PRIVACY POLICY

PRIVACY POLICY

This policy governs
the processing of your personal data carried out by Win Win S.r.l., in accordance
with current regulations on data protection, in particular EU Regulation 2016/679
(General Data Protection Regulation, hereinafter “GDPR”).

  1. DATA CONTROLLER

The
Data Controller is Win Win S.r.l., with office
address in Via Bressanella, 4 – 22044 Inverigo (Como) and
warehouse address
in via Risorgimento, 8 – 22044 Inverigo (Como).

You
can contact the Data Controller at any time at the following contacts: tel. +39
031.604205, +39 031.604214, e-mail info@beltts.com.

The
updated list of Data Processors is made available by the Data Controller upon
request.

  • PROCESSING OF YOUR PERSONAL DATA

PERSONAL DATA AND PURPOSE

BROWSING DATA – Please, have a look at our
Cookie Policy. The purpose of the processing is to be able to give you the best
possible experience on the website. The legal basis for this is Win Win’s
legitimate interest.

CONTACT DETAILS – If you send an optional and
voluntary electronic mail to the e-mail address on our website, we involve the
subsequent acquisition of your address, necessary to respond to request, as
well as any other personal data included in the message. The legal basis for this
is Win Win’s legitimate interest.

JOB APPLICANTS – If you are applying for a job
at Win Win S.r.l., we may process information about your name, address,
telephone, email address, date of birth, photo, education and other data that
is included in your application. The purpose of the processing is to assess and
select applicants. The legal basis for this is Win Win’s legitimate interest.

PERSONAL DATA RECIPIENTS

The personal data provided will be
communicated to recipients, who will process the data as Processors (article 28
of the GDPR), as persons acting under the authority of the Controller and
Processor (article 29 of the GDPR), for the purposes listed above. Precisely,
the data will be communicated to: parties that provide services for the
management of the information system and telecommunications networks used by
the Data Controller (including e-mail, the web platform); studies or companies
in the context of assistance and consultancy relationships; competent
authorities for compliance with legal obligations and provisions of public
bodies, upon request.

TRANSFER TO THIRD COUNTRIES

Win Win S.r.l. may forward your personal data
to recipients outside the EU, if this is necessary in order to deliver the
agreed service, or to fulfil any regulatory requirements.

Win Win S.r.l. will ensure that there is an
adequate level of protection when transferring to a third country, cf. articles
45-49 of the GDPR.

STORAGE

Win Win S.r.l. will retain your personal data
for the period necessary for the purpose. This will vary according to the
nature of the task, and is described in internal procedures and guidelines,
which ensure that no personal data is saved for longer than is justified based
on objective grounds for doing so. The period of time is determined on the basis
of an overall assessment of the type and amount of personal data, Win Win S.r.l.’s
legitimate interest, and the fulfilment of any customer or statutory
requirements.

SECURITY

Your personal data are processed with
automated tools for the time strictly necessary to achieve the purposes for
which they were collected. In accordance with the article 32 of the GDPR,
specific security measures are observed to prevent data loss, illicit or
incorrect use and unauthorized access.

  • YOUR PRIVACY RIGHTS

With respect to the personal data provided, in
accordance with articles 15–21 of the GDPR, you have the following rights:

  • to request access the data and request a copy;
  • to request rectification;
  • to request erasure;
  • to obtain restriction of processing;
  • to object to the processing;
  • to receive the personal data in a structured,
    commonly used and machine-readable format and to transmit such data to another
    controller without hindrance, where technically feasible.

In any case, you have the right, at any time,
to object to the processing of your personal data that is performed for the
purpose of pursuing Win Win’s legitimate interests. You can exercise your
rights by writing an e-mail to info@beltts.com.
Please be aware that it is your right to submit a complaint to the competent Italian
data protection authority (Garante per la Protezione dei Dati Personali).

  • UPDATES

Win Win S.r.l. complies with legislation
related to the protection of personal information and strives to review and
improve this privacy policy in a timely manner.

Last revised: 3 August 2020.

This policy governs
the processing of your personal data carried out by Win Win S.r.l. within this website, in accordance
with current regulations on data protection, in particular EU Regulation 2016/679
(General Data Protection Regulation, hereinafter “GDPR”).

  1. DATA CONTROLLER

The
Data Controller is Win Win S.r.l., with office
address in Via Bressanella, 4 – 22044 Inverigo (Como) and
warehouse address
in via Risorgimento, 8 – 22044 Inverigo (Como).

You
can contact the Data Controller at any time at the following contacts: tel. +39
031.604205, +39 031.604214, e-mail info@beltts.com.

The
updated list of Data Processors is made available by the Data Controller upon
request.

  • PROCESSING OF YOUR PERSONAL DATA

PERSONAL DATA AND PURPOSE

BROWSING DATA – When you visit our website, we collect your IP address,
information about your operating system, language setting, browser type,
equipment type, actions on our website, etc. The purpose of the
processing is to be able to give you the best possible experience on the
website. The legal basis for this is Win Win’s legitimate interest.

CONTACT DETAILS – If you send an optional and
voluntary electronic mail to the e-mail address on our website, we involve the
subsequent acquisition of your address, necessary to respond to request, as
well as any other personal data included in the message. The legal basis for
this is Win Win’s legitimate interest.

JOB APPLICANTS – If you are applying for a job
at Win Win S.r.l., we may process information about your name, address,
telephone, email address, date of birth, photo, education and other data that
is included in your application. The purpose of the processing is to assess and
select applicants. The legal basis for this is Win Win’s legitimate interest.

PERSONAL DATA RECIPIENTS

The personal data provided will be
communicated to recipients, who will process the data as Processors (article 28
of the GDPR), as persons acting under the authority of the Controller and
Processor (article 29 of the GDPR), for the purposes listed above. Precisely,
the data will be communicated to: parties that provide services for the
management of the information system and telecommunications networks used by
the Data Controller (including e-mail, the web platform); studies or companies
in the context of assistance and consultancy relationships; competent
authorities for compliance with legal obligations and provisions of public
bodies, upon request.

TRANSFER TO THIRD COUNTRIES

Win Win S.r.l. may forward your personal data
to recipients outside the EU, if this is necessary in order to deliver the
agreed service, or to fulfil any regulatory requirements.

Win Win S.r.l. will ensure that there is an
adequate level of protection when transferring to a third country, cf. articles
45-49 of the GDPR.

STORAGE

Win Win S.r.l. will retain your personal data
for the period necessary for the purpose. This will vary according to the
nature of the task, and is described in internal procedures and guidelines,
which ensure that no personal data is saved for longer than is justified based
on objective grounds for doing so. The period of time is determined on the basis
of an overall assessment of the type and amount of personal data, Win Win S.r.l.’s
legitimate interest, and the fulfilment of any customer or statutory
requirements.

SECURITY

Your personal data are processed with
automated tools for the time strictly necessary to achieve the purposes for
which they were collected. In accordance with the article 32 of the GDPR,
specific security measures are observed to prevent data loss, illicit or
incorrect use and unauthorized access.

  • YOUR PRIVACY RIGHTS

With respect to the personal data provided, in
accordance with articles 15–21 of the GDPR, you have the following rights:

  • to request access the data and request a copy;
  • to request rectification;
  • to request erasure;
  • to obtain restriction of processing;
  • to object to the processing;
  • to receive the personal data in a structured,
    commonly used and machine-readable format and to transmit such data to another
    controller without hindrance, where technically feasible.

In any case, you have the right, at any time,
to object to the processing of your personal data that is performed for the
purpose of pursuing Win Win’s legitimate interests. You can exercise your
rights by writing an e-mail to info@beltts.com.
Please be aware that it is your right to submit a complaint to the competent Italian
data protection authority (Garante per la Protezione dei Dati Personali).

  • UPDATES

Win Win S.r.l. complies with legislation
related to the protection of personal information and strives to review and
improve this privacy policy in a timely manner.

Last revised: 3 August 2020.