PRIVACY POLICY
This Privacy Policy explains how personal data are collected and processed when users visit www.porphyryroads.com(the “Website”) or contact Porphyry Roads through the Website.
This Policy is provided pursuant to Article 13 of Regulation (EU) 2016/679 (“GDPR”) and should be read together with the Websites Cookie Policy.
1. Data Controller
The Data Controller is:
Porphyry Roads
Viale B. Bonfanti 10
38034 Cembra Lisignago (TN), Italy
VAT ID: IT02696990221
Email: info@porphyryroads.com
2. Personal data processed
Browsing and technical data
During normal operation, the systems and services used to provide the Website may automatically collect technical information, including:
IP address;
date and time of access;
requested pages and resources;
browser and device information;
operating system;
referring page;
technical logs and information concerning errors, security events and Website performance.
These data are generally necessary to deliver the Website, maintain its security and diagnose technical problems.
Data submitted through the contact form
When users contact Porphyry Roads through the Website, the following information may be collected:
first name;
last name, where provided;
email address;
content of the message;
any other information voluntarily included in the communication.
Users are requested not to include special categories of personal data—such as information concerning health, political opinions, religious beliefs or other sensitive matters—unless strictly necessary. Any unnecessary sensitive information received may be deleted.
Email communications
If a user contacts Porphyry Roads directly by email, the sender’s email address, the content of the message and any other information or attachments voluntarily provided will be processed for the purpose of handling the communication.
Cookies and similar technologies
The Website uses cookies and similar technologies for technical purposes and, subject to the user’s consent, for platform analytics.
Further information about the technologies used, their providers, purposes and duration is available in the Website’s Cookie Policy.
3. Purposes and legal bases
Personal data may be processed for the following purposes:
Providing and securing the Website
Technical and browsing data are processed to:
make the Website available;
ensure its correct operation;
maintain security;
prevent abuse, fraud and unauthorised access;
diagnose technical problems.
The legal basis is the legitimate interest of the Data Controller in operating and protecting the Website, pursuant to Article 6(1)(f) GDPR.
Responding to enquiries
Data submitted through the contact form or by email are processed to answer questions, provide requested information and manage communications with users.
Depending on the nature of the request, the legal basis is:
Article 6(1)(b) GDPR, where processing is necessary to take steps at the user’s request before entering into a contract; or
Article 6(1)(f) GDPR, based on the legitimate interest of Porphyry Roads in responding to enquiries and maintaining business communications.
No separate consent is required merely to answer a request submitted by the user.
Compliance with legal obligations
Personal data may be processed where necessary to comply with legal, regulatory, accounting or tax obligations.
The legal basis is Article 6(1)(c) GDPR.
Establishing or defending legal claims
Where necessary, personal data may be retained and used to establish, exercise or defend legal claims.
The legal basis is Article 6(1)(f) GDPR, based on the legitimate interest of the Data Controller in protecting its rights.
Platform analytics
With the user’s prior consent, analytics technologies provided through Hostinger Website Builder may collect information about the use of the Website for statistical and improvement purposes.
The legal basis is consent pursuant to Article 6(1)(a) GDPR. Consent may be refused or withdrawn at any time through the Website’s Cookie Settings without affecting access to the Website.
4. Provision of personal data
Providing browsing data required for the technical operation of the Website is necessary in order to access the Website.
Providing the information marked as mandatory in the contact form is necessary to submit and handle the request. Failure to provide it may make it impossible for Porphyry Roads to respond.
Providing optional information is voluntary.
5. Processing methods and security
Personal data are processed using electronic and, where necessary, manual methods.
Appropriate technical and organisational measures are adopted to protect personal data against accidental loss, unauthorised access, unlawful disclosure, alteration or destruction.
Access is limited to persons who require the data for the purposes described in this Policy and who are subject to appropriate confidentiality obligations.
6. Recipients and service providers
Personal data may be accessed or processed by:
persons authorised by Porphyry Roads;
hosting, Website Builder and email service providers;
technical support, information technology and security service providers;
professional advisers, where necessary;
public authorities or other entities where disclosure is required by law.
The Website is hosted and operated through Hostinger Website Builder. Hostinger may process Website data on behalf of Porphyry Roads as a data processor for the provision of hosting, Website Builder and related technical services.
Hostinger’s privacy documentation is available at:
https://www.hostinger.com/legal/privacy-policy
https://www.hostinger.com/legal/dpa
Personal data are not sold to third parties.
7. International data transfers
Some technology providers or their subprocessors may process personal data outside the European Economic Area.
Where such transfers occur, they are carried out in accordance with Articles 44–49 GDPR, using an adequacy decision adopted by the European Commission or appropriate safeguards such as the European Commission’s Standard Contractual Clauses.
Further information about processing locations and safeguards may be requested from Porphyry Roads or found in the relevant provider’s privacy documentation.
8. Data retention
Personal data submitted through the contact form or by email are normally retained for no longer than 12 months after the request has been dealt with, unless further retention is necessary because:
the communication leads to a contractual or business relationship;
a longer period is required by law;
the data are necessary to establish, exercise or defend legal claims.
Where a communication results in a contractual relationship, the relevant data may be retained for the period required by applicable civil, accounting and tax legislation.
Technical and security logs are retained for the period necessary to operate and protect the Website, investigate anomalies and comply with legal obligations.
Data processed through analytics technologies are retained for the periods specified in the Cookie Policy and according to the user’s consent preferences.
When the applicable retention period expires, personal data are deleted or anonymised.
9. External websites
The Website contains links to external websites, including 33trentini.life and pathugo.com.
This Privacy Policy applies only to porphyryroads.com. Once users follow an external link, any personal data collected by the destination website are processed according to that website’s own privacy and cookie policies.
Purchases, payments, orders and related customer data are not processed through porphyryroads.com. The Porphyry Roads outdoor collection is sold through 33trentini.life, whose policies apply to the relevant transactions.
10. Automated decision-making
Porphyry Roads does not use personal data collected through the Website for automated decision-making or profiling that produces legal effects or similarly significantly affects users.
11. Users’ rights
Under Articles 15–22 GDPR, where applicable, users have the right to:
obtain confirmation as to whether their personal data are being processed;
access their personal data;
request the rectification of inaccurate or incomplete data;
request erasure of their personal data;
request restriction of processing;
object to processing based on legitimate interests;
receive personal data in a structured, commonly used and machine-readable format;
withdraw consent at any time, where processing is based on consent;
lodge a complaint with a competent supervisory authority.
Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.
Requests may be sent to:
Porphyry Roads may request information reasonably necessary to verify the identity of the person submitting the request.
12. Complaints
Users who believe that the processing of their personal data infringes applicable data protection law have the right to lodge a complaint with the competent supervisory authority.
In Italy, the competent authority is:
Garante per la protezione dei dati personali
https://www.garanteprivacy.it
The right to seek a judicial remedy remains unaffected.
13. Changes to this Privacy Policy
This Privacy Policy may be updated following changes to the Website, the services used or applicable legislation.
The date shown at the beginning of this Policy indicates the latest revision. Users are encouraged to review this page periodically.
