Welcome to the website www.etichetta-conai.com of CONAI – Consorzio Nazionale Imballaggi (hereinafter “Site“).
Browsing is free and does not require any registration; any provision of personal data is provided in the “Associations and Chambers of Commerce Reserved Area” section where the content is referred to a specific information on the processing of personal data.
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Holder of the treatment
The Data Controller, i.e., the entity responsible for decisions regarding the purposes, methods and security of personal data, is CONAI – Consorzio Nazionale Imballaggi, with registered office in Rome, Via Tomacelli no. 132 and operational headquarters in Milan, Via Pompeo Litta n. 5 (hereinafter “CONAI“).
Type of personal data processed
Personal data means any information concerning the user and referable to him.
Specifically, the treatment will concern:
- Personal data relating to navigation
When browsing the Site, CONAI collects browsing data through cookies or other tracking technologies to verify the smooth operation of the Site and allow the user to take advantage of the services provided therein, as well as to derive information about visits and process statistical analysis and, finally, to identify anomalies and/or abuses.
For more information on the technologies used to collect such data, CONAI invites you to review the provisions in section 4) below on Cookies.
- Data provided voluntarily by the user
CONAI processes, also, personal data voluntarily provided by the user during interaction with the services provided by the Site, such as in the case of registration to the area provided in the section “Association and Chambers of Commerce Reserved Area”. Such data are:
- first name, last name, e-mail address, association/chamber of commerce of affiliation, province of residence/location, for the creation of the personal account in the “Association and Chamber of Commerce Reserved Area” section and the use of the services therein;
- first name, last name, e-mail address, membership association/chamber of commerce, province of residence/location, and any and further information indicated in the assessment test, for taking the assessment test about environmental labeling skills;
- first name, last name, company/organization, telephone number, any and further information given in the message, and image to request information;
(hereinafter collectively “Data“).
The optional and voluntary sending of e-mail messages to the addresses indicated on this Site entails the acquisition of the sender’s e-mail address, as well as any additional personal data voluntarily indicated in the massage. Said data are used for the sole purpose of matching the sender and are not disseminated in any way.
Purposes of processing, legal bases and nature of the provision of Data
As part of the consultation of the Site and the use of the services provided therein:
- enable navigation of the Site, obtain anonymous statistical information on its use, as well as monitor its proper functioning and ascertain liability in the event of computer crimes (hereinafter “Browsing“). The legal basis can be found in the execution of the contract (Art. 6.1 b) Regulations), as well as in the legitimate interest of CONAI (Art. 6.1 f) Regulations);
- registration to the area provided in the “Association and Chambers of Commerce Reserved Area” section, creation of the relevant personal profile, management of the strictly related tasks and all further legal and contractual obligations (hereinafter “Personal Area“). The legal basis can be found in the execution of pre-contractual measures taken at the request of the user (Art. 6.1 (b) Regulations), in the execution of the contract (Art. 6.1 (b) Regulations) and in fulfilling related obligations to which CONAI is subject (Art. 6.1 (c) Regulations);
- Execution of the test for assessing the user’s competency in environmental labeling and management of strictly related tasks, including sending communications containing the certificate in case of passing the test (hereinafter referred to as “Assessment Test“). The legal basis can be found in the execution of pre-contractual measures taken at the request of the user (Art. 6.1 (b) Regulations), in the execution of the contract (Art. 6.1 (b) Regulations) and in fulfilling related obligations to which CONAI is subject (Art. 6.1 (c) Regulations);
- Publication of User Data in the list of environmental labeling experts provided on the CONAI Site (hereinafter “Publication“). The legal basis can be found in the consent expressed by the user (Art. 6.1 (a) Regulations).
- Acknowledge and process requests received from the user (hereinafter “Ask A Question“). The legal basis can be found in the execution of pre-contractual measures taken at the request of the user (Art. 6.1 b) Regulations);
- Exercise and defense of CONAI’s rights in any forum including judicial, administrative, arbitration and/or mediation and conciliation procedures (hereinafter “Defense“). The legal basis can be found in CONAI’s legitimate interest (Art. 6.1 f) Regulations).
With the exception of navigation data (collected automatically), the provision of Data is in the nature:
- necessary for the pursuit of the purposes set forth in the preceding paragraphs b), c), e) f). Therefore, failure by the user to provide the Data marked with (*) will result in CONAI’s inability to fulfill what is requested (e.g., register the user to the personal area, allow the user to access and perform the assessment test, fulfill legal and contractual obligations, acknowledge and fulfill any requests), while failure to provide the Data not marked with (*) will not affect the fulfillment of what is requested;
- Optional for the pursuit of the purposes mentioned in (d) above. Therefore, failure to provide the Data will result in the objective impossibility for CONAI to proceed with the publication of the Data, but will not affect the execution of the test, Navigation and Defense.
Within the scope of the purposes indicated in point 3) above, the processing of Data will take place mainly by electronic and automated means, as well as in paper form, in compliance with the legal provisions on the processing of personal data, taking appropriate security measures. The processing of Data will be handled by CONAI’s in-house personnel, who are specially authorized, trained and instructed to ensure adequate security and confidentiality, as well as to avoid risks of loss and/or destruction and access by unauthorized parties.
Communication and Dissemination of Data
The Data will be disseminated on CONAI’s Site with the user’s consent.
Within the limits strictly relevant to the purposes indicated in the previous point 3), the Data may be communicated to:
- subjects legitimated by law or regulation, such as by way of example and not limited to the Public and Judicial Authorities;
- subjects who, as independent data controllers or data processors pursuant to art. 28 of the Regulations, are involved in the processing of Data (such as, but not limited to, the company in charge of managing and maintaining the computer systems and the Site).
The updated list of names of the Data Processors is available at the CONAI operational headquarters.
Data retention period and criteria used
CONAI retains the Data for the period of time strictly necessary to achieve the purposes for which said data were collected. Except as expressly provided in (4) above, the Data for the purposes of:
- Personal Area and Assessment Test, will be kept until the user closes the profile, which can be requested at any time;
- Publication, will be retained until the user withdraws consent;
- Make A Question will be kept for a period not exceeding 15 (fifteen) days from the date of their collection;
without prejudice, however, to the right to revoke consent for those processing operations that have such a legal basis, the right to object to processing, as well as the fulfillment of specific preservation obligations required by law and the exercise of the right of defense in the event of a dispute.
Rights of the interested party
With reference to the Data, the right to ask CONAI is envisaged in the manner indicated in the Regulations and without prejudice to the provisions and limitations set out in Legislative Decree n. 196/2003 (Part I – Title I – Chapter III):
- Right of access: art. 15 of the Regulations allows the user to obtain from the Data Controller confirmation as to whether or not data processing is taking place concerning him/her in which case to obtain access to such data.
- Right of rectification: art. 16 of the Regulation allows the user to obtain from the Data Controller the correction of inaccurate personal data concerning him without undue delay. Taking into account the purposes of the processing, the user has the right to obtain the integration of incomplete personal data, also by providing an additional declaration.
- Right of cancellation: art. 17 of the Regulation allows the user to obtain from the Data Controller the deletion of personal data concerning him without undue delay if one of the reasons provided for by the law exists.
- Right to limitation: art. 18 of the Regulation allows the user to obtain from the Data Controller the limitation of the processing when one of the hypotheses provided for by the law occurs.
- Right to portability: art. 20 of the Regulation allows the user to receive in a structured format, commonly used and readable by an automatic device, the personal data concerning him provided to a Data Controller and has the right to transmit such data to another Data Controller without impediments. by the Data Controller to whom he provided them according to the conditions provided for by the law.
- Right of opposition: art. 21 of the Regulation allows the user to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her in accordance with Article 6(1), subparagraphs e) or f), including profiling based on these provisions.
In case of treatment based on consent, the right to revoke it is also recognized at any time without prejudice to the lawfulness of the treatment carried out before the revocation.
All the rights listed above can be exercised by sending CONAI a communication by certified e-mail to the address email@example.com or by registered letter to the address of the operational headquarters in Milan, Via Litta, 5. If it is believed that the processing of data violates the provisions contained in the Regulation, it is possible to lodge a complaint with the Guarantor for the protection of personal data in accordance with the provisions of art. 77 of the Regulation itself.
Data are subject to transfer abroad; they are, in fact, stored on servers located in the United Kingdom, as well as on servers located in the European Union. The transfer of Data to the United Kingdom is, however, permitted, the European Commission having recognized the adequacy of that country through specific decision under Art. 45 of the Regulations.
Further Information and Collaboration
Data protection and compliance with the principles set forth in the regulations, with particular reference to the principle of transparency, are values of primary importance to CONAI. CONAI’s Legal and Corporate Affairs Office is available to provide any clarifications related to the exercise of rights. Requests can be made in writing by contacting the above office. You can also report any misunderstandings of this document or suggest improvements.
CONAI – Consorzio Nazionale Imballaggi