Information on the processing of personal data pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR).
1. Data Controller
Data Controller: Circular S.r.l.
Registered office: Via Libertà 34, 90141 Palermo (PA) - Italy
VAT No. and Tax Code: 06958250828
E-mail: info@circular.srl
Certified e-mail (PEC): circularsrl@arubapec.it
2. Categories of personal data processed
When users browse this website, technical data necessary for the operation and security of the IT systems may be processed, including IP address, browser type, device used, date and time of requests and pages visited.
When users submit the contact form or otherwise voluntarily communicate with Circular S.r.l., the Company may also process information directly provided by the user, such as name, e-mail address, subject of the request and message content.
Users are requested not to provide personal data that are not necessary for the purpose of their enquiry, particularly special categories of personal data under Article 9 GDPR, unless strictly necessary.
3. Purposes and legal bases of processing
Personal data may be processed for the following purposes:
a) Website operation and browsing
To enable the correct display and operation of the website, ensure system security and prevent misuse or unauthorised access.
The legal basis is the Data Controller’s legitimate interest in ensuring the security and proper operation of its IT systems pursuant to Article 6(1)(f) GDPR.
b) Responding to enquiries
To respond to requests for information, quotations, collaboration proposals or other communications submitted by users.
The legal basis is the taking of steps at the request of the data subject prior to entering into a contract, where applicable, pursuant to Article 6(1)(b) GDPR, as well as the Data Controller’s legitimate interest in managing communications received pursuant to Article 6(1)(f) GDPR.
c) Compliance with legal obligations
Personal data may be processed where necessary to comply with obligations imposed by laws, regulations or competent authorities.
The legal basis is Article 6(1)(c) GDPR.
Personal data collected through the contact form will not be used for promotional or marketing activities without an appropriate legal basis.
4. Provision of personal data
The provision of data requested in mandatory fields of the contact form is necessary in order for Circular S.r.l. to receive and process the enquiry.
Failure to provide such information may make it impossible to respond to the request.
Fields marked as optional may be left blank.
5. Processing methods and security
Personal data are processed using electronic systems and, where necessary, manual procedures, with appropriate technical and organisational measures designed to protect them against unauthorised access, loss, destruction, alteration or unlawful disclosure.
Access to personal data is limited to authorised persons who require such access in order to perform their duties.
6. Recipients of personal data
Personal data may be disclosed, where necessary, to service providers assisting Circular S.r.l., including:
- hosting and IT infrastructure providers;
- e-mail service providers;
- technical support, maintenance and IT service providers;
- consultants and professional advisers;
- public authorities or other parties where disclosure is required by law.
Depending on the circumstances, such parties act as processors pursuant to Article 28 GDPR or as independent data controllers.
Personal data will not be publicly disclosed unless required by law.
7. Transfers outside the EEA
Some technology service providers may process personal data outside the European Economic Area.
Where this occurs, Circular S.r.l. adopts or verifies the existence of the safeguards required under Chapter V of the GDPR, such as European Commission adequacy decisions or Standard Contractual Clauses, where applicable.
8. Data retention
Personal data submitted through the contact form are retained for the period necessary to manage and respond to the request.
Where the communication results in a contractual or professional relationship, the data may be retained for the period necessary to manage that relationship and comply with applicable legal obligations.
Technical data and system logs are retained for the period necessary to ensure the security, operation and maintenance of the website, according to the configurations of the systems and service providers used.
Data may be retained for longer where necessary to comply with legal obligations or for the establishment, exercise or defence of legal claims.
9. Cookies and similar technologies
The website may use cookies and similar technologies that are necessary for its operation.
Detailed information on the cookies used, their purposes and, where applicable, the management of user consent is provided in the relevant Cookie Policy, where required.
10. Data subject rights
Where provided for by the GDPR, data subjects have the right to:
- obtain access to their personal data;
- request rectification of inaccurate data;
- request erasure of their data;
- request restriction of processing;
- object to processing;
- request data portability, where applicable;
- withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
Requests may be sent to info@circular.srl or by certified e-mail (PEC) to circularsrl@arubapec.it.
Data subjects also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) if they consider that their personal data are being processed in breach of the GDPR.
11. Automated decision-making
Circular S.r.l. does not use personal data collected through this website for automated decision-making producing legal effects concerning users or similarly significantly affecting them, nor for profiling producing such effects.
12. Links to third-party websites
The website may contain links to websites or services operated by third parties.
Circular S.r.l. is not responsible for the data processing practices of such third parties. Users should review the relevant privacy notices before providing personal data.
13. Changes to this Privacy Policy
Circular S.r.l. may update this Privacy Policy to reflect changes in legislation, technologies or the services provided.
The updated version will be published on this page together with the date of the latest revision.