Privacy Policy

NEW LIFE SRL respects the privacy of its users and undertakes to protect its personal data on the bases of the European Regulation UE 2016/679 issues by the European Parliament and Council of 27 April 2016 “concerning the protection of individuals, with regard to treatment of personal data, as well as their free circulation of such data and repealing Directive 95/46/CE (General data protection regulation), in force since 24 May 2016 and applicable as from 25 May 2018.

1. Foreward
The privacy regulations describe the use of the user’s personal data by NEW LIFE SRL during the interaction with NEW LIFE SRL for our services or simply for our internet website consultation.
They are further meant to inform the users of their legal rights in connection to privacy and related protection offered by the legal system.
We invite the user to carefully read these privacy rules, in order to be informed on the use of his personal data on our part.
For any question or in order to exercise a right in connection to privacy, we invite to follow the instructions contained in the present privacy norms. Contact NEW LIFE SRL for any question about privacy. Contact NEW LIFE SRL for any question about privacy.

2. Institutional Website
Our company’s website deals with the presentation of our goods/services. Use of website is for everyone and we do not knowingly collect data concerning them.
NEW LIFE SRL is the data controller of this website and the processing of any personal data made by or on behalf of NEW LIFE SRL. The owner of the data processing carried out by or on behalf of NEW LIFE SRL is NEW LIFE SRL, in the person of its Data Processing Manager, Mr. BATTISACCO ALESSIO. In these privacy rules we refer to “NEW LIFE SRL”, “we” or “us” to indicate the NEW LIFE SRL responsible for the processing of user data.

3. Personal data that we can collect
Personal data, or personal information, is information related to any subject from which one can derive its identity. The data from which the user’s identity has been removed (anonymous data) is therefore excluded.
We collect a series of information about our customers. These personal data are attributable to the following categories.

Identification data: name, surname, and in case user confer with us by mean of social media, this category includes also user name utilized in such social media

  • Contact data: postal address, telephone numbers, email addresses, invoice address.
  • User’s identification codes or keys.
  • Personal characteristics data: date of birth, gender, Nationality.
  • Operational data: include information in relation to payments to and from customer, as well as further information in relation to products and services purchased from us.

We do not collect sensitive data about you (they include data revealing racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, health status information, and genetic and biometric data). Furthermore, we do not collect the judicial data concerning the user.

4. How the collection of personal data takes place?
Following a list of different methods of and from user’s data colleting we adopt.
Direct interaction. The user decides to communicate the identification, contact and financial data by completing a form or by communicating such data by post, telephone, e-mail or by chat or social media.
Personal data supplied by the user are included when this:

  • Requires an offer for goods/service of ours;
  • Forwards enquiries os solicits information receiving;
  • Requiries an appointment;
  • Forwards a C.V. from our web site;
  • Contacts us via social media
  • Sign up for our Newsletter


5. How we utilize user’s personal data
We utilize personal data within the limits foreseen by the law. Generally we utilize data in the following circumstances.

  • If we are to execute a contract that is being concluded or already concluded with the user. For example, issue an invoice for a good/service provided to a user.
  • If it is necessary to pursue our legitimate interests (or those of third parties) provided that the interests and fundamental rights of the user do not prevail over them.
  • Should we comply with obligations imposed by laws or regulations.

In general, the legal basis on which we base the processing of personal data of the user does not include the consent of the same except where expressly provided for by law, for example for sending certain direct marketing communications. In cases where the legal basis is based on consent, the user has the right to withdraw consent at any time.
For more information please compare the legal bases on which we base ourselves for the processing of personal data with the legal basis on which we base the processing of personal data.

6. The legal bases on which we rely for the processing of personal data
User is aware of the fact that we could treat its personal data based on different legal bases, depending on specific purpose of data utilization.
Our decision – making process is not automated.
We invite user to forward us any question on the subject. Please refer to How to contact NEW LLIFE SRL section for questions concerning privacy.

7. Advertising, Marketing and user preferences in comunications
In case of specific consent we could utilize direct marketing strategies by e-mail, telephone, SMS or post. For example, user could receive our newsletter through his e-mail box. We strive to the most for our web site to clearly indicate our activities and the kind of messages sent to user, both when it’s the user himself to decide to receive our newsletter, or on occasion of compilation of contact form. The user can change his mind at any time and decide to unsubscribe.

8. Cookie
By using the site, user are consenting to the use of cookies in accordance with this policy. If user do not consent to the use of cookies in this way, user must set its browser appropriately or do not use the site. If user decide to disable cookies this could affect the browsing experience on the site. Cookies are computer files or partial data that can be saved on user’s computer or other devices enabled to browse the internet (eg smartphone or tablet) when user visit a site. A cookie contains the name of the website from which the cookie comes from, the duration of the cookie (ie how long it will remain on your device), and a value made up as a rule by a unique randomly generated number. Cookies are used in order to make the use of the site easier and / or adapt the site and the services offered in it to the interests and needs of the user. Cookies can also be used to speed up future user activities on the site. Cookies are also used to track users and compile anonymous statistics in aggregate form.

More information on utilized cookies
When visiting the present website, the following four kinds of cookies can be introduced in p.c or device: proprietary cookies (first part), third party cookie, session cookies and persistent cookies.

Session cookies
The duration that elapses between when the Internet browser is opened and when it is closed is called the browsing session. Session cookies are cookies stored on the computer or other device of the visitor during a browsing session, but expire and are normally deleted at the end of a browsing session.

Proprietary cookies (first part)
Proprietary cookies (first party) are cookies that are saved directly on user computer or other device. They may include cookies such as session cookies and persistent cookies (described below). We use proprietary cookies (first part) to follow the movements made by the computer or other device of the visitor by consulting one of our sites, for example for analysis purposes.

Third-party cookies
Third-party cookies are cookies managed by third parties that can collect and track certain navigation data. This site uses the service of Google Analytcs (described in navigation data and statistics collected by third parties)

Persistent cookies
Persistent cookies are cookies stored on the computer or other device of the visitor during a browsing session, but remain in the computer or other device after the end of the aforementioned browsing session (eg registration of the password). Persistent cookies allow our sites to recognize the visitor’s computer or other device when it is used to access one of our sites again, after the end of a browsing session and at the beginning of a new browsing session, essentially for help the visitor to quickly reconnect to our site

NAVIGATION DATA AND STATISTICS COLLECTED BY THIRD PARTIES
As is now customary on the Internet, this site uses statistical analysis tools provided and managed by third parties that can collect and “track” some navigation data.
It is worth pointing out that many Italian and foreign sites normally use these technologies and solutions in “outsourcing”, but very few people report it in their “Privacy Information”. We have tried to do it and to inform you in the most correct and transparent way possible: we are still always vs. provision for any information or further clarification.
Being collected by different tools and companies compared to the site manager, these data are not physically owned by New Life Srl which can use them only in consultation, but has no possibility to modify or delete them independently. For these operations and to know in depth the privacy policy applied to such data, the user must contact the Data Controller directly, or the Company that directly provides the statistical service used.
The tools belonging to third parties used within this site are the following:
– Google Analytics (provided by: Google Inc. 1600 Amphitheater Parkway – Mountain View CA 94043, USA)

INFORMATION ON GOOGLE ANALYTICS
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files that are stored on your computer to allow the website to 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. 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. Google will not associate your IP address with any other data held by Google. You may refuse to use cookies by selecting the appropriate settings on your browser, but this may prevent you from using all the features of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Useful addresses to better understand the privacy policy of Google Analytics:
http://www.google.com/analytics/it-IT/tos.html
http://www.google.com/privacypolicy.html
Any requests relating to data concerning this treatment must be addressed to the Data Controller (Google Inc.).

9. Disclosure of personal data
Your personal data will not be shared with third parties, except with external auditors and professional consultants such as bank, legal, accounting and insurance consultants and administrative, regulatory and law enforcement agencies. Furthermore, if the activity for which it was requested to request the intervention of an external inspector or collaborator, the data could be shared with the latter.
We require all third parties to respect the security of the user’s personal data and to manage them in accordance with current legislation. We do not allow third party service providers to use your personal data for their specific purposes, but we only allow them to process your personal data for the specified purposes and in accordance with our instructions.

10. Data security
We have established appropriate security measures to prevent the accidental loss of your personal data, as well as their use or access by unauthorized parties, as well as their alteration or dissemination. Furthermore, access to personal data of the user is limited to collaborators and other third parties who, for reasons connected with the performance of their business, must necessarily know. The user’s personal data will be processed exclusively upon our instructions and these subjects are bound by the obligation of confidentiality.
We have set up procedures for the management of any personal data breaches and will take care to communicate such violations to you and to any supervisory authority if required by law.

11. Third party links
This site may include links to third-party sites, as well as plug-ins and third-party applications (for example, Facebook). By clicking on these links or linking to them you agree that third parties collect or share user data. The sites of third parties are not controlled by us and New Life Srl is not responsible for the respective privacy policies. Abandoning our site, the user is required to read the privacy policy of any other site consulted.

12. Data retention
We will store your personal data only for the time necessary to fulfill the purposes for which the data were collected, including the purposes related to the satisfaction of any legal, accounting or reporting obligation.
To determine the correct retention period of personal data, we consider the quantity, nature and degree of sensitivity of personal data, the potential risk related to possible damages due to unauthorized use or for the diffusion of personal data of the user, the purposes for which the treatment and the possible existence of alternatives take place, together with the applicable legal obligations.
For tax purposes, the law requires the retention of our customers’ basic information (including contact details, identifiers, financial details and transactions) for six years from the time the customer’s status becomes invalid.
For curriculum vitae sent from the appropriate area of ​​our site they are stored for a maximum of 24 months, after this period will be deleted from our database.
In certain circumstances, the user can ask us to delete data concerning him; for more information, see the section The rights guaranteed by law below.

13. The rights guaranteed by law
The European Regulation on the protection of personal data is applied to the user, he is the owner of the rights ensured by the privacy protection legislation in relation to his personal data.

  • Right to information – we have the obligation to inform you about the use of your personal data on our part (obligation that we comply with these privacy regulations);
  • Right of access – right to submit a “request for data access by the interested party” to obtain a copy of the personal data of the interested party filed by NEW LIFE SRL;
  • Right of rectification – right to demand correction of personal data if they are incomplete or incorrect;
  • Right of cancellation – also known as “right to be forgotten” when, under certain circumstances, the user can request to delete personal data concerning him (provided there is no provision for their maintenance and which prevails over the request);
  • Right to limit the processing – right to request, in certain circumstances, the suspension of the processing of personal data;
  • Right to portability – the right to request a copy of the user’s personal data in a commonly used format (for example, a .csv file);
  • Diritto di opposizione – diritto di opporsi al trattamento dei dati personali dell’utente (ad esempio, se l’utente non ammetta il trattamento dei dati per finalità di marketing diretto);

These rights are subject to certain rules that determine their exercise. For more information, you can consult the Guide to the application of the European Regulation on the protection of personal data.
You can contact us if you wish to exercise any of the aforementioned rights (see the section Contacting NEW LIFE SRL for a privacy question).
There are no costs for access to the user’s personal data (or for the exercise of the aforementioned rights). Nevertheless, we reserve the right to apply substantial costs if the request is clearly groundless, repetitive or excessive. Alternatively, and under these circumstances, we may refuse to comply with the user’s request.
We may request user-specific information to help us confirm your identity and ensure correct access to your personal data (or to exercise any of your rights). This security measure is necessary to ensure that personal data are not disclosed to any third party that does not have the right to receive them. We may also contact you to request additional information related to your request in order to speed up the process.
We do our best to answer all legitimate requests within a month. Sometimes it may take more than a month if the request is particularly complex or the user has submitted numerous requests. In these cases, it will be our concern to communicate the timing to the user and keep it updated.
We have set up a Privacy Division with a working team that oversees all issues related to these privacy regulations. If the user has further questions relating to these privacy regulations, or intends to submit a request to exercise one of the rights guaranteed by law, he can contact the RDP Working Group through the contact information in section 14. how to contact NEW LIFE SRL for privacy questions.

14. How to contact New Life Srl for privacy concerning questions
For any questions related to this privacy policy, or if you intend to exercise any of your rights, you can contact the Company in the following ways:
E-mail: info@newlifecontract.com