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Privacy Policy

Privacy Policy FEAM Rev.1

Information on privacy as per article 13 of the Italian Legislative Decree no. 196/2003 (hereinafter, “Privacy Code”) and art. 13 EU Regulation n. 2016/679 (hereinafter, “GDPR”).
According to these laws, FEAM Srl informs you with this document in relation to the handling of personal data of whomsoever consults the website www.feam-ex.com (hereinafter, “the site” or “the website”), and personal data submitted by newsletter subscription form.
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Privacy Policy

From the entry into force of the GDPR (25 May 2018), this site will collect and process some data as described below, in compliance with the obligations resulting from the European and national privacy legislation (European Regulation for the protection of personal data No. 679/2016 and Legislative Decree 101/2018) as well as subsequent amendments and additions.
The data controller, in compliance with the recommendations of the Privacy Authority about the adaptation of the GDPR, places great importance on the privacy of visitors and users in order not to infringe the rights of visitors / users who browse this site.
The intent of this privacy statement is to provide transparency and understandable information relating to the information collected on the site and its use.
This information applies exclusively to the online features of the site and is valid for visitors / users of the site. The information does not apply to all information collected outside the web channel where this website is located.

Navigation data and storage times
Data acquired from system and security logs
This site, during user visits, automatically acquires information through system LOGs and security logs.
The collected information could be:
– time and date of the visit;
– IP address and name of the provider of origin;
– records of errors and problems.
All these data, collected in aggregate form, are used only to support diagnostics for security purposes. Example: In the event of an attack, the logs are monitored to block unauthorized access and to prevent malicious activity.
Access to these data is only at the server administration level and are never used for the identification or profiling of the user / visitor but only acquired for the protection and security of the present site. They could be used only in the event of a crime, and only at the request of the judicial authority in the cases provided for by law.
The LOG data collected by the site are processed at the headquarters of the Data Controller, and at the web Hosting datacenter.
The web hosting is responsible for data processing (FEAM srl, based in Italy, via Mario Pagano 3 Trezzano sul Naviglio) and processes the data only at the explicit request of the owner and acts in compliance with European regulations.
The data used for security purposes are kept for 90 days.

Automated decision-making processes
Our web site collects personal data (using cookies) on how you use it and on any other actions you have taken: for more detailed information on the types of cookies used, on other tracking techniques and on the information we collect about them, please read our cookie policy below.
We specify that some pages of the site include codes and plugins (third-party cookies) that allow you to read and configure browser cookies for sharing the page on your social network profile. It is also specified that the information obtained from the third party allows it to identify your IP address.
Finally, we remind you that you can configure your browser not to receive cookies or not to be informed of their installation but that disabling cookies can compromise the use of all the site’s features.

Purpose and legal basis of the processing
The purpose of our data processing activities is to pursue our legitimate interests.
For the processing of data we rely on the legal bases described below:
– art. 6 a) GDPR, i.e. your consent, provided for certain personal data processing procedures;
– art. 6 b) GDPR, i.e. when the processing of personal data is necessary for the fulfillment of the obligations deriving from a contract (for example: if you send requests for information which then is followed by your order, the processing of data is essential);
– art. 6 c) GDPR, i.e. when the processing of personal data is necessary to fulfill a legal obligation;
– art. 6 f) GDPR, i.e. based on the legitimate interest of our company or third parties – provided that the interests or fundamental rights and freedoms of the data subject do not prevail – considering that our main legitimate interest is the development and execution of our commercial activity (and this corresponds to the legitimate interests of companies expressly described by the European legislator).

Security measures
The processing of data acquired by surfers through this site is managed in a legal manner, taking all appropriate measures to:
– increase security
– prevent unauthorized access
– prevent unauthorized disclosure of data.
The processing is carried out using IT devices, with logics and organizational methods strictly related to the purposes described above. In addition to the owner, as specified above, the data is accessed by third parties (Social Network Service) with reference to social plugins or is delegated to technical consultants involved in the site project.
The subjects involved, always appointed by the data controller, can also be external and are intended as third party technical service providers, hosting providers, IT companies.

User rights
Pursuant to European Regulation 679/2016 (GDPR), and in the manner and within the limits established by current legislation, the user can exercise the following rights:
Right of withdrawal, or updating / rectification / integration and deletion of data;
request confirmation of the existence of their personal data;
request the origin of their data in an intelligible manner;
have information regarding the methods and purposes of data processing;
request the transformation of data into anonymous form
make a complaint with the Privacy Authority as Supervisory Authority (https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524);
Requests should be sent to the Data Controller through the “contact us” form.
We also specify that the visitor / user can deny consent to the provision and collection of data and can revoke at any time a consent previously provided through the Contact Us form on the site.
The refusal of consent, through the appropriate refusal button on the cookie banner, or through a withdrawal of consent via email could result in a ban on access to certain services and compromise the browsing experience of this site.

Holder of the treatment
Pursuant to the laws in force, the data controller is:
FEAM S.r.l., with registered office in Trezzano sul Naviglio (MI) in via Mario Pagano n. 3 and can be contacted through the Contact section of this site.

Update of the privacy policy and Cookie policy
This document is updated on 1 September 2020

Cookies Policy

This site uses cookies, small files that are stored on the visitor’s computer and that allow you to acquire / store information on the preferences of visits used in order to:
– improve the functionality of this site;
– simplify navigation through automated procedures (eg. Login, site language setting)
– analyze the use of the site to improve its usability and user experience.
Session cookies are necessary to be able to differentiate connected users and prevent the functionality requested by a visitor from being used by another visitor and are necessary for security purposes to try to neutralize cyber attacks on the site.
The session cookies used on this site do not acquire personal data and their duration is linked to the current browsing session. Closing the browser deletes the session cookies. For these no consent is required.
The functionality cookies used by this site are essential to the use of the site and are associated with features specifically requested by the visitor (for example, login in a reserved area, or acceptance of the cookie warning banner). For these no consent is required.

Disabling cookies
By refusing the initial banner you can block the installation of cookies.
However, cookies are strictly connected to the browser used for navigation and management of these, as the revocation of previously accepted cookies can be done through the browser.
You can read all the explanations for disabling cookies at the following links:
Mozilla Firefox (https://support.mozilla.org/it/kb/protezione-antitracciamento-avanzata-firefox-desktop?redirectslug=Attivare+e+diseactivare+i+cookie&redirectlocale=it)
Microsoft Internet Explorer (https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies)
Microsoft Edge (https://support.microsoft.com/it-it/help/4027947/microsoft-edge-delete-cookies)
Google Chrome (https://support.google.com/chrome/answer/95647?hl=it)
Opera (https://help.opera.com/en/latest/web-preferences/#cookies)
Apple Safari (https://support.apple.com/it-it/HT201265)

Third party cookies
This site plays the role of intermediary with regard to third-party cookies and has no control over these cookies. These cookies are used to:
– acquire statistical information on the use of the site (Google Analytics)
– add some features external to the site (Social Network Service plugin)
– make visitors interact with social networks (Linkedin share buttons, etc.)
In particular, Google Analytics data is acquired through a code entered on the site where the anonymization of IP addresses is preset.
These anonymous data (example: number of visits, list of the most visited pages, average residence time) collected in aggregate form through an administration panel are used by site analysts, at the explicit request of the owner, in order to study new features of the site and improve navigability and user experience.
The data is transmitted and stored on Google’s servers in the United States and is stored for a period of 26 months.

Google Analytics Cookie Usage on Websites and ShareThis.com Cookies
The information on the use, purposes and suspension of these cookies is provided directly by third parties and can be consulted at the following links:
– ShareThis.com (https://sharethis.com/privacy/)
– LinkedIn – (https://www.linkedin.com/legal/cookie-policy)
In the event that the user / visitor is still logged into the social network while browsing this site, he / she conveys acceptance of the use of social network cookies.

Transfer of data to non-EU countries
Based on Google, Facebook and Microsoft’s adherence to the Privacy Shield (in particular decision 1250/2016), and through the Google Analytics service and social plugins, this site may share some of the data collected outside the area of the European Union.
The transfer is authorized on the basis of specific decisions of the European Union and the Authority for the protection of personal data.

Security measures
The processing of data acquired by visitors through this site is managed in a legal manner, taking all appropriate measures to:
– increase security
– prevent unauthorized access
– prevent unauthorized disclosure of data.
The processing is carried out using IT devices, with logics and organizational methods strictly related to the purposes described above. In addition to the owner, as in the case of Google Analytics, data access is delegated to technical consultants involved in the site project.
The subjects involved, always appointed by the data controller, can also be external and are intended as third party technical service providers, hosting providers, IT companies, web marketing agencies.

User rights
Pursuant to European Regulation 679/2016 (GDPR), and according to the methods and within the limits established by current legislation, the visitor / user can exercise the following rights:
Right of withdrawal, or updating / rectification / integration and cancellation of data;
request confirmation of the existence of their personal data;
request the origin of their data in an intelligible manner;
have information about the methods and purposes of data processing;
request the transformation of the data into anonymous form
make a complaint with the Privacy Authority as supervisory authority (https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524);
Requests should be sent to the Data Controller through the “contact us” form.

Holder of the treatment
Pursuant to the laws in force, the data controller is:
FEAM S.r.l with registered office in Trezzano sul Naviglio (MI) in via Mario Pagano n. 3 and can be contacted through the Contact section of this site.

Update of the privacy policy and Cookie policy
This document is updated on 1 September 2020

Privacy policy for section “Career”

Data Controller
The Data Controller is FEAM S.r.l., with registered office in Via Mario Pagano 3, 20090 Trezzano sul Naviglio (MI); any requests for information and / or clarifications regarding the processing of data may be requested by sending an email to the following address: privacy@bartectopgroup.com

Purposes of the processing
The Data Controller would like to inform that your personal data (name/surname, address, email and other info related to you) provided in the form on our web site will be collected and processed for the following purposes:
– take in charge of your application and evaluation for a possible employment in our company.
The activities carried out with the aid of paper / computer tools do not involve the use of automated decision-making processes.

Legal basis of the processing
The processing is carried out based on the existing contractual relationship between the Data Controller and the Data Subject and, in any case, the processing is necessary to achieve the legitimate interest of the Data Controller.

Provision of data
The provision of data is optional, but necessary to achieve the above-mentioned purposes and its unavailability does not allow the fulfillment of the above obligations nor the acceptance of your application.

Data communication and circulation limits
The data may be disclosed to the following subjects that the Data Controller uses to perform some activities functional to conduct its business, as well as to Top Group S.p.A.’s companies of which the Owner is a part (Nuova ASP Srl, vat number 07653940150, based in Trezzano Sul Naviglio (MI) via Mario Pagano n.7/9; Fenex Srl, vat number 01058300318, based in Moraro (GO) via Carducci n. 16); accountant firm for accounting / tax obligations; banks for payments; law firm in the event of a dispute; public administration for communications required by law. Your data will not be subject to circulation.

Conservation Time
The data will be kept for the time necessary to carry out the above purposes in compliance with the terms of the law. If your request does not lead an employment relationship, your data will not be subject to further processing by the Data Controller.

Rights of the data subject
The data subject has the right to: ask the Data Controller to access his personal data and to correct or delete them or limit their processing or to oppose their processing, in addition to the right to the portability of the data. This right can be exercised by sending an email to privacy@batectopgroup.com
The Data Controller will interrupt the processing when the relative request is received.

Complaint to the supervisory authority
The interested party has the right to make a complaint to the Supervisory Authority if his requests for information addressed to the Data Controller have not received satisfactory responses.
The reference Authority is the Data protection supervisor:
http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524

Privacy Policy for “contact us” form

Data Controller
The Data Controller is FEAM S.r.l., with registered office in Via Mario Pagano 3, 20090 Trezzano sul Naviglio (MI); any requests for information and / or clarifications regarding the processing of data may be requested by sending an email to the following address: privacy@bartectopgroup.com

Purposes of the processing
The Data Controller would like to inform that your personal data (name/surname and email address) required in the contact form published on this web site will be collected and processed for the following purposes:
– take in charge of your request/question and give you the required information.
The activities carried out with the aid of paper / computer tools do not involve the use of automated decision-making processes.

Legal basis of the processing
The processing is carried out based on the existing contractual relationship between the Data Controller and the Data Subject and, in any case, the processing is necessary to achieve the legitimate interest of the Data Controller.

Provision of data

The provision of data is optional, but necessary to achieve the above-mentioned purposes and its unavailability does not allow the fulfillment of the above obligations nor the taking in charge of your request with the aim to give you an answer.

Data communication and circulation limits
The data will be processed only by people expressly authorized by the Data Controller or by companies acting as Data Processors, on behalf of the Data Controller and who have signed a specific contract that governs the treatments entrusted to them and the obligations regarding data protection and will never be disseminated or transferred abroad..

Conservation Time
The data will be kept for the necessary time to carry out the above-mentioned purposes in compliance with the contractual and legal terms, unless otherwise provided by the laws in force. If your request does not lead to the signing of a contract / order, your data will not be subject to further processing by the Data Controller..

Rights of the data subject
The data subject has the right to: ask the Data Controller to access his personal data and to correct or delete them or limit their processing or to oppose their processing, in addition to the right to the portability of the data. This right can be exercised by sending an email to privacy@batectopgroup.com
The Data Controller will interrupt the processing when the relative request is received.

Complaint to the supervisory authority
The interested party has the right to make a complaint to the Supervisory Authority if his requests for information addressed to the Data Controller have not received satisfactory responses.
The reference Authority is the Data protection supervisor:
http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524

Privacy policy for newsletter subscription

Data Controller
The Data Controller is FEAM S.r.l., with registered office in Via Mario Pagano 3, 20090 Trezzano sul Naviglio (MI); any requests for information and / or clarifications regarding the processing of data may be requested by sending an email to the following address: privacy@bartectopgroup.com

Purposes of the processing
The Data Controller would like to inform that your email address as well as your contact data will be collected and processed for the following purposes:
– subscription to the newsletter managed by the Data Controller with the aim to promote its products/events/services.
The activities carried out with the aid of paper / computer tools do not involve the use of automated decision-making processes.

Legal basis of the processing
The processing is carried out based on the existing contractual relationship between the Data Controller and the Data Subject and, in any case, the processing is necessary to achieve the legitimate interest of the Data Controller.

Provision of data
The provision of data is optional, but necessary to achieve the above-mentioned purposes and its unavailability does not allow the fulfillment of the above obligations nor the administrative and accounting management of the relationship.

Data communication and circulation limits
The data will be processed only by people expressly authorized by the Data Controller or by companies acting as Data Processors, on behalf of the Data Controller and who have signed a specific contract that governs the treatments entrusted to them and the obligations regarding data protection and will never be disseminated or transferred abroad.

Conservation Time
Registration and the related processing are considered valid until the user subscription, which is possible through the link included in each email. If the sending frequency is less than six months, at least every six months a verification communication will be sent to all users, containing the unsubscribe link.

Rights of the data subject
The data subject has the right to: ask the Data Controller to access his personal data and to correct or delete them or limit their processing or to oppose their processing, in addition to the right to the portability of the data. This right can be exercised by sending an email to privacy@batectopgroup.com
The Data Controller will interrupt the processing when the relative request is received.

Complaint to the supervisory authority
The interested party has the right to make a complaint to the Supervisory Authority if his requests for information addressed to the Data Controller have not received satisfactory responses.
The reference Authority is the Data protection supervisor:
http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524