, data are stored and retained for 10 years.

9) Security and quality of personal data

Benussi Marine S.r.l. is committed to protecting the security of users’ personal data and complies with the security requirements provided by applicable laws in order to prevent data loss, unlawful or illicit use of data, and unauthorized access, with particular reference to the Technical Guidelines on minimum security measures. Furthermore, the information systems and software used by Benussi Marine S.r.l. are configured to minimize the use of personal and identifying data; such data are processed only to achieve the specific purposes pursued from time to time.

Benussi Marine S.r.l. uses multiple advanced security technologies and procedures designed to foster the protection of users’ personal data; for example, personal data are stored on secure servers located in protected and controlled access areas. Users can help Benussi Marine S.r.l. keep their personal data up to date and accurate by communicating any changes relating to their address, role, contact details, etc.

10) Scope of communication and access to data

The user’s personal data may be disclosed to:

• all entities to whom the right of access to such data is recognized by law or regulatory measures;
• our collaborators and employees, within the scope of their duties;
• all natural and/or legal persons, public and/or private, where disclosure is necessary or functional to the performance of our activities and in the ways and for the purposes described above.

11) Nature of providing personal data

Providing certain personal data is mandatory in order to allow the Company to manage communications and requests received from the user or to contact the user to follow up on their request. Such data are marked with an asterisk [*]; in such cases, providing the data is mandatory to enable the Company to process the request, which otherwise cannot be fulfilled. Conversely, the collection of other data not marked with an asterisk is optional: failure to provide them will not entail any consequences for the user.

Providing personal data for marketing purposes, as specified in the section “Purposes and methods of processing,” is optional and refusal will not entail any consequences. The consent given for marketing purposes is understood to extend to the sending of communications through both automated and traditional means of contact, as exemplified above.

12) Data subject rights

12.1 Articles 15 (right of access) and 16 (right to rectification) of Regulation (EU) 2016/679
The data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning them are being processed and, where that is the case, access to the personal data and the following information:
a) the purposes of the processing;
b) the categories of personal data concerned;
c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
d) where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;
e) the existence of the data subject’s right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning them or to object to such processing;
f) the right to lodge a complaint with a supervisory authority;
h) the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

12.2 Right under Article 17 of Regulation (EU) 2016/679 – right to erasure (“right to be forgotten”)
The data subject has the right to obtain from the controller the erasure of personal data concerning them without undue delay and the controller has the obligation to erase personal data without undue delay where one of the following grounds applies:
a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) the data subject withdraws consent on which the processing is based according to Article 6(1)(a), or Article 9(2)(a), and where there is no other legal ground for the processing;
c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
d) the personal data have been unlawfully processed;
e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of Regulation (EU) 2016/679.

12.3 Right under Article 18 – right to restriction of processing
The data subject has the right to obtain from the controller restriction of processing where one of the following applies:
a) 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;
b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
c) the controller no longer needs the personal data for the purposes of processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims;
d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

12.4 Right under Article 20 – right to data portability
The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format and has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.

13. Withdrawal of consent to processing

The data subject has the right to withdraw consent to the processing of their personal data by sending a registered letter with return receipt (Raccomandata A/R) to the following address: Benussi Marine S.r.l., Via Olivetti No. 50/A13 – 30025 Fossalta di Portogruaro (VE), enclosing a photocopy of their identity document, with the following text: <>. After this operation, your personal data will be removed from the archives as soon as possible.
If you would like further information about the processing of your personal data, or to exercise the rights referred to in point 7 above, you may send a registered letter with return receipt (Raccomandata A/R) to the following address: Mr. Benussi Matteo c/o Benussi Marine S.r.l., Via Olivetti No. 50/A13 – 30025 Fossalta di Portogruaro (VE). Before we can provide or amend any information, it may be necessary to verify your identity and ask you a few questions. A response will be provided as soon as possible.