Privacy Policy

Privacy information pursuant to art. 13 EU Reg. 679/2016

In accordance with the provisions of EU Regulation no. 679 of 2016 on the protection of personal data, and in particular by art. 13 of the same, hereby the Company PRIMO SRL (CF and PI 04366080275, with registered office in 30030 PIANIGA (VE), Via Noalese Sud, 66 Mellaredo, Tel. 041-468966 Email informs you that this information is valid for this website and for websites owned, licensed and / or managed by PRIMO SRL as data controller which will be based on the principles of lawfulness, correctness, transparency and of the additional principles referred to in art. 5 EU Reg. 679/2016.

A) Treatment of personal data

By “treatment” we mean what is defined in point 2 of Article 4 of EU Reg. 679/2016 and that is any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data , such as the collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available , comparison or interconnection, limitation, cancellation or destruction.

B) Legal basis of the processing

The data is processed on the basis of consent. The provision of data and therefore the consent to the collection and processing of data is optional, the user can deny consent and can revoke a consent already provided at any time by contacting the owner.

However, denying consent may make it  impossible to provide some services, execute contracts, respond to requests and the use of any online applications used by the owner or included in this website may not be available or not fully usable.

As regards, instead, the marketing and advertising communication activities carried out  by the Data Controller, the lack of consent to the processing of the data of the interested party for this purpose will have, as the only consequence, that of making it impossible to send advertising material and informative.

The legal bases legitimizing the processing of your data by this company are given:

  • the need to execute a contract of which you, as an interested party, are a party (letter B art. 6 EU Reg. 679/2016);
  • the need to fulfill legal obligations to which the Company is subject (legal basis referred to in letter C, paragraph 1, art.6 EU Reg. 679/2016);
  • from the legitimate interest of the Company in the correct execution of the existing relationship with you (legal basis referred to in letter F, paragraph 1, art.6 EU Reg. 679/2016)
  • with regard to communications via paper mail, email, SMS, MMS or other tools, from your consent (legal basis referred to in letter A, paragraph 1, art. 6 of EU Reg. 679/2016).

C) Purpose of the treatment:

The personal data of the interested parties collected from them and / or through this website constitute data subject to processing. They are processed and used for the following purposes: instrumental activities to requests received from the interested parties themselves; execution of contracts; carrying out pre-contractual phases; contractual and post-contractual assistance; accounting and tax compliance; defense in court; provision of services.

Subject to the separate consent of the interested party,  personal data can be processed and used with the aim of allowing the Data Controller to send him information, newsletters, carry out marketing activities, send paper mail, email, SMS , MMS, etc. For this option it is necessary for the interested party  to provide the Data Controller with consent to the processing in a voluntary and separate manner by ticking the appropriate box in any request, registration or communication forms present on this website.

D) Data collected:

This site makes use of log files in which information collected in an automated manner is stored during user visits. The information collected could be the following:

– internet protocol address (IP);
– type of browser and device parameters used to connect to the site;
– date and time of visit;
– web page of origin of the visitor (referral);
– possibly the number of clicks.

The aforementioned information is processed in an automated form in order to verify the correct functioning of the site, and for security reasons.

For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may possibly also include personal data such as the IP address, which could be used, in accordance with applicable laws, in order to block attempts to damage to the site itself or to cause damage to other users, or in any case try to prevent harmful activities or activities constituting a crime. These data are never used for the identification or profiling of the user, but only for the purpose of protecting the site and its users, except in the case of provisions of the competent authorities.

These data may also be used by the Data Controller in order to obtain anonymous statistical information on the use of the site with the aim of identifying the preferred pages by users and therefore providing increasingly adequate content and to check its correct functioning.

The following data is also collected through the site through the appropriate forms:

Personal data of the interested party including addresses, telephone numbers, emails
Possible VAT number
Tax code
Credentials for access to restricted areas when granted
Data released spontaneously by the interested party

E) Processing methods:

The data processing is carried out through IT procedures or in any case electronic means or paper supports by specifically authorized persons who act under the authority and control of the Data Controller based on art. 29 of the European Regulation n. 679/2016 and may possibly be processed by internal or external subjects appointed as responsible in the forms provided for by the European Regulation no. 679/2016 with particular reference to Article 28, equipped with a specific contractual assignment, the instructions provided by the Data Controller who also ascertains their competences in matters of privacy and rights of the interested parties.

The list of any Managers and / or persons in charge of the processing is available upon request of the users of the site.

Personal data are stored in paper and / or computer archives and will be processed in ways that guarantee their security and confidentiality and in full compliance with the provisions of EU Reg. 679/2016 – with the support, as well as paper materials , also of IT or telematic materials as well as through automated tools designed to store, manage or transmit the data. When the data is collected through the use of IT and / or telematic tools (websites of the owner, PC, notebook, tablet, mobile phone, SIM, internet key, e-mail, internet access) they may also be known by the companies, Technicians or personnel providing assistance to computer hardware and / or software systems,

Personal data are recorded and stored on electronic databases owned by the Company PRIMO SRL (CF and PI 04366080275, with registered office in 30030 PIANIGA (VE), Via Noalese Sud, 66 Mellaredo, Tel. 041-468966 Email , Data Controller, as well as, as regards this website, will be stored on servers in the territory of countries belonging to the European Union (EU) – ARUBA spa, with registered office in Via San Clemente, 53 – 24036 Ponte San Pietro (BG ).

F) Communication and dissemination:

In principle, personal data will not be disclosed, sold or exchanged with third parties, except if the communication is necessary for the pursuit of the aforementioned purposes and except in cases in which the interested party gives express authorization and in the cases provided for by the Laws and regulations in force.

However, for the performance of certain activities relating to the processing of your personal data, the Data Controller may communicate your data to subjects who carry out activities strictly connected, useful or necessary for the execution of the service and / or any operations requested and necessary by you. , therefore, to the correct execution of the contractual commitments undertaken towards you by the Company such as, by way of example and not limited to:

  • transport and forwarding companies;
  • subjects who provide specific processing or consultancy services for corporate, legal or fiscal / tax administration and management, operating on behalf of our Company;
  • subjects that provide information systems processing and / or maintenance services;
  • subjects that deal with the maintenance, contents and functions of this website and companies that provide hosting services, cloud, IT applications in saas mode (software as a service) and web applications in general
  • company supplying the IT security system;
  • credit institutions;
  • credit recovery institutes;
  • associated or controlled companies;
  • other entities, public or private, for the fulfillment of obligations established by law.

An updated list of these subjects can be requested from the Company as Data Controller.

The same will be able to indicate which of these subjects operate as “Data Processors”, carrying out a treatment on behalf of the Owner. The data processors selected by our company have undertaken to implement adequate technical and organizational measures in such a way that the processing meets the requirements set out in Reg EU 679/2016 and guarantees the protection of your personal data.

The persons in charge also undertook, with a specific and signed letter of appointment, to fulfill all the specific obligations pursuant to art. 28 EU Reg 679/2016 and to act, pursuant to Article 29 of the same Regulation, under the authority of the Data Controller and subject to his instruction, as well as to communicate to the Data Controller (pursuant to the second paragraph of Article 33 of EU Reg 679 / 2016) any violations of your personal data.

G) Transfer of data abroad:

Your personal data may be transferred abroad; however, given the impossibility of establishing as of now which countries the data will be transferred to, the Company undertakes to inform you of this as soon as possible and in any case not before the transfer takes place, providing, if from a third country, to collect your consent or to offer other suitable guarantees

H) Rights of the interested party:

Rights exercisable by the interested party; complaint to the Supervisory Authority and judicial appeal

With regard to the Data Controller, it is always possible to exercise the rights referred to in Articles. 15 ss of EU Regulation 679/2016 (access to personal data, rectification or cancellation of the same, limitation of processing, opposition to processing, data portability), in terms of the rights of the interested party, the provisions of Legislative Decree . June 30, 2003 n. 196 as amended by Legislative Decree no. 101/2018

Furthermore, it is always possible to lodge a complaint with the competent supervisory authority (pursuant to art.77 EU Reg 679/2016) or judicial appeal (pursuant to art.79 EU Reg 679/2016) if the interested party believes that the rights he enjoys have been violated as a result of processing.


The data will be kept for the time strictly necessary for the performance of the service requested by you, as well as for the pursuit of the additional purposes set out in point C) of this information, without prejudice to the right to object to the processing freely exercisable by the interested party.

For tax purposes, the retention of only the data collected in this sense, the retention time is that provided for by the current tax legislation.

L) Cookies:

This site uses technical cookies that allow the site to function properly. It also carries third-party cookies as per the extended information that you can read by clicking here, or by going to the web address:

M) Contact details with the Data Controller:

To exercise their rights and to request information, the interested parties may contact:

Company PRIMO SRL (CF and PI 04366080275, with registered office in 30030 PIANIGA (VE), Via Noalese Sud, 66 Mellaredo, Tel. 041-468966 Email


Last update of this information 09/23/2019

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