Privacy policy

Armando Testa S.p.A. cares about the privacy and personal data of its users.
The following privacy policy is meant to inform you on how we process your personal data when you use our services.

PRIVACY POLICY
INFORMATION PURSUANT TO ART. 13 OF THE EU REGULATION N. 679/2016 (“GDPR”)

This Policy explains which of your personal data are collected by Armando Testa S.p.A. (hereinafter “we” or “Armando Testa“), for which purposes and how they are processed. You can also find below the necessary information to enforce your rights provided for by GDPR.
Generally, we collect your personal data if you create an account, when you use our services and products, when you email or call us or send us a message, when you use our websites, apps and social media. We inform you that the personal data collected during such processes will be used in order to reply to your queries, to allow you to use the services and products provided by Armando Testa, to carry out marketing activities, to provide customer support and to carry out analyses in order to ensure you have a customized user experience on the website, as specified below.

1. Who processes your data – Data Controller

Armando Testa S.p.A., with registered office in via Luisa del Carretto n. 58, 10131 – Torino, Italy, is the Data Controller of the processing of your personal data, necessary to provide you with the services and products of Armando Testa and, upon your consent, for marketing purposes, consistently with the purposes and modalities indicated below.
Armando Testa’s Data Protection Officer (“DPO”) can be contacted via email or at the above address.

2. Which data we use – type of processed data

During normal use, the electronic systems and software procedures enabling this Site to operate, acquire certain personal data; transmission of same is implicit in the use of internet communication protocols.
The category of data could be listed as follow: (i) IP addresses of computers used by users connecting to the Site, (ii) addresses in URI (uniform resource identifier) notation for resources requested, (iii) the time of request, (iv) the method used to submit the request to the server, (v) the dimension of the file obtained in response, (vi) the numerical code indicating the status of the response given by the server (success, error etc) and (vii) other parameters regarding the user’s operating system and the IT environment.
These data are recorded in special log and could only be communicated to the Judicial Authority, in case of relevant information security events.
Otherwise are deleted from the system no later than one working week.

3. Where we collect your data – Data collection methods

Through the use of the website and the app. We use cookies and other analysis tools, to improve the functionalities of the website and the app and make their use more efficient. To learn more, please see our Cookie Policy.

4. Why and for how long we process your data – Purpose and legal basis of processing – Data retention period

To prevent or assess unlawful conducts, to protect and enforce our rights. For example, we may use your data to prevent or prosecute infringements, including of our – and third parties’ – intellectual/industrial property rights, or to prevent or prosecute cybercrimes or crimes committed through the internet. The legal basis of such processing is the legitimate interest of Armando Testa to protect its rights and to prevent criminal offences. The retention period of your data is equal to the time reasonably necessary to enforce our rights from the moment we become aware of the offence or of its potential commission.
For Armando Testa’s and its own partners marketing purposes. After having obtained your consent, you may be contacted by Armando Testa via email with promotional content regarding Armando Testa’s services. Also subject to your further consent, we may disclose your data to select Armando Testa’s partners for the purpose of sending you promotional, advertising material and other communications with marketing purposes related to their products (in such case you will find the explicit mention of the partner that may receive your data with a link to its privacy policy). The legal basis for this processing is your explicit consent. The retention period of your data is 12 months from the collection of your data.
To obtain information on the use of the website. When you browse our website, even when you do so without being registered or having logged in, the software procedures and the computer system controlling the functioning of the web applications acquire, during their normal operation, some data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified data subjects, but due to their very nature they could, through processing and associations with data held by the Data Controller or by third parties, allow users to be identified.
 In case of unregistered users, geographical location data and data related to how the website is used will only be used in an anonymous form that does not in any way allow, even in combination with the Unique Device Identifier (UDID), the MAC address, the IMEI or IMSI codes or other customer codes, to trace, directly or indirectly to your identity, unless you allow us to use your data at the moment of registration with explicit consent. In such case, we shall connect your browsing data used in an anonymous form in the previous 30 days to your identity.
This category of data includes IP addresses or domain names of the devices used by users connecting to the application, the addresses in URI (Uniform Resource Identifier) 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 given by the server indicating the status of the response (successful, error, etc.), the visited sections of the website, the type of device used, the country from which you connect and other parameters related to the operating system and the user’s computer environment. Armando Testa uses this information solely to allow navigation on its websites and to process the operations normally related to the use of the website. The legal basis of this processing is the legitimate interest of Armando Testa to communicate with the public through telematic networks. The retention period of the information that could potentially allow the identification is 30 days from access to the website.
Data obtained from browsing may be used, with your consent (which you can manage and revoke by modifying the privacy settings), also to determine your preferences and carry out web analytics activities to evaluate the profitability of each online activity and understand the user’s behaviors with the aim of improving the available services. It is however your right to object, at any time and without charge, to the processing of your data for this purpose. The legal basis for this processing is your consent. The retention period of the data related to the website’s navigation for analysis purposes is 30 days from access to the website. To learn more, please read our Cookie Policy.

5. Cookies

6. Where are your data processed – Transfer of data

The data will be processed and stored at our offices in via Luisa del Carretto n. 58, 10131 – Torino, Italy.
As anticipated, for internal administrative and organizational purposes and to provide you with customer assistance, we may communicate your data to companies belonging to the Armando Testa’s group, operating in the United States and which have entered into with Armando Testa agreements in compliance with art. 28 GDPR with standard data protection clauses approved by the European Commission.

7. With whom we share your data – recipients of the personal data

With Armando Testa’s commercial partners. If you accept, at the time of expressing your preferences regarding personal data, to let your data to be communicated to Armando Testa’s commercial partners, they may process them according to the privacy policy they will submit to you.
With service providers. Armando Testa uses third-party services (clouds, customer care, analysis, profiling, research, hosting, browsing functionalities, use of the app and of the website and components of Armando Testa’s products and services) that operate as data processors pursuant to agreements in compliance with art. 28 GDPR. When such providers operate from a third country, they do it on the basis of standard contractual clauses in compliance with the decision of the European Commission relating to the data protection clauses or by virtue of an adequacy decision of the European Commission on the level of data protection (Privacy Shield). These subjects acquire only the personal data necessary to fulfil their functions and may use them only for the purpose of performing these services on our behalf or to comply with the law. The updated list of third-party suppliers, operating as data processors pursuant to art. 28 GDPR, is available by sending a request to privacy@armandotesta.it.
With other companies belonging to the Armando Testa’s Group. Your data may be shared with other companies belonging to Armando Testa’s group either for internal administrative and organizational purposes or to provide you with the services you have requested or with customer assistance. Up-to-date data on Armando Testa companies recipients of your data are available by sending a request to privacy@armandotesta.it.
With judicial or administrative authorities. Where we believe we have to do so to comply with an order from the judge or from an authority, or to comply with legal obligations or in order to protect us or third parties judicially, we may disclose your data to the Judicial Authority or to a Governmental Agency in Italy or the European Union.

8. Minors

Armando Testa does not process the personal data of minors under the age of 16. In the event that Armando Testa becomes aware that it has collected personal data from users under the age of 16, it will take the necessary steps to delete such information as soon as possible.

9. Your rights

In addition to managing your preferences on processing of your personal data in accordance with the previous paragraphs, you can contact Armando Testa to request access to your personal data, rectification, erasure of the same or restriction of the processing, to object to the processing and ask for the portability or the copy of your data; you can also revoke the consent at any time (this will not affect the lawfulness of the processing based on the consent given before the revocation).
You have the right to lodge a complaint with the Authority for the Protection of Personal Data and to ask to the data controllers, at any time, information about the data processors and the persons authorized by the data controllers to process your data.
You can exercise your rights by contacting Armando Testa via email at privacy@armandotesta.it or at dpo@gruppotesta.it or by writing to the address indicated above.

10. What do we do if we change this policy – update of the privacy policy

We may introduce changes to our privacy policy. We will notify you in relation to these changes by publishing an updated version on our website and by notifying you via email and with other messages that may be available on the app. The new privacy policy will have a different date than the one shown below. Please visit the website periodically for updates.
Version updated as of December 13 2018.