PRIVACY / COOKIE POLICY

Zephyr Trading srl – Socio Unico | P.Iva IT00752690115 - Via Privata Oto 10, 19136 La Spezia Italy, (hereinafter only “ZEPHYR”), in its capacity as data controller regarding the processing of personal data pursuant to the EU Regulation 679/2016 directly applicable starting from May 25, 2018 – General Data Protection Regulation (“GDPR”) (hereinafter Privacy Code and GDPR are collectively referred to as “Applicable Law”) recognises the importance of personal data protection and considers that preserving the confidentiality of your personal data is one of the main objectives of its activity.


Before providing any personal data, ZEPHYR invite you to carefully read this privacy policy (“Privacy Policy”), since it contains important information regarding the personal data protection and security measures adopted in order to ensure confidentiality and full respect of the Applicable Law. Moreover, this Privacy Policy:
Is intended for the website www.zephyrtrading.com whilst it does not apply to other websites that could potentially be accessed by clicking external links;
Is to be construed as an information notice pursuant to Article/Section 13 of the Applicable Law, intended for those who interact with the Website;
Is in conformity with Recommendation n. 2/2001 related to the minimum requirements for online data collection in the European Union, adopted on 17 May 2001 by the Article 29 Working Party.


Zephyr informs you that processing of your data will be carried out in accordance with the principles of, lawfulness, fairness, transparency, accuracy, purpose and storage limitations, data minimisation, integrity and confidentiality. Your personal data will be processed in accordance with the legislative provisions of the Applicable Law and of the confidentiality obligations included therein.

 

TABLE OF CONTENTS
Please find below the table of contents, which will enable you to quickly track information related to the processing of your personal data.

 

1. DATA CONTROLLER AND DATA PROTECTION OFFICER
2. PERSONAL DATA SUBJECT TO PROCESSING
2.1 Browsing data
2.2 Data provided on a voluntarily basis
2.3 Cookies and similar technologies
3. PURPOSES, LEGAL BASIS AND VOLUNTARY OR OBLIGATORY NATURE OF DATA PROCESSING
4. RECIPIENTS
5. TRANSFERS
6. DATA RETENTION
7. YOUR RIGHTS
8. AMENDMENTS

 

1.    DATA CONTROLLER AND DATA PROTECTION OFFICER
Pursuant to the Applicable Law, the data controller of the processing activates carried out through the Website is ZEPHYR as defined above.

2.    PERSONAL DATA SUBJECT TO PROCESSING

“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, mental, economic, cultural or social identity of that natural person.

By means of the Website, ZEPHYR collects the following Personal Data:

a. Browsing Data

The computer systems and software procedures used to operate the Website collect some Personal Data, the transmission of which is an integral part of Internet communication protocols. This information is not collected to be associated with you but, by its very nature, it may allow you to be identified by processing and associating it with data held by third parties. Among collected Personal Data there are IP addresses or domain names of the devices used by you to connect to the Website, the URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as a reply, the numeric code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding your operating system and device environment.
This data is used exclusively for the purposes of obtaining anonymous statistics on the use and proper functioning of the Website to control its correct functioning, to enable ZEPHYR to correctly provide the various functionalities to you, as well as for security reasons. These Personal Data may also be used to ascertain any liability in cases of alleged computer crimes against the Website or against third parties and they will be deleted after XX days.

b. Data provided on a voluntarily basis

By means of the Website you may voluntarily provide Personal data such as name, e-mail address for subscribing the on-demand service “ICT Insider” or to contact ZEPHYR via the “Send us a message” form. ZEPHYR will process these data in accordance with the Applicable Law and on the presumption they refer to you or to third parties who have authorised you to provide them pursuant to an appropriate legal basis which legitimise the processing at stake. In this case, you act as an independent data controller, assuming all relevant obligations and responsibilities according to the Applicable law. In this regard, you hence waive, in the full sense of the term, the right to all disputes, claims, claims for damages due to processing etc., which may be submitted to ZEPHYR of the said third party whose Personal Data have been processed through your use of the Website in breach of the Applicable Law.

c. Cookies and similar technologies

ZEPHYR collects Personal Data using cookies. You may find further information on the use of cookie and similar technologies here. (link a cookie policy)

 

3.    PURPOSES OF THE PROCESSING AND VOLUNTARY OR OBLIGATORY NATURE OF PROVIDING THE DATA

The Personal Data that you provide by using the Website will be processed by ZEPHYR for the following purposes:

a) Purposes related to the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g., contact request made by using the “Send us a message” form available on the Website);

b) Purposes related to research/statistical analyses on aggregated or anonymous data, without the possibility of identifying the data subject, aimed at measuring the functioning of the Website, traffic, usability, and interest;

c) Purposes related to the compliance with a legal obligation to which the controller is subject;

d) Purposes necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity;

e) Newsletters, marketing and advertising, market analysis and surveys, promotional activities, customer satisfaction surveys.

*For the purposes of processing connected with the commercial activity indicated in point e) activities related to commercial activity mail order, marketing and advertising, market analysis and surveys, promotional activities, customer satisfaction surveys.

The legal basis for the processing of Personal Data for the purposes referred to in point a) is the provision of a service or the response to a request that does not require you prior consent under the Applicable Law.
The purpose referred to in point b) does not imply the processing of Personal Data, whilst the processing for the purpose referred to in point d) constitutes a legitimate processing of Personal Data within the meaning of the Applicable Law because, once the Personal Data have been provided, the processing is indeed necessary to comply with a legal obligation to which ZEPHYR is subject.

Providing your Personal Data for the above-mentioned purposes is voluntary, however, any refusal to provide such data may not allow ZEPHYR to reply to your requests and to comply with legal obligations to. to which ZEPHYR is subject.

4. RECIPENTS

Your Personal Data may be disclosed, in close relation to the purposes specified above in section 3, only to:
a. subjects necessary for order fulfilment of the services offered through the Website e.g., sending e-mails and analysing data, which typically process Personal Data on behalf of ZEPHYR as data processors.
b. persons authorised by ZEPHYR to process Personal Data, that are committed to/ or under an appropriate statutory obligation of confidentiality (e.g., employees and lawyers of ZEPHYR) (a. and b. are hereinafter collectively referred to as “Recipients”);
c. law enforcement agencies and public authorities when so required by the Applicable Law.

5. TRANSFERS

Some of your Personal Data are transferred to Recipients who may be established outside the European Economic Area. ZEPHYR ensure that the processing of Personal Data by these Recipients is carried out pursuant to the Applicable Law. In fact, the transfer of Personal Data is based alternatively on an adequacy decision or the Standard Contractual Clauses issued by the European Commission. Further details and the signed agreements may be requested to the DPO.

6. DATA RETENTION

ZEPHYR will process your Personal Data only for the duration necessary to achieve the purposes described in section 3 (e.g., ZEPHYR will process your Personal Data for the on-demand service “ICT Insider” until you will decide to unsubscribe). Apart from the above, ZEPHYR will retain your Personal Data for a period of time necessary or permitted to comply with the Applicable Law (Art. 2947(1)(3) of the Italian Civil Code).

7.    YOUR RIGHTS

Pursuant to and to the extent allowed by the Applicable Law, you have the right, at any time, to request to ZEPHYR access to, rectification, erasure, restriction of the processing concerning your Personal Data or to object to relevant processing activity and to receive in a structured, commonly used and machine-readable format the Personal Data concerning you.

Requests to exercise your rights must be sent to the following address: dpo[at]ictlegalconsulting.com

In any case, pursuant to the Applicable Law, you have the right to lodge a complaint with the relevant supervisory authority (the Italian Garante) if you believe that the processing of your Personal Data is against the Applicable Law.

8.    AMENDMENTS

This Privacy Policy came into force on 25 May 2018 ZEPHYR reserves the right to amend or to update its content, whether in whole or in part, including following changes in the legal and regulatory obligations regarding data protection. ZEPHYR will inform you on such amendments and updates through their publication on the Website as soon as they are adopted, and they will be binding from the moment of their publication. ZEPHYR therefore invites you to visit this section of the Website regularly in order to be aware of the most recent and updated version of the Privacy Policy, so that you are always updated on the processing activities that ZEPHYR carries out.

 

Cookie Policy

1. Definitions and characteristics of cookies

Cookie and similar technologies are information sent/read by websites and apps on your devices during their first visit, which are then transmitted back to those websites and apps during the next visit. Thanks to cookies and similar technologies, websites and apps remember your actions and preferences (such as login data, the default language, font sizes, additional display settings, etc.) so that they do not need to specify them again on the next visit.
These technologies are used to perform IT authentications, session monitoring, and to store information about the activities of users who access a service, and may also contain a unique identifier that allows for monitoring of user experiences on the site for statistical or advertising purposes.
There are indeed various types of cookies, depending on their features and functions, and these may remain on your device for different periods of time: so-called session cookies, which are automatically deleted when you close your browser; and so-called persistent cookies, which remain on your device until a pre-established date.
According to the Applicable Law, your prior explicit consent for the use of cookies is not always required. In particular, such consent is not required for “technical cookies”, i.e. those used for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or as strictly necessary to provide a service explicitly requested by the user. In other words, cookies which are indispensable for the operation of a website or to perform tasks requested by the user.
On the other hand, your prior consent is instead required for non-anonymised “analytics” and “profiling” cookies, i.e. those aimed at providing analytical statistics of the usage of a website or those creating profiles for users in order to send them advertising messages in line with the preferences they have expressed while surfing the web.

 

2. Types of cookies used by the Website and the possibility of (de-)selection
While navigating the Website, you will receive the following cookies:
Third-party cookies, i.e., cookies from websites or servers other than that of the ZEPHYR TRADING. Please note that these third parties, listed below with the corresponding links to their privacy policy and opt-out mechanisms, are processing your Personal Data as data processors on behalf of ZEPHYR TRADING. Indeed, such third-party providers have signed data processing agreements with ZEPHYR TRADING and cookies have been anonymised by means of masking IP addresses. Third party cookies are:

– Google Analytics. These cookies help ZEPHYR TRADING to analyse the performance of the Website. To opt-out from Google Analytics cookie, you may download and install the Google Analytics opt-out browser add-on. This add-on instructs Google Analytics JavaScript (ga.js, analytics.js, and dc.js) to prohibit sending information to Google Analytics. The browser add-on is available for most modern browsers. Learn more about the Google Analytics opt-out browser add-on here.
– Worpress. These are technical cookies provided by WordPress in order to enhance the navigation of the Website (i.e. proving the Website in your own language, if available). If you want to disable such cookies, please refer to WordPress’s privacy policy available at the following links: https://en.support.wordpress.com/cookies/ and https://automattic.com/privacy/

3. How to view and modify the cookies through your browser
You may authorize, block or delete (in whole or in part) cookies through the specific functions of your browser. However, in the hypothesis in which all or some of the cookies are disabled, it may not be possible to consult the Website, or certain services or certain features of the Website may not be available or may not work properly and/or you may be forced to change or manually enter some information or preferences each time you visit the Website.
For more information on how to set preferences on the use of cookies through your browser, consult these instructions:

Internet Explorer

Firefox

Safari 

Chrome