Contact Form Disclosure

Contact form information according to Art. 13 EU Regulation 2016/679

Reference Standards:

- EU Regulation No. 679 dated April 27, 2016 on the protection of individuals with regard to the protection and processing of personal data (hereinafter “EU Regulation”)

- Legislative Decree No. 196 dated June 30, 2003 (hereinafter the “Privacy Policy”), as revised by Legislative Decree No. 101 dated August 10, 2018

- Guidelines on Promotional Activities and Counteracting Spam dated July 4, 2013 (hereinafter “Personal Data Protection Authority Guidelines”)

Cadlog Group S.r.l. (hereinafter “the association”), a company belonging to the Var Group S.p.A., with its head office in Via Derna, 26 - 20132 Milan - VAT number 02989490368, desires to inform users about the terms and conditions applied by the association to the processing operations performed on their personal data.
In particular, the information is provided in relation to the personal data of users who are filling in one or several forms in the “Contact us” section on the association’s website.

The association acts as a “data processor”, meaning “the natural or legal person, public authority, service or other body which alone or jointly with others determines the purposes and means of processing personal data”.

Specifically, the processing of personal data may be carried out by individuals specifically authorized to perform processing operations on users’ personal data and, to this end, specifically instructed by the association.

In the application of the legislation on the processing of personal data, users who consult and use the association’s website acquire the status of “interested subjects”, meaning the natural person to which the personal data processed refer.


  1. Purpose and legal ground of personal data processing

The personal data processed by the association is provided by users by filling in the contact form, in order to request information or assistance. In this case, the processing is based on the execution of specific requests and the fulfillment of pre-contractual actions; the explicit consent of users is therefore not required.

On the basis of the specific and optional consent provided by users, personal data may be processed by the association for the purpose of sending commercial and promotional communications, via telematic and/or telecommunication means, relating to the association’s services and products, as well as information on the association’s institutional activities.

Please note that consent to the processing of personal data may be revoked at any time; this shall not affect the legality of processing carried out prior to the revocation.
Consent already given may be revoked by writing to the following email address:


  1. Modalities and duration of personal data processing

The processing of users’ personal data is carried out by specifically authorized corporate staff; for this purpose, such individuals are specifically identified and instructed by the association.

The processing may be carried out by means of IT, telematic, or printed media in compliance with the regulations guaranteeing security and confidentiality, as well as, among other things, the accuracy, updating, and relevance of the personal data to the declared purposes.

The personal data collected will be stored in electronic and/or paper files at the registered and/or operating offices of the association.
Personal data provided by users will be stored to enable identification for a maximum period of time necessary to pursue the purposes, as identified in point 1 of this notice, for which such data is collected and processed.

In any case, the determination of the retention period occurs in accordance with terms permitted by applicable law.
In relation to marketing and sales promotion purposes, in case the optional consents requested are given, the personal data collected will be kept for the time strictly necessary for the management of the above-mentioned purposes in accordance with principles based on compliance with the law in force and the balance between the legitimate interests of the association as well as the rights of users. Consequently, in the absence of specific regulations setting different retention periods, the association will take care to process personal data for the aforementioned marketing and sales promotion purposes only for a reasonable period of time.

In any case, the association takes utmost care to avoid the indeterminate use of personal data, proceeding periodically to verify adequately whether the users’ interest in having personal data processed for marketing and sales promotion purposes is still valid.


  1. Nature of providing personal data

The submission of personal data is optional but necessary in order to fulfill requests for information or assistance made by users.

In particular, refusal to complete the fields in the contact form prevents requests for information or assistance from being submitted.

In this case, consent to the processing of personal data is “obligatory” in order for the association to reply to requests for information or assistance.

In all other cases referred to in point 1 of this notice, the processing is based on consent; as already stated, consent is always revocable.


  1. Recipients of personal data

Users’ personal data may be communicated, in Italy or abroad, within the territory of the European Union (EU) or the European Economic Area (EEA), in fulfillment of a legal obligation, regulation, or EU legislation; in particular, personal data may be communicated to public authorities and public administrations for the performance of institutional purposes.

Furthermore, without requiring the user’s consent, personal data may be communicated to companies belonging to the SeSa S.p.A. business group for the sole purpose of responding to requests for information or assistance addressed to the association.

Personal data may be transferred to third countries outside the EU or the European Economic Area based on the existence of adequacy decisions of the European Commission or based on specially authorized contractual clauses or binding corporate rules.


  1. Rights under articles 15, 16, 17, 18, 20 and 21 of EU Regulation 2016/679

Users, as data subjects, may exercise their rights of access to personal data under article 15 of the EU Regulation and their rights under articles 16, 17, 18, 20 and 21 of the EU Regulation regarding adjustment, cancellation, restriction of processing of personal data, data portability, where applicable, and the objection to the processing of personal data.

The aforementioned rights may be exercised by writing to the following address:

If the association does not respond within the timeframe provided by law, or if the response to the assertion of rights is inadequate, users may submit a complaint to the Data Protection Authority (Garante per la Protezione dei Dati Personali).

Contact details:

Garante per la Protezione dei Dati Personali
Piazza Venezia n. 11 - 00187 Rome
Fax: (+39) 06.69677.3785
Telephone switchboard: (+39) 06.69677.1


  1. Data Protection Manager

It is hereby specified that SeSa S.p.A., the holding company of the business group to which the association belongs, has appointed a Personal Data Protection Manager. The Data Protection Manager monitors compliance with data protection regulations and provides appropriate consulting. Furthermore, where necessary, the Data Protection Manager cooperates with the Data Protection Authority. Please find the relevant contact details hereafter:



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