(pursuant to article 13 and 14 of European regulation No. 679/16)



From the design phase, the Spirale S.r.l. website intends to ensure compliance with the principles enshrined in EU Regulation No. 2016/679 concerning the protection of individuals with particular regard to the processing of personal data, without exception, as well as to the free circulation of personal data in the public interest consistent with the right to transparency.

Spirale S.r.l. guarantees data subjects the possibility of interacting with the website to freely use the services requested, such as sending newsletters or information for which the data subject has knowingly expressed consent for processing.

The personal data processed - which may be collected or provided in the specific forms by the browser - and any other type of pertinent information, are accessible via the address www.spirale.it which corresponds to the official website of Spirale S.r.l.

With this policy, Spirale Srl, not only describes the methods of using the site, but also informs users and browsers about personal data processing and the relevant guarantees recognised by law, pursuant to art. 13 of the aforementioned “Regulation”.

This policy is provided exclusively for the personal data contained or acquired during the use of the Spirale S.r.l. website and not for other websites (of which the COMPANY is not responsible or co-owner) that can be consulted by the user via links.


Data controller


The controller of the personal data is Spirale S.r.l. in the person of the legal representative pro tempore, domiciled for the role at the company offices. The current person nominated as data controller is Carlo Pase, who can be contacted at the following address: c.pase@spirale.it – telephone: +39 0461 591417 e-mail: spirale@spirale.it, PEC (certified email): spirale@pec.spirale.it

Purpose of the processing and legal basis

Personal data will be processed in a manner consistent with the services offered by Spirale S.r.l. through its own website to guarantee the supply of goods and services pertaining to the subject of the articles of association, as well as to allow direct marketing activities (activities for which the company has a suitable data processing register containing the categories of subjects to whom the personal data refer).

In the framework of these purposes, the processing also concerns data relating to registrations on the website required to manage relations with Spirale Srl, as well as to enable efficient corporate communication and fulfil any legal, regulatory or contractual obligations.


Place and method of processing


The data are processed exclusively within Italy by personnel who have been instructed, trained and authorised to lawfully process the data according to the principles of fairness, lawfulness, transparency, relevance and not beyond the purposes of data collection and subsequent processing.

The data processing related to the services offered by the website of Spirale S.r.l. takes place for the time strictly necessary to achieve the goals set by the user who is afforded all the minimum security (and confidentiality) measures aimed at preventing the loss of data, illicit or incorrect use or unauthorised access.

The personal data provided by the users who register or use the websites services of Spirale S.r.l. - such as name, surname, email address, telephone number, company and website - can be used for other processing operations compatible with the purposes of the data collection, such as sending emails about company communications and of public interest (e.g. notifications regarding food contamination).

The personal data of users who request documents or information material (newsletters, answers to questions, documents and provisions, etc.) are used only to perform the service requested and are not subject to transfer or distribution.

The use of automated processing or automated decision-making processes or ones aimed at profiling users of the Spirale Srl website is not envisaged.

Type of data processed and recipients


The categories of data processed, as well as the categories of recipients to which the data refer, are outlined in the data processing register available at the headquarters of Spirale S.r.l.

Storage time

The data will be kept for a period of time which does not exceed the achievement of the aforementioned purposes (“storage limitation principle”, article 5 of the EU Regulation) or based on the deadlines established by law.

Transfer of data abroad


The data are not transferred to other countries outside the European Economic Area




The data subject’s rights (ref. Articles 15-21 of the EU Regulation) can be exercised at any time and are summed up in the right:

  • to obtain confirmation of whether or not personal data concerning him or her are being processed and access to the personal data;

  • to obtain rectification of the data without unjustified delay, including the integration of the data;

  • to obtain the erasure of the data;

  • to obtain the limitation of processing and the communication of any revocation of the limitation;

  • to data portability;

  • to lodge a complaint with a supervisory authority;

The above applies unless the Data Controller has legitimate reasons to the contrary.