Name and contact details of the controller
article 4, paragraph 7, GDPR

xelom Ltd.
Via Copernico 6
39100 Bolzano – Italia

T +39 0471 195 8515
E-Mail: info@xelom.com

 

Our general privacy policy

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Security and protection of your personal data

These pages contain a description of the website management methods with regard to the processing of the personal data of users who consult the website. This information is also provided, within the meaning of the EU General Data Protection Regulation (GDPR 2016/679), to those who interact with xelom web services, which can be accessed by telematic means at the address: www.xelom.com. In particular, this concerns the methods, timing and nature of the information that the data controller must provide to users when the latter open a web page, regardless of the purpose of the link.

Place of Data Processing

The data processing linked to the web services of this website takes place at the xelom head office and is carried out exclusively by authorised personnel or by persons appointed to perform occasional maintenance operations. No data acquired through these web services shall be circulated. The personal data that users supply by e-mail is, for that matter, used solely to carry out the services or performances requested.

Definitions

Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject ('lawfulness, fairness and transparency'). For the purposes of this Regulation:

1. Personal data
   'personal data's means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. Processing
   'processing' means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
3. Restriction of processing
   'restriction of processing' means the marking of stored personal data with the aim of limiting their processing in the future.
4. Profiling
   'profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
5. Pseudonymisation
   'pseudonymisation' means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
6. Filing system
   'filing system' means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.
7. Controller
   'controller' means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
8. Processor
   'processor' means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
9. Recipient
   'recipient' means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
10. Third party
    'third party' means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
11. Consent
    'consent' of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Lawfulness of processing

Processing shall be lawful only if and to the extent that at least one of the following applies (legal basis for data processing: Article 6, paragraph 1, point a – f of the GDPR):

• the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which the controller is subject;
• processing is necessary in order to protect the vital interests of the data subject or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Information on the collection of personal data

1. In the following we inform about the collection of personal data when using our website. Personal data are e.g. name, address, e-mail addresses, user behavior.
2. The optional, explicit and voluntary sending of e-mails to the addresses on this website automatically results in the registration of the sender's address, which is essential for responding to the requests, as well as any other personal data contained in the message. If the user fails to transmit this data - even partially - it may, under certain circumstances, be impossible to process the user's requests.

Collection and storage of personal data and the nature and purpose of their use

You can in principle use our website without revealing your identity. When you visit our website, the browser used on your device automatically sends information to our website’s server. This information is temporarily stored in a so-called log file. The following information will be collected without your intervention and stored until automated deletion (legal basis for data processing: Article 6, paragraph 1, page 1, point f of the GDPR):

• IP address
• Date and time of access
• Time zone difference from Greenwich Mean Time (GMT)
• Request content (concrete page)
• Name and URL of the retrieved file
• Website from which access takes place (referrer URL),
• Browser used and, if applicable,
• the operating system of your computer as well as
• the name of your access provider

The data mentioned are processed by us for the following purposes:

• Ensuring a smooth connection to the website
• Ensuring comfortable use of our website
• Evaluation of system security and stability, as well as
• Other administrative purposes.

Use of cookies

This site uses Cookies to help us provide you with a better user experience tailored to your personal preferences. Cookies are small text files that are stored on your hard drive associated with the browser you are using and through which the entity that sets the cookie receives certain information. Cookies cannot execute programs or transfer viruses to your computer. They are used to make the Internet offer as a whole more user-friendly and effective.

Other features and offers of our website

With regard to the collection of data directly by the website, it is hereby declared that, within the context of the collection, only the data strictly necessary for processing in this way is collected (e.g. at the end of each registration process of a form). However, it is always possible to obtain more complete data privacy information on the website. Transmission of the requested data is optional, but may be strictly necessary in order to use the services offered by xelom. If such data is not transmitted, it may therefore be impossible for the user to obtain what you have requested. 
Please note in this regard that the optional and voluntary sending of e-mails to the address info@xelom.com or another e-mail address of the company, as well as the completion of the contact form, automatically results in the registration of the sender's address, as well as any other personal data contained in the message. This is essential for responding to the sender's requests.

Children

Our offer is aimed at adults/companies. Persons under the age of 18 should not submit any personal data to us without the consent of their parents or legal guardians.

Data Processing Methods

Personal data is processed by automated tools and retained only for as long as is strictly necessary to achieve the purposes for which it has been collected. Specific security measures are taken to prevent data loss, illicit or incorrect use of the data and unauthorised access to such data.

Rights of the data subject

xelom uses technical and organisational security measures in order to protect the stored personal data against accidental or intentional manipulation, loss or destruction and against access by unauthorised persons. Our security measures are continually being improved in line with technological progress.
If your consent is necessary for the processing of your data, we will only process it with your express consent. You have the right at all times to be informed by the Data Controller about the personal data concerning you, its origin and recipient, as well as the purpose of its retention. Provided there is no statutory retention obligation, you have the right to have this data erased and to object to its processing. You also have the right to correct the data and to restrict its processing, as well as the right to data portability and to lodge a complaint with the Data Protection Authority. If you have a query regarding your rights, please contact us at info@xelom.com or privacy@technoalpin.com.

1. Withdrawal of consent
   If the processing of personal data is based on a granted consent, you have the right to withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. You can withdraw your consent at any time at the following email address: info@xelom.com or privacy@technoalpin.com .
2. Right to confirmation
   You shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. You can request confirmation at any time at info@xelom.com or privacy@technoalpin.com .

3. Right of access
   If personal data is processed, you shall have the right to access to the personal data and the following information:

   • the purposes of the processing;
   • the categories of personal data concerned;
   • the recipients or categories of recipient to whom the personal data have been or will be disclosed;
   • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
   • the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
   • the right to lodge a complaint with a supervisory authority;
   • where the personal data are not collected from the data subject, any available information as to their source;
   • the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

   Where personal data are transferred to a third country or to an international organisation, you shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
   Please contact us regarding your rights at info@xelom.com or privacy@technoalpin.com.

4. Right to rectification
   You shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

5. Right to erasure ('right to be forgotten')
   You shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay, if one of the following reasons applies:​​​​​

   • The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
   • the data subject withdraws the consent on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR and there is no other legal basis for the processing.
   • The data subject objects to the processing pursuant to Article 21(1) DSGVO and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) DSGVO.
   • The personal data have been processed unlawfully.
   • The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
   • The personal data have been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.

   If the controller has made the personal data public and is obliged to erase it pursuant to paragraph 1, it shall take reasonable measures, including technical measures, to inform data controllers which process the personal data that a data subject has requested that they erase all links to or copies or replications of that personal data, taking into account the available technology and the cost of implementation.
   The right to erasure ("right to be forgotten") does not exist to the extent that the processing is necessary:

   • for the exercise of the right to freedom of expression and information;
   • for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
   • for reasons of public interest in the area of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the GDPR;
   • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, where the right referred to in paragraph 1 is likely to make impossible or seriously prejudice the achievement of the purposes of such processing; or
   • for the assertion, exercise or defense of legal claims.

6. Right to restriction of processing
   You shall have the right to obtain from the controller restriction of processing if one of the following conditions is met:

   • the accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data,
   • the processing is unlawful and the data subject objects to the erasure of the personal data and instead requests the restriction of the use of the personal data;
   • the controller no longer needs the personal data for the purposes of the processing, but the data subject needs it for the establishment, exercise or defense of legal claims; or
   • the data subject has objected to the processing pursuant to Article 21(1) of the GDPR, as long as it is not yet established whether the legitimate grounds of the controller override those of the data subject.

   If processing has been restricted in accordance with the above conditions, such personal data - apart from being stored - shall only be processed with the consent of the data subject or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.
   In order to exercise the right to restrict the processing, the data subject may at any time contact us using the contact details provided in the legal notice.

7. Right to data portability
   You shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, provided that:

   • the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b) of the GDPR; and
   • the processing is carried out with the aid of automated procedures.

   When exercising the right to data portability pursuant to paragraph 1, you have the right to obtain that the personal data be transferred directly from one controller to another controller, where technically feasible. The exercise of the right to data portability does not affect the right to erasure ("right to be forgotten"). This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

8. Right to object
   You shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point e or f of Article 6, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
   If personal data are processed for the purpose of direct marketing, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data will no longer be processed for these purposes.
   In connection with the use of information society services, notwithstanding Directive 2002/58/EC, you may exercise your right to object by means of automated procedures using technical specifications.
   You have the right to object on grounds relating to your particular situation to the processing of personal data concerning you which is carried out for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1), unless the processing is necessary for the performance of a task carried out in the public interest.
   You can exercise the right to object at any time by contacting the respective controller.

9. Automated individual decision-making, including profiling
   You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. This shall not apply if the decision:

   • is necessary for the conclusion or performance of a contract between the data subject and the controller,
   • is permissible under Union or Member State law to which the data controller is subject, and that law contains suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
   • with the explicit consent of the data subject.

   The controller shall take reasonable steps to safeguard the rights and freedoms as well as the legitimate interests of the data subject, which include, at least, the right to obtain the intervention of a data subject on the part of the controller, to express his or her point of view and contest the decision.
   The data subject may exercise this right at any time by contacting the relevant controller.

10. Right to complain to a supervisory authority
    You also have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.
11. Right to an effective judicial remedy.
    They shall have the right to an effective judicial remedy, without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to Article 77 GDPR, if they consider that their rights under this Regulation have been infringed as a result of the processing of their personal data not in compliance with this Regulation.

Use of Google Analytics

1. This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. However, due to the activation of IP anonymization on this website, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.
2. Google will not associate your IP address with any other data held by Google.
3. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. In addition, you may prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address), as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
4. We use Google Analytics to analyze and regularly improve the use of our website. The statistics obtained allow us to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 para. 1 p. 1 lit. f DSGVO.
5. Information of the third party provider: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.
   Terms of use: http://www.google.com/analytics/terms/us.html 
   Privacy Policy Overview: http://www.google.com/intl/de/analytics/learn/privacy.html,
   and Privacy Policy: https://policies.google.com/privacy .
6. This website also uses Google Analytics for a cross-device analysis of visitor flows, which is carried out via a user ID. You can deactivate the cross-device analysis of your usage in your Google customer account under "My data", "Personal data".

Google AdWords and Google Conversion-Tracking

Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on this Application. Google Privacy Policy: https://www.google.com/policies/privacy/.

Google Tag Manager

This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion. Google Privacy Policy: https://www.google.com/policies/privacy/.