Privacy & Cookie Policy

Latest update 27/03/2023

PRIVACY POLICY according to ARTICLE 13 of the GENERAL DATA PROTECTION REGULATION UE 2016/679

for the users of this website

For us, data protection is an important issue, so we would like to inform you about the way in which your data is processed and the rights you can exercise under the current data protection legislation, in particular the EU Regulation 2016/679 (hereinafter also referred to as “GDPR”).

Data Controller

Diamond International S.r.l.

Via Lorenzo Mascheroni n. 31, 20145, Milano (MI)

E-mail: [email protected]

Categories of personal data processed by the Controller

The data processed by the Controller (pursuant to article 4.1 of GDPR) could be, by way of example only, but certainly not exhaustive:

Identification data (such as name, surname, etc.);
Contact data (such as, address, e-mail address, etc.);
Data relating to the requests or questions made by the data subject.

Purposes and legal basis for personal data processing
- Purposes based on the data subject’s consent (pursuant of article 6.1 (a) of the GDPR)

Personal data may be processed for certain purposes for which the data subject has given his/her consent.

Answer requests or questions sent through the contacts listed on the website, send spontaneously or through the specific section on the website.

The personal data’s retention period for the above-mentioned purposes are:

For purpose under a: until the fulfilment of the request or question.

Recipients or categories of recipients of personal data (pursuant to article 13.1 (e) of the GDPR) *

In relation to the mentioned purpose, the Data Controller can communicate your personal data to:

Internal offices and authorized personnel;
Companies and professionals which offer IT related services, like electronic processing of data, software management, website management and of IT consultancy.

*More information regarding recipients (pursuant of art. 4.9 of the GDPR) is available on request to the Controller at the address above listed.

Recipients or categories of recipients of the personal (pursuant of art. 13 paragraph 1(f) of the GDPR) and data transfer outside the EU

The Controller does not intend to transfer your personal data to Countries which are not member of the EU or the EEA for the above-mentioned purpose.

The Data Subject’s rights

The data subject can exercise the following rights, in relation to personal data mentioned in this privacy policy, as stated by the GDPR:

Right of access by the data subject [art. 15 of EU Regulation] (right to be informed on the processing carried out on his/her personal data and, if necessary, receive a copy of them);
Right to rectification [art. 16 of EU Regulation] (data subject has the right to rectify incorrect data concerning him/her);
Right to erasure without unjustified delay (“right to be forgotten”) [art. 17 of EU Regulation] (data subject has the right to have deleted his/her personal data);
Right to restriction of processing, as provided by article 18 of EU Regulation, among the other cases, in case of illicit processing or contestation of the accuracy of personal data by the data subject [art. 18 of EU Regulation];
Right to data portability [art.20 of EU Regulation], (data subject has the right to receive the personal data concerning him/her, which he/she or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as provided by the same article);
Right to object to processing [art. 21 of EU Regulation] (the data subject has the right to object processing of personal data as provided by article 21 of EU Regulation);
Right to not be subject to automated individual decision-making [art. 22 of EU Regulation] (The data subject shall have the right not to be subject to a decision based solely on automated processing).

Regarding those purposes which require consent, the data subject can revoke his/her consent at any time, and it will affect processing from the moment of revocation, safe for conservation periods established by law. Generally, revocation of consent affects only future processing.

The above-mentioned rights can be exercised as established by the GDPR contacting the controller at the above listed addresses.

Diamond International S.r.l., in compliance to art. 19 of the GDPR, when it is possible, communicate to the recipients, to which personal data has been transferred, any corrections, cancellations or limitation of processing as requested by the data subject.

Right to lodge a complaint (art. 13 paragraph 2 (d) of the GDPR)

If the data subject considers that his/her right has been compromised, he/she has the right to lodge a complaint to the supervisory authority (or Data protection Supervisor), according to the methods indicated by the same authority. If you are Italian you can refer to the following link: http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524 or by lodging a complaint to the Italian Authority for the Protection of Personal Data

Potential consequences of failure to provide personal data and natura of the providing of data (art. 13 paragraph 2 (e) of the GDPR)

8.1 In case of processing personal data based upon consent

We inform you that the above-mentioned purposes have as lawful base the consent, and that in relation to such purposes, the data subject can revoke his/her consent at any time, and that the revocation’s effects will affect only from the time of revocation, safe for conservation periods established by law. Generally, the revocation of consent will only affect future processing. Thus, the processing which has been performed before the consent’s revocation will not be affected and will maintain its lawfulness.

The complete or partial lack of consent will not guarantee the complete performing of services, in relation to the individual purposes for which it will be negated.

Please note that with reference to the request for information, while consent to the processing of personal data remains free and optional, it is necessary to process the request. Therefore, the sending of the request or equivalent manifestation of will should be considered as the granting of consent, which will always be revocable with the consequences described above.

When data is no longer needed, it will be deleted. If its deletion is impossible or only possible with a disproportionate effort due to a particular storage method, the data cannot be processed and must be stored in inaccessible areas.

Presence of an automated decision-making process (included profiling activity)

The use of a purely automated decision-making processes as detailed by Article 22 of the GDPR is currently excluded. Should it be decided in the future to establish such processes on a case-by-case basis, the data subject will be notified separately if this is required by law or if this information notice is updated.

Methods of data processing

Personal data will be processed both in analog and electronic format and inserted in the applicable data bases (clients, potential clients, etc.), which can be consulted and processed by the operators and processors designated by the Data Controller who will be able to carry out the consultation, use, handling, comparison and any other appropriate operation, direct or automatic, respecting the legal requirements necessary to guarantee the confidentiality and the security of the data, as well as their accuracy, updating, and their relevancy to the declared purposes.

Processing of personal data for web surfing purposes

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified.

Among the information that can be collected we have the IP addresses, the type of browser or the operating system used, the addresses in notation URI (uniform resource identifier), the domain name and the addresses of the websites from which the access or exit (referring / exit pages), the time at which the request was made to the server, the method used and information on the response obtained, further information on the user’s navigation on the site (see also the related section to cookies) and other parameters relating to the operating system and the user’s computer environment.

These same data could also be used to identify and ascertain responsibilities in case of any computer crimes against the website.

Notice concerning children under 14 years old

Children under 14 cannot provide personal data to the Controller. Diamond International S.r.l. will not be in any way responsible for any collection of personal data, as well as false statements, provided by the minor, and in any case, if you notice its use, the Controller will facilitate the right of access and cancellation forwarded by the legal guardian or by those who exercise parental authority.

Changes and updates

This privacy policy reports the date of its last update in the header.

Diamond International S.r.l. may change or update this privacy policy also due to future changes and or amendments of laws.

Legal references about the data subject’s rights

Article 15

Right of access by the data subject

The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

(a) the purposes of the processing;

(b) the categories of personal data concerned;

(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

(e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

(f) the right to lodge a complaint with a supervisory authority;

(g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

2.Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

3.The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

4.The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Article 16

Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Article 17

Right to erasure (‘right to be forgotten’)

1.The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;

(c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);

(d) the personal data have been unlawfully processed;

(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

(f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1). 2.Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

3.Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

(a) for exercising the right of freedom of expression and information;

(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);

(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

(e) for the establishment, exercise or defense of legal claims.

Article 18

Right to restriction of processing

1.The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

(a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

(b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

(c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims;

(d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

2.Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

3.A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

Article 19

Notification obligation regarding rectification or erasure of personal data or restriction of processing

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

Article 20

Right to data portability

1.The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where: (a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and (b) the processing is carried out by automated means.

2.In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3.The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

4.The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21

Right to object

1.The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

2.Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

3.Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4.At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information. 5.In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications. 6.Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Article 22

Automated individual decision-making, including profiling

1.The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

2.Paragraph 1 shall not apply if the decision: (a) is necessary for entering into, or performance of, a contract between the data subject and a data controller; (b) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or (c) is based on the data subject’s explicit consent.

3.In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

4.Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.

COOKIE POLICY

The following information is provided to the user in compliance with the provision of the Italian Authority for the protection of personal data of May 8^th, 2014 “Identification of simplified methods for the information and acquisition of consent for the use of cookies” and by the subsequent “Guidelines on cookies and other tracing instruments” of the 10^th of June 2021. To see for what purposes personal data is processed please verify the privacy policy located in the website’s footer.

DATA CONTROLLER

Diamond International S.r.l.

Via Lorenzo Mascheroni n. 31, 20145, Milano (MI)

E-mail: [email protected]

WHAT ARE COOKIES?

Cookies are small text strings that a website can send, during navigation, to your device (be it a PC, a notebook, a smartphone, a tablet; they are usually stored directly on the browser used for navigation). The same website that transmitted them can then read and record cookies that are on the same device to obtain various types of information. Which ones? For each type of cookie there is a clearly defined role.

HOW MANY TYPES OF COOKIES ARE THERE?

There are three basic macro-categories, with different characteristics: technical cookies (which are subsequently divided between necessary or navigational cookies and functional cookies), analytics (or statistical cookies) and profiling cookie.

Technical cookies are generally necessary for the correct functioning of the website and to allow navigation; without them you may not be able to view pages correctly or use certain services. For example, a technical cookie is essential to keep you logged in throughout your visit to a website, or to store your language settings, display settings, etc. Technical cookies can be further distinguished into:

navigation cookies, which guarantee the normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access reserved areas);
functionality cookies, which allow the user to navigate according to a series of selected criteria (for example, language, products selected for purchase) in order to improve the service provided to the user;

There are, also, the following categories of cookies:

analytics cookies, which can be assimilated to the technical ones only whenever they are used directly by the website controller to collect data in an aggregated form, on the number of user and how these users navigate through the website, and also whenever there are the necessary prerequisites specifically requested by the afore mentioned guidelines;
Profiling cookies are more sophisticated! These cookies have the purpose of profiling the user and are used to send promotional messages in line with the user’s preferences, as they are expressed by her/his actions during web surfing.

Profiling and analytics cookies, not assimilable to the technical ones, can also be called or classified as non-technical cookies.

Cookies can also be categorized as:

session cookies, which are deleted immediately when you close your browser;
persistent cookies, which – unlike session cookies – remain within the browser for a certain period of time. They are used, for example, to recognize the device that connects to the site and facilitate authentication operations for the user;
first-party cookies, i.e., cookies generated and managed directly by the operator of the website on which the user is browsing.
Third-party cookie, which are generated and managed by parties other than the operator of the website on which the user is browsing (usually by virtue of a contract between the owner of the website and the third party). Third party cookies can also include the profiling cookies (or the non-technical ones in general) mentioned and described before (for these types of cookies, read what has been said above, also with reference to the preemptive acquisition of the free consent). Concerning third party cookies, you can have more detailed information and updates on their usage and their retention period in the specific informational pages published by the third party, which You can access by specific links, inserted in the description of the single cookies listed below.

Exercising the Data Subject’s rights

The data subject, in relation to the personal data mentioned in this privacy policy, has the power to exercise the rights mentioned in the GDPR as below listed:

Right of access by the data subject [art. 15 of the GDPR]: the data subject has the right to obtain from the Data Controller confirmation that his personal data is being processed and, in this case, access to the information expressly provided for in the aforementioned article, including the purpose of the processing, the categories of data and recipients, the retention period, the existence of the right of cancellation, correction or limitation, the right to propose a complaint, all the available information on the origin of the data, the exemplary and non-exhaustive any existence of an automated decision-making process pursuant to art. 22 of the Regulations, as well as a copy of their personal data.
Right to rectification [art. 16 of the GDPR]: the data subject has the right to obtain from the data controller the correction and / or integration of the incorrect personal data concerning him, without unjustified delay;
Right to erasure (‘right to be forgotten’) [art. 17 of the GDPR]: the data subject has the right to cancel his / her personal data without unjustified delay, if one of the reasons expressly provided by the aforementioned article exists, including as an example and not exhaustive the need for treatment with respect to the purpose, revocation of the consent on which the treatment is based, opposition to the treatment in case it is based on non-prevailing legitimate interest, unlawful data processing, deletion due to legal obligations, data of minors treated in the absence of the conditions of applicability expected by art. 8 of the Regulations;
Right to restriction of processing [art. 18 of the GDPR]: in the cases provided by art. 18, including the unlawful processing, the contestation of the accuracy of the data, the opposition of the interested party and the loss of the need for treatment by the data controller, the information provided by the data subject must be processed only for storage unless the consent of him and the other cases expressly provided by the aforementioned article;
Right to data portability [art. 20 of the EU Regulation]: the data subject, in cases where the processing is based on consent and contract and is performed by automated means, he may request to receive personal data in a structured format, commonly used and readable by automatic device, and he has the right to transmit them to another Data Controller;
Right to object [art. 21 of the GDPR]: the data subject has the right to object to the processing of his / her personal data, in the event that the processing is based on a non-prevailing legitimate interest or is carried out for direct marketing purposes;
Right not to be subject to a decision based solely on automated processing [art. 22 of the GDPR]: the data subject has the right to be not subjected to a decision, including profiling, based solely on automated processing (for example carried out exclusively through electronic tools or computer programs).

The description given above does not replace the text of the articles cited here which are referred to and that you can read exhaustively and fully below.

WHAT KIND OF COOKIES DO WE USE?

I FIRST PARTY COOKIES

I A) TECHNICAL COOKIES

Among these technical cookies, described above, we point out the essential or browsing cookies, which enable functions, without which it would not be possible to fully use the Site. These cookies are first-party cookies.

Essential cookies cannot be disabled using the functions of the Site.

Functional and the supra mentioned “analtycs”, used exclusively for statistical purposes and that collect data in an aggregated form from which the user cannot be singled out, are also included in the field of technical cookies.

To install such cookies do not require the data subject’s prior consent. These cookies can also be deactivated and/or cancelled through the web browser’s settings. Such cancellation does not equate to a revocation of consent.

In case of cookie blocking, services offered by the website will be limited, also influencing the website’s experience.

The chapter below lists, for every technical and assimilated cookie, the name, the purpose, and the retention period.

Necessary Cookies (incluiding the navigational ones).

Cookie’s name	Purpose	Retention period
cookies.js	Determines whether the visitor has accepted the cookie consent box. This ensures that the cookie consent box will not be presented again upon re-entry.	session
wc_fragments_#		session
wc_cart_hash_#		Persistent
wc_cart_hash_#		session
CookieConsent	Stores the user’s cookie consent state for the current domain	1 anno
rc::a	This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website.	Persistent
rc::c	This cookie is used to distinguish between humans and bots.	session
rc::b	This cookie is used to distinguish between humans and bots.	session
_grecaptcha	This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website.	Persistent
_GRECAPTCHA	This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website.	180 giorni

Analytics Cookies (Not completely anonymized, also those pseudoanonymized and which do not directly attributable to the user’s IP address)

Cookie’s name	Purpose	Retention period
mailchimp_landing_site	Used to register how the user entered the website – This function is provided by Mailchimp.	28 giorni
collect	Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels.	session
_fbp	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.	3 mesi
td		session

Finally, listed below are the links to the most popular browser, where You can find information about the settings to disable the memorization or to cancel the already memorized cookies on the browser:

Notice concerning children under 14 years old

Children under 14 cannot provide personal data to Diamond International S.r.l. will not be in any way responsible for any collection of personal data, as well as false statements, provided by the minor, and in any case, if you notice its use, the Controller will facilitate the right of access and cancellation forwarded by the legal guardian or by those who exercise parental authority.

Changes and updates

This privacy policy presents its date of last update in its heading.

Diamond International S.r.l. could modify or implement changes to the privacy policy also as a consequence of future legislative changes or amendments.

LEGAL REFERENCES ABOUT THE DATA SUBJECT’S RIGHTS