Xtra S.r.l. (from now on, for the sake of brevity, “Xtra”, or the “Company”, or “us” or “we”) informs you that the personal data of yours that it acquires when you browse this site shall be processed in accordance with the law on the protection of personal data.
With reference to the methods used for the management and processing of your personal data, as a user who consults this site, Xtra provides the following notice pursuant to Article 13 of EU Regulation No. 679/2016:
1. Types of data collected, purposes and legal basis for the processing operations
The information technology systems and software procedures that enable the functionality of this site acquire, during their normal utilisation, certain personal data the transmission of which is implicit in the use of internet communication protocols. This category of data includes the IP addresses or domain names of the computers used to access the site, the MAC (Media Access Control) addresses, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the user’s information technology environment. These data are used for the sole purposes of compiling anonymous statistical information on the use of the site and to check its correct functionality, and are deleted immediately after processing. The data may be used to ascertain liability in the event of cybercrimes that cause damage to the site. The legal basis that legitimises the processing of personal data for this purpose is set out in the circumstances described by Article 6, section 1, letter b) of EU Regulation No. 679/2016 – i.e. processing is necessary for 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. The same data may also be used to ensure compliance with legal obligations or requests on the part of the judicial authorities. The legal basis that legitimises the processing of personal data for this purpose is set out in the circumstances described by Article 6, section 1, letter c) of EU Regulation No. 679/2016 – i.e. processing is necessary to comply with a legal obligation to which the Data Controller is subject.
Data that you supply voluntarily
Following the voluntary sending of email messages to the email addresses found on the site and the filling out of the contact form on the site, Xtra may process your email address and any additional personal data contained both in the message and in the contact form (personal data, contact details) in order to respond, again by email, to the requests you have submitted. The legal basis that legitimises the processing of personal data for this purpose is set out in the circumstances described by Article 6, section 1, letter b) of EU Regulation No. 679/2016 – i.e. processing is necessary for 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. The same data may also be used to ensure compliance with legal obligations or requests on the part of the judicial authorities. The legal basis that legitimises the processing of personal data for this purpose is set out in the circumstances described by Article 6, section 1, letter c) of EU Regulation No. 679/2016 – i.e. processing is necessary to comply with a legal obligation to which the Data Controller is subject.
As the Data Subject, you are asked not to enter or send via the instruments provided on the site any “special data”, “biometric data”, “genetic data”, “data concerning health” or “data relating to criminal convictions and offences” as defined by the current legislation.
Any such data, if supplied by you, as the Data Subject, shall be immediately deleted.
The site uses technical (session and browsing) cookies for the purposes of enabling the normal browsing and utilisation of the website (allowing, for example, authentication in order to access reserved areas). The site also uses third-party analytical cookies (with reduced potential for identification), with a view to monitoring use of the site by users for purposes of optimising the web platform and for statistical (analytical) purposes.
2. Period of data storage
Any personal data of yours that are collected and processed as a result of you browsing this site) shall be stored for the entire period of delivery of the service and shall be, in any case, deleted or rendered anonymous within 7 days. Any personal data that you send of your own volition through the instruments on the site (email address and contact form) shall be deleted after the requested service has been delivered or a response has been provided, and in any case within the maximum term of 15 days from the completion of said operations, with the exception of those data that are necessary to ensure compliance with fiscal, accounting and administrative regulations, or to comply with other legal obligations, and to document the operations carried out.
3. Methods of processing
Any personal data collected shall be processed, retained and analysed using electronic tools and shall be stored both in electronic format and in hard copy, organised into databases, and on any other appropriate type of media.
Specific security measures are implemented to prevent the loss, illegal or unfair use of the data, or unauthorised access to them.
The processing of your personal data carried out by Xtra does not involve any automated decision-making.
4. Disclosure of your personal data
The disclosure of the browsing data is a contractual requirement and it is necessary in order to supply the requested service (browsing of the site): failure/refusal on your part to provide your personal data shall make it impossible for Xtra to allow you to browse this site. The disclosure of your data for other purposes is optional: failure/refusal to provide your data for said other purposes shall not have consequences for you, but may make it impossible to provide you with the requested responses.
5. Parties to which your personal data may be disclosed
The personal data collected will not be disclosed and may be communicated, in addition to those to whom the right and interest in accessing your personal data is recognized by law or secondary and/or EU regulations, to authorized personnel internal to the Data Controller, as well as to companies (operating in the field of web and digital service provision), which provide services and activities on behalf of the Data Controller as Data Processor for the fulfillment of legal and/or contractual obligations, as well as for any organizational and administrative needs necessary to provide the services requested.
The names of the additional parties to which your personal data may be disclosed, operating as Data processors, are shown in an up-to-date list that can be requested from Xtra (using the data indicated at Point 9).
6. Transfer of data outside the European Economic Area or to international organisations
Xtra shall not transfer your personal data, collected through this website and the tools contained therein, to countries situated outside the European Economic Area or to international organisations.
7. Links to third-party sites or services
This informative statement is applicable only to the processing operations carried out on personal data through this site or the instruments set aside for that purpose by the site, but it is not applicable to other sites that you may consult through links on this site; the managers of said linked sites operate as independent Data Controllers, responsible for the relevant processing operations. You are, therefore, invited – before accessing the services of third parties – to read their privacy statements carefully.
8. Your rights as the Data Subject
In relation to the aforementioned processing operations carried out on your personal data, you are entitled to exercise at all times those rights set out by EU Regulation No. 679/2016 (GDPR), including, for example, the right to be informed as to:
- the origin of any personal data held that concerns you;
- the purposes and methods of the processing operations;
- the logic applied in the case of processing operations carried out using electronic instruments;
- the identification of the Data Controller, the Data Processors and the designated representative.
As the Data Subject, you have the right to obtain:
- access to the data, and their updating, rectification or (where in your interest) completion;
- the erasure, transformation into anonymous form or blocking of access to any data processed in breach of the law;
- the limitation of the processing of those data that concern you, or to request that the Data Controller or the Data Processor reduce the purposes and/or methods for/with which your data are being processed.
You can also request a copy of your data in a standard format (the so-called “Right to data portability
As the Data Subject, you also have the right to object, at any time and at no cost, wholly or partially:
- for legitimate reasons, to processing of your personal data, even if the processing operations are still relevant to the purpose for which the data were collected in the first place;
- to processing of your personal data carried out pursuant to Article 6, Paragraph 1 of the GDPR, Letters e. (“processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”) or f. (“processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party”) including profiling on the basis of these provisions;
- to processing of your personal data for the purposes of sending advertising or direct sales material or for the completion of market research or commercial communications (direct marketing), including any relevant profiling operations.
You have the right to withdraw your consent for the processing operations when that consent is based on the circumstances described by Article 6, Paragraph 1, Letter a. (when “the data subject has given consent to the processing of his or her personal data for one or more specific purposes
”), or by Article 9, Paragraph 2, Letter a. (when “the data subject has given explicit consent to the processing of those personal data for one or more specified purposes
”) of EU Regulation No. 679/2016, at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Should you consider the processing operations to have been carried out in breach of current legislation, you have the right to lodge a complaint with a supervisory authority, specifically in the Member State in which you habitually reside or work, or the Member State where the alleged breach has taken place. The Italian supervisory authority can be contacted using the contact data on its own website
9. Data Controller – Contact data
The Data Controller is Xtra S.r.l. with its registered offices at Bergamo (BG), Via San Tomaso, n. 88, PC 24121, VAT Registration No. 04201100163.
The company can also be contacted at the following email addresses firstname.lastname@example.org
To exercise the rights listed above, you may submit a request to that end by writing to the following email address: email@example.com