This section describes the management methods in relation to the processing of the personal data of users of the websites owned by Studio Moretto Group Srl, devlf.com/smg, www.smgdesk.com and www.translationoutlet.com and of the customers that use our services and products, in accordance with Art. 13 of Legislative Decree. n. 196/2003.
Controller and place of processing
Studio Moretto Group Srl, with its registered office in Via Cefalonia, 70 – 25124, Brescia, Italy is the controller of the personal data processing procedures. The data are mainly processed in the office in Brescia or in its subsidiaries’ offices, SMG UK Translations Ltd., which has its operational headquarters in Bristol – St Brandon’s House, 27-29 Great George Street, Bristol, BS1 5QT and its registered office in The Old Carriage Works, Moresk Road, Truro – TR1 1DG and Studio Moretto Group America SAC, which has its registered office in Calle Julio C. Tello 154 Urb. San Jose Bellavista, Callao 2, Lima, Peru.
Types of data processed
The purpose of the information and data collected is to provide the user with the best possible browsing experience and to guarantee that all the sections of the website devlf.com/smg are fully functioning. Some technical data is collected anonymously whilst browsing and will not be associated with the user’s identity. This category of data includes the URI addresses (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the numerical code indicating the status of the response from the server (error, timeout, etc.) and other parameters related to the user’s operating system and IT environment.
Data supplied voluntarily by the user
Some sections of the site, such as forms for quote requests, subscriptions to the newsletter, application and auto profiling forms, can ask to enter the contact details such as name, surname, telephone number and email address etc. The sending of the above-mentioned data from the user entails the subsequent acquisition of the users details, which is necessary to respond to requests, as well as sending information of a commercial nature. The data entry fields marked as “mandatory”, are needed in order to respond efficiently to the user’s requests, who choose to sign to the forms in a completely optional, explanatory and voluntary way. Where applicable, sending personal data, including any sensitive data, is necessary for the enforcement of contractual and pre-contractual obligations in respect to the interested parties. In this case, the failure to provide personal data means it becomes impossible to fulfill the contractual obligations.
In relation to necessary data collection for the fulfillment of contractual obligations, both in purchasing and sales, they can be provided to our financial and legal consultants, as well as processed by Studio Moretto Group and its subsidiary companies’ employees, or by collaborators and/or experts appointed exclusively for strictly functional reasons, connected to the nature of such contracts. The list of data processors and third-parties receiving communications is available at our offices in Via Cefalonia, 70, Brescia.
The processing of personal data, including that of a sensitive nature, that was collected by Studio Moretto Group whilst procuring, producing and supplying goods and services provided by Studio Moretto Group, aims at carrying out the contractual obligations and to satisfy clients’ requests, as well as regulatory obligations, in particular those pertaining to accounting and tax. Such processing consists of the collection of data and their registration, organisation, conservation, elaboration, modification, selection, extraction, comparison, use, interconnection, interruption, communication, dissemination, cancellation, destruction of the data, including a combination of two or more of the above listed activities.
In the framework of a plan focused on the continuous improvement of services offered, the contact details (telephone number and email) of the clients that sign supply contracts with Studio Moretto Group or one of its subsidiary companies, could later be used to submit short surveys on customer satisfaction with the services, or to forward commercial/promotional information.
Rights of the data subjects
According to art. 7 of Legislative Decree of 30 June 2003, n. 196, the data subject has the right to oppose, in whole or in part, the processing of data and can, according to the ways and the limits laid down by the current legislation, ask for confirmation of the existence of his/her personal data, know their origin, receive intelligible communication, get information about the rationale, the method and the purpose of the processing, request updating, correction, integration, cancellation, transformation into an anonymous form, the blocking of processed data in violation of law, including those no longer required in pursuing the aims for which they have been collected, as well as, more generally, to exercise all of the to which he/she is entitled according to the current legal provisions, by addressing requests to Studio Moretto Group Srl, having its registered office in Brescia, Via Cefalonia, 70.
Procedure of data protection
The data that is collected and exchanged from the users is protected from malicious external attacks by means of a firewall system, known as a DMZ (acronym of Demilitarized Zone). It is a security system against cyber-attacks that are controlled by an isolated segment of a LAN subnetwork, which allows the servers in the same DMZ to be reachable from the external network, without compromising the internal business system. This allows Studio Moretto Group to offer to its clients all of the features of its website, without risk to the security of data collected through such methods. The system also has as double backup protocol for the protection of the data and the files the customer can exchange with Studio Moretto Group in the specific reserved areas of SMGDesk.
Any paper documentation provided to the company by customers is kept in a fireproof armoured safe in the registered office in Via Cefalonia, 70, Brescia. Furthermore, Studio Moretto Group has certified procedures for the processing of classified information (confidential, highly confidential, secret and highly secret).
This data privacy statement could be subject to periodical reviews, in compliance to any subsequent amendments, modifications, integrations and/or updates of the current regulations, as a consequence of the changes in conditions to the services offered by the data controller. The use of the information of the clients, suppliers and the users of the sites by Studio Moretto Group Srl is regulated by the most up-to-date version of the data privacy statement, which is available at devlf.com/smg/privacy. In the event of changes to the current data privacy information notice, we will notify them in the news section of the devlf.com/smg website, which is displayed on the home page and we will provide written information to customers and suppliers via email. The access to, or use of the services following the entry into force of these modifications, requires the acceptance of constraints imposed by the new version of the data privacy information notice.
The current data privacy information notice has been in force since 14/03/2016.