Privacy Policy

This document contains a section dedicated to Users in the United States and their privacy rights.

This document contains a section dedicated to Users in Switzerland and their privacy rights.

This document contains a section dedicated to Brazilian Users and their privacy rights.

SITE PRIVACY POLICY
pursuant to art. 13 of the European Regulation on privacy 2016/679 (“GDPR”)

By browsing this site, you declare that you are over 16 years of age and give your consent to the processing of your personal data to allow NORD FLUID S.P.A., as Data Controller, to follow up on your contact (requests for information and/or release of a comment). Therefore, in compliance with the provisions of art. 13 of the European Regulation on privacy 2016/679 (hereinafter also simply “GDPR”), we are providing you, as an interested party, with the necessary information regarding the purposes and methods of processing your personal data, as well as the scope of communication and dissemination of the same.

1. PURPOSE OF THE PROCESSING
The data processing is aimed at the following activities:
a) allowing the user to navigate all sections of our website;
b) allowing the user to access our social networks (Linkedin and Facebook);
c) being able to interact directly with the Data Controller, via the contact form, in the “blog” section;
d) being able to interact directly with the Data Controller, via the contact form, in the “contact us” section;
e) helping the user to keep track of his navigation, for this purpose read the Cookie Policy.

2.METHODS OF DATA PROCESSING

Pursuant to art. 5 of the GDPR, the personal data being processed will be processed lawfully and correctly, and will not exceed the purposes referred to in point 1. Your personal data will be processed in compliance with the principles of minimization and limitation of purposes and conservation pursuant to art. 5 no. 1 letter. e) of the GDPR, will be stored for:

-the purposes referred to in point no. 1, letters a) and b), for the duration of navigation;
-the purpose referred to in point no. 1, letter c), for 24 months from receipt of the comment sent to the Data Controller;
-the purpose referred to in point no. 1, letter d), for 24 months from the response provided by the Data Controller.

The processing will be carried out by means of the operations or set of operations as set out in art. 4, no. 2 of the GDPR and can be carried out with or without the aid of electronic or automated tools and according to logics that fully respond to the purposes pursued. In both cases, the Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction, thus basing the processing on the various principles of the Regulation: by design and by default (art. 25 GDPR) and by adopting the correct technical-organizational measures (art. 32 GDPR).

The data processing will be carried out by the Data Controller, by persons authorized to process data, as well as by Data Processors, formally appointed and trained pursuant to the Regulation.

The complete list of Data Processors is available upon request from the Data Controller.

3.LEGAL BASIS OF THE PROCESSING, NATURE OF THE DATA PROVISION AND CONSEQUENCES OF REFUSAL

The provision of personal data for the purposes referred to in point no. 1, letters a) and b), or for browsing, occurs pursuant to art. 6, letter a). b) GDPR (pre-contractual measures) and is strictly necessary to allow the user to navigate all the sections that make up the site. The data collected for purposes c) and d), or for the contact forms, which are the only sections that allow interaction between the site and the user, are the personal data (name) and contact details (email) of the user, as well as a description of the contact (description of the request or description of the comment). The processing to achieve these purposes is carried out pursuant to art. 6, par. 1, letter a) of the GDPR (consent of the interested party) which is released in correspondence with the specific section, to allow the Data Controller to follow up on the contact proposed by the user. It should be noted that any refusal by the interested party to provide their personal data will make it impossible for the Data Controller to provide the service requested by the user. The processing for the purpose referred to in point no. 1, letter e), is carried out pursuant to art. 6, par. 1, letter a) of the GDPR (consent of the interested party), to allow the user to choose the tracking tools (for more specific information, please refer to the cookie policy).

4. SCOPE OF DATA COMMUNICATION

The data, subject to processing, may be communicated to the subjects who act as Data Processors, pursuant to art. 28 GDPR, such as, for example, external collaborators, technicians and, in general, to all those subjects to whom communication is necessary for the correct fulfillment of the purposes indicated in point no. 1. The persons in charge and the Managers will process the data only if necessary for the performance of the tasks assigned to them and after their training. All this without prejudice to the guarantee of protection of the Rights and Freedoms of the interested party.

5. SCOPE OF DATA DISSEMINATION

Personal data are not subject to dissemination.

6. TRANSFER OF DATA ABROAD

Personal data within the scope of the purposes mentioned in point no. 1, may be transferred to Data Processors resident in European Union countries, if such transfer is functional for the provision of the services offered by the Data Controller. Furthermore, in the event of data transfer to Third Countries (for example for the use of a cloud platform and/or for the storage of the same data) they will be processed in accordance with the provisions of articles 44 and following of the GDPR.

7. RIGHTS OF THE INTERESTED PARTY

Pursuant to art. 15, 16 and 17 of the GDPR, you may assert your rights by contacting the data controller. In particular, in accordance with art. 15 of the GDPR, you may obtain from the data controller: • confirmation of the existence or otherwise of your personal data and their provision in an intelligible form; • know the origin of the data; • know the purposes and methods of processing; • know the logic applied to the processing; • know the identification details of the data controller and the subjects to whom the data may be communicated; • the updating, rectification and integration of the data; • the cancellation, transformation into anonymous form or blocking of data processed in violation of the law. The interested party may object, for legitimate reasons, to the processing of data concerning him/her, even if pertinent to the purpose of the collection and also has the right to data portability pursuant to art. 20 of the GDPR. To exercise the aforementioned rights, you can contact the Data Controller by sending a request via email to the contact details below.

8. DATA CONTROLLER – DATA PROTECTION OFFICER

The Data Controller is NORD FLUID S.P.A – Single-member company, VAT number: 06088940157, with registered office: in Milan (20123 – MI), Via Carducci, 26, in the person of its legal representative pro tempore. The Data Controller can be contacted at the following address: privacy@nordfluid.it

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information.

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

Internet or other electronic network activity information

Personal Information collected or disclosed: Usage Data, Trackers, coarse location, first name, last name, email address, various types of Data, IP address, answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events, number of Users, session statistics, various types of Data as specified in the privacy policy of the service

Purposes:

Displaying content from external platforms
Displaying content from external platforms
Displaying content from external platforms
Spam and bots protection
Contacting the User
Tag management
Collection of privacy-related preferences
Spam and bots protection
Analytics
Analytics
Further information about Personal Data
Traffic optimisation and distribution
Traffic optimisation and distribution

Retention period: for the time necessary to fulfill the purpose

Sold or Shared *: Yes

Targeted Advertising *: No

Third-parties: Fonticons, Inc. , Google LLC, Defiant, Inc., iubenda srl, Cloudflare, Inc.

Service providers or contractors: this Website

Identifiers

Personal Information collected or disclosed: first name, last name, email address, various types of Data, Trackers, Usage Data, various types of Data as specified in the privacy policy of the service

Purposes:

Contacting the User
Data transfer outside of the UK
Data transfer outside of the UK
Data transfer outside the EU
Data transfer outside the EU
Data transfer outside the EU
Data transfer outside of the UK
Traffic optimisation and distribution
Hosting and backend infrastructure

Retention period: for the time necessary to fulfill the purpose

Sold or Shared *: Yes

Targeted Advertising *: No

Third-parties: Cloudflare, Inc., VHosting Solution s.r.l.

Service providers or contractors: this Website

Geolocation data

Personal Information collected or disclosed: Trackers, Usage Data, coarse location

Purposes:

Spam and bots protection

Retention period: for the time necessary to fulfill the purpose

Sold or Shared *: Yes

Targeted Advertising: *: No

Third-parties: Defiant, Inc.

Inferences drawn from other personal information

Personal Information collected or disclosed: Usage Data, Trackers, answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events

Purposes:

Spam and bots protection

Retention period: for the time necessary to fulfill the purpose

Sold or Shared *: Yes

Targeted Advertising: *: No

Third-parties: Google LLC

*You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights in particular to opt out of certain processing activities you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Website.

For example, you directly provide your Personal Information when you submit requests via any forms on this Website. You also provide Personal Information indirectly when you navigate this Website, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Website and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have

The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana you have

The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have

The right to opt out of the processing of your Personal Information for Targeted Advertising;
The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Website.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Further information for Users in Switzerland

This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

The rights of Users according to the Swiss Federal Act on Data Protection

Users may exercise certain rights regarding their Data within the limits of law, including the following:

right of access to Personal Data;
right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
right to receive their Personal Data and have it transferred to another controller (data portability);
right to ask for incorrect Personal Data to be corrected.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.

Further information for Users in Brazil

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the “Lei Geral de Proteção de Dados” (the “LGPD”), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

your consent to the relevant processing activities;
compliance with a legal or regulatory obligation that lies with us;
the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
studies conducted by research entities, preferably carried out on anonymised personal information;
the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
the exercising of our rights in judicial, administrative or arbitration procedures;
protection or physical safety of yourself or a third party;
the protection of health – in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests

Your Brazilian privacy rights

You have the right to:

obtain confirmation of the existence of processing activities on your personal information;
access to your personal information;
have incomplete, inaccurate or outdated personal information rectified;
obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
obtain information on the possibility to provide or deny your consent and the consequences thereof;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except for anonymised information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
revoke your consent at any time;
lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an automated decision; and
request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
when the transfer is necessary to protect your life or physical security or those of a third party;
when the transfer is authorised by the ANPD;
when the transfer results from a commitment undertaken in an international cooperation agreement;
when the transfer is necessary for the execution of a public policy or legal attribution of public service;
when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.