PRIVACY POLICY

Privacy Policy and Cookie Policy pursuant to Article 13 of the EU General Data Protection Regulation 2016/679 (GDPR)

TOPGRAF srl, with its registered office at Via Cremasca 24/A - 24052 Azzano San Paolo (BG) - Italy, is committed to constantly protecting the online privacy of its users.

A) Source of Personal Data and Data Controller

This document has been drafted in accordance with Article 13 of EU Regulation 2016/679 (hereinafter referred to as the "Regulation") to inform you about our privacy practices. It describes the general methods for processing personal data of website users and cookies, as well as how your personal information is processed when you use our site [www.topgraf.it] (hereinafter "Site"). The information and data you provide or that we acquire through other means while using the services of Topgraf srl, such as access to the restricted area of the Site, newsletters, etc. (hereinafter "Services"), will be processed in compliance with the provisions of the Regulation and the confidentiality obligations governing the activities of Topgraf srl.

In accordance with the Regulation, the processing of personal data by Topgraf srl will be based on the principles of legality, fairness, transparency, purpose limitation, data minimization, accuracy, integrity, and confidentiality.

The data controller of the Site is Topgraf srl, with its registered office at Via Cremasca 24/A - 24052 Azzano San Paolo (BG) – Italy, as mentioned above. You may contact this company for any information related to the processing of your personal data.

This privacy policy is valid only for this Site and does not apply to other websites you may visit through links. You can consult specific sections of the Site for additional information and consent requests related to specific processing activities.

B) Types of Data

When navigating the Site, we inform you that Topgraf srl will process personal data (Article 4(1) of the Regulation), hereinafter "Personal Data."

The personal data processed through the Site is as follows:

1.  Browsing Data

The computer systems and software procedures necessary for the functioning of the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. These are information that is not collected to be associated with identified persons, but which, by their nature, could, through processing and association with data held by third parties, allow the identification of users. This category of data includes IP addresses or domain names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) addresses 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 server response status (successful, error, etc.), as well as other parameters related to the user's operating system and IT environment. These data are used solely for obtaining anonymous statistical information about the use of the Site and to ensure its correct functioning (see the section on cookies below), to identify anomalies and/or abuses, and are deleted immediately after processing. The data may be used by competent authorities to investigate potential computer crimes against the site.

2. Data Voluntarily Provided by the Data Subject

Apart from the browsing data mentioned above, the user is free to provide the personal data requested in the forms available on the site (e.g., to subscribe to a newsletter, sign up for free, make a purchase, etc.). Failure to provide this data could make it impossible to provide the requested service. In these cases, only the data necessary for the provision of the requested service will be required (see the specific information in the relevant forms).

In the use of certain services on the Site, it is possible that the processing of personal data of third parties that you send to Topgraf srl will take place. In such cases, you act as an independent data controller, assuming all legal obligations and responsibilities. In this regard, you release Topgraf srl from any disputes, claims, or demands for compensation for damages resulting from the processing of such data, etc., that may be made by third parties whose personal data has been processed by your use of the Site's functions in violation of applicable data protection laws. In all cases, if you provide or otherwise process personal data of third parties in connection with the use of the Site, you hereby guarantee – taking on all associated responsibilities – that such processing is based on an appropriate legal basis in accordance with Article 6 of the Regulation, which legitimates the processing of the relevant data.

C) Purposes of Data Processing and Legal Bases

The processing of your personal data, with your specific consent when necessary, has the following purposes:

  • To allow the provision of the Site’s Services;

The legal basis for the processing is the performance of pre-contractual measures adopted at your request (Article 6(1)(b) of the Regulation), as the processing is necessary for the provision of the Service.

Providing Personal Data for these purposes is optional, but failure to provide the data may prevent the activation of services provided by the Site.

D) Recipients of Personal Data

Your Personal Data may be shared, for the above purposes, with:

  • persons authorized by Topgraf srl to process Personal Data necessary for carrying out activities directly related to providing the Services, who are committed to confidentiality or are legally bound by a confidentiality obligation (e.g., employees and system administrators);
  • third parties who are potentially responsible for managing the Site and who generally act as Data Processors (the complete and updated list of Data Processors is available on www.topgraf.it);
  • entities, bodies, or authorities to whom it is mandatory to communicate your Personal Data pursuant to legal provisions or orders from authorities.

E) Transfer of Personal Data

Some of your Personal Data may be shared with recipients located outside the European Economic Area. Topgraf srl ensures that the processing of your Personal Data by these recipients is in compliance with the Regulation. Transfers may be based on an adequacy decision, Standard Contractual Clauses approved by the European Commission, or another appropriate legal basis.

F) Your Privacy Rights under Articles 15 and following of the Regulation

In accordance with Articles 15 and following of the Regulation, you have the right to request access to your Personal Data, its correction or deletion, or to object to its processing at any time. You also have the right to request the limitation of processing in cases provided for in Article 18 of the Regulation, as well as to obtain your data in a structured, commonly used, and machine-readable format, in the cases provided for in Article 20 of the Regulation.

Requests must be sent in writing to the Data Controller at the following address: info@topgraf.it

In any case, you always have the right to lodge a complaint with the competent supervisory authority (the Data Protection Authority), in accordance with Article 77 of the Regulation, if you believe that the processing of your Personal Data is in violation of applicable laws.

G) Changes

This privacy policy has been in effect since 2016. Topgraf srl reserves the right to modify or update its content, in whole or in part, due to changes in applicable legislation. Topgraf srl will inform you of such changes as soon as they are made, and they will become binding as soon as they are published on the Site.

Topgraf srl invites you to consult this section regularly to become aware of the most recent and updated version of the privacy policy in order to stay informed about the data collected and its use by Topgraf srl.