Privacy Policy
Valli is a company owned by ASSA ABLOY Italia Spa.
ASSA ABLOY Italia SpA, (hereinafter "ASSA ABLOY", the "Company", "we", "our / a / i / e"), with registered office in Via Bovaresa 13, San Giovanni in Persiceto 40017 (Bologna), and e-mail privacy.it.openingsolutions@assaabloy.com as data controller collects and processes personal data in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation ("GDPR"), the Legislative Decree. June 30, 2003, n. 196 ("Privacy Code"), Legislative Decree 10 August 2018, n. 101 of adaptation of the Privacy Code to the GDPR(the "Adjustment Decree"), in compliance with the privacy principles and the rights of the interested party.
This constitutes the information provided pursuant to art. 13 of the GDPR in relation to the collection and processing of your personal data by ASSA ABLOY for the purposes identified below.
Version updated 10 November 2022
1. Personal data processed
ASSA ABLOY processes the following personal data provided by you during and as a result of browsing the website and / or using the messaging servers, and / or in relation to our presence on the social platform and / or when filling in forms of contact and / or personal data in paper or digital form, surveys, questionnaires or researches and / or in the context of paper or electronic correspondence and / or during purchases, meetings, events or other contacts with our agents or third parties that you have authorized to transmit the data to us. The necessary data are always indicated; all additional data are always voluntary.
- Personal data: name, surname.
- Contact details: e-mail, telephone, physical address for sending products or administrative, commercial and / or marketing communications.
- Professional data: name of the company or company they belong to and relative VAT number / tax code; title and / or function, professional information, type of activities ect
- Bank or payment details: any bank account codes, credit cards and / or other means of payment.
- Device data and navigation data: IP address, operating system, browser type, URL of the web pages from which you accessed this website, web pages you visited, links you clicked on, the duration of your navigation on our site, information relating to your requests and purchases on our website.
For more detailed information on how ASSA ABLOY processes the personal information collected in relation to your use of our website and related cookie policy, see the Privacy Policy - Website and Cookie Policy.
For more detailed information on how ASSA ABLOY treats personal information collected in relation to our social platforms, please consult the Social Media Privacy Policy.
For more detailed information on how ASSA ABLOY treats personal information collected in connection with investigations into the Code of Conduct, please see the Code of Conduct Privacy Policy.
2. Purpose and legal basis of the processing; nature of the provision of personal data
| Purpose of the processing of personal data | Legal basis for the processing of personal data | What is the legal basis for such processing? |
| To provide you with the information you request via the website. | The necessity to take steps at your request prior to entering into a contract with you in relation to the use of the website, our products and services and to perform such contract with you. | The provision of the personal data is mandatory for this purpose. Failure to provide the data may lead to the impossibility to supply the requested information. |
| To fulfil your order where you have made a purchase to contact you about sales and as a part of our customer relation procedures. | The necessity to take steps at your request prior to entering into a contract with you in relation to the use of the website, our products and services and to perform such contract with you. | The provision of the personal data is mandatory for this purpose. Failure to provide the data may lead to the impossibility to fulfil your order or customer request. |
| To offer you guided sales tools to assist you with selecting the correct product or service. | The necessity to take steps at your request prior to entering into a contract with you in relation to the use of the website, our products and services and to perform such contract with you. | The provision of the personal data is mandatory for this purpose. Failure to provide the data may lead to the impossibility to fulfil your customer request. |
| For Customer Service purposes. | The necessity to take steps at your request prior to entering into a contract with you in relation to the use of the website, our products and services and to perform such contract with you. | The provision of the personal data is mandatory for this purpose. Failure to provide the data may lead to the impossibility to fulfil your customer request. |
| To ensure that the website is up-to-date and meets the needs of users, to analyze, review and improve the products or services offered on the webite, to provide users with a user-browsing experience friendly. The information used for this purpose will remain strictly anonymous and will not be used to identify any user nor will it be aggregated to the personal data of users. | The necessity to pursue our legitimate interest in protecting our assets, our business and our rights. | The provision of the personal data is mandatory for this purpose. Failure to provide the data may lead to the impossibility to allow you to use our website. |
| To ensure compliance with the website Terms and Conditions, the safety of the website and its users, to prevent fraud and to protect the rights and / or assets of the Company. | The necessity to pursue our legitimate interest in enforcing the website Terms and Conditions, ensuring the safety of the website and its users and the protection of our rights and assets; The necessity to comply with a legal obligation to which ASSA ABLOY is subject. | The provision of the personal data is mandatory for this purpose. Failure to provide the data may lead to the impossibility to allow you to use our website. |
| To share your personal data with other companies belonging to the ASSA ABLOY for administrative, legal and business reasons. | The necessity to pursue our legitimate interest in abiding by and enforcing the ASSA ABLOY Group's guidelines. | The provision of the personal data is mandatory for this purpose. Failure to provide the data may lead to the impossibility to allow you to use our website. |
| Send you commercial (including market researches) and marketing communications about our products, services or events by electronic means (i.e. e-mail, SMS, newsletter) and / or non-electronic means (i.e. paper mail and telephone calls). | Your consent. | The provision of your personal data is voluntary and optional for this purpose. Failure to provide it will not have any negative consequences. on the commercial or contractual relationship with ASSA ABLOY. |
| Send you promotional e-mails relating to products similar to those in your order (Article 130 paragraph 4 of the Privacy Code), using the e-mail address that you send us at the time of your order. You may object to these treatments at any time, and when any communication is sent. | The need to pursue our legitimate interest in carrying out promotional activities with our own customers. | The provision of your personal data is voluntary and optional for this purpose. Failure to provide it will not have any negative consequences. on the commercial or contractual relationship with ASSA ABLOY. |
| Carry out profiling activities about your interests and preferences in relation to ASSA ABLOY products, services and events, to carry out commercial analyzes and send you commercial and marketing communications based on your interests and preferences; for these purposes we might carry out commercial classifications using the data provided by you when filling in the customer form, event form, contact form, or on the occasion of your participation to seminars and/or events organized by the ASSA ABLOY, the data relating of your participation to surveys, questionnaires and market research, data relating to purchases and services used and data deriving from any analysis of your navigation and interaction on the web and social media. | Your consent. | The provision of your personal data is voluntary and optional for this purpose. Failure to provide it will not have any negative consequences on the commercial or contractual relationship with ASSA ABLOY. |
| Carry out a minimal profiling activity about your interests and preferences in relation to ASSA ABLOY products, services and events, to carry out commercial analyzes and, to the extent that there is a legal basis for marketing communications, send you communications based on your interests and preferences, using only the data about the source of your contact, the professional data (type of business, city or region) that you may have provided when filling in contact forms, and/or registering on our website or social media, or of the customer form and purchase orders (if you are already a customer), and the data deriving from the possible analysis of his navigation and interaction only on our website. In consideration of the source, type, minimization and purpose of the data processed (commercial classifications for the purpose of sending our proposals more in accordance with your needs, also in your interest), we consider excluded any possibility of risk, incidence, legal effect or injury for your privacy rights. | The need to pursue our legitimate interest in sending you commercial proposals that meet your needs. | The provision of your personal data is voluntary and optional for this purpose. Failure to provide it will not have any negative consequences on the commercial or contractual relationship with ASSA ABLOY. |
| Carry out customer satisfaction surveys, by electronic means (i.e. e-mail, SMS, newsletter) and / or non-electronic means (i.e. paper mail and telephone calls) inviting you to participate. You may object to these treatments at any time, and when any communication is sent. | Your consent for participation in surveys. The need to pursue our legitimate interest in obtaining useful information to improve our offers, to invite you to participate. | The provision of your personal data is voluntary and optional for this purpose. Failure to provide it will not have any negative consequences on the commercial or contractual relationship with ASSA ABLOY. |
| Sharing your personal data with other ASSA ABLOY Group companies and third parties for their marketing purposes. | Your consent. | The provision of your personal data is voluntary and optional for this purpose. Failure to provide it will not have any negative consequences on the commercial or contractual relationship with ASSA ABLOY. |
| Make video recordings or photographs of yourself during the participation to ASSA ABLOY events, publish the same also for promotional purposes within the company’s communication channels such as intranet (accessible only to employees) or public digital channels ( website and social networks). | Your consent. | The provision of your personal data is voluntary and optional for this purpose. Failure to provide it will not have any negative consequences. on the commercial or contractual relationship with ASSA ABLOY. |
| Make video recordings or photographs of yourself during the participation to ASSA ABLOY events, publish the same also for promotional purposes within the company’s communication channels such as the newsletter, the printed annual report, the brochures or catalogues both in digital or paper format. | Your consent. | The provision of your personal data is voluntary and optional for this purpose. Failure to provide it will not have any negative consequences. on the commercial or contractual relationship with ASSA ABLOY. |
| Meet the legal requirements to which ASSA ABLOY is subject, such as requirements related to reporting tax or financial information. | The need to fulfill a legal obligation to which ASSA ABLOY is subject. | The provision of your personal data is mandatory for this purpose. |
| To undertake and / or constitute oneself as a party in judicial and / or administrative actions for the exercise and defense of rights. | The need to ascertain, exercise or defend a right in court or whenever the judicial authorities exercise their judicial functions. | The provision of your personal data is necessary and mandatory for this purpose. |
3. Methods of processing and storage of personal data
We collect and process your personal data by electronic, automated and / or non-electronic means. With regard to marketing and promotional activities, you will always have the opportunity to express your preferences regarding the ways in which to receive communications about our products or services or relevant events or to participate in market research or surveys on customer participation, come indicator above. In this regard, you can send us an e-mail to the address privacy.it.openingsolutions@assaabloy.com. In the absence of the manifestation of your preferences, we will carry out any of our marketing and promotional activities by all means of communication. Profiling activities for marketing purposes and sending commercial and marketing communications are carried out using the CRM Dynamics 365 Marketing Core software.
Furthermore, we will keep your personal data for the time necessary to fulfill the purposes for which it was collected, in accordance with the GDPR and this Privacy Notice. This means that you delete your personal data or make them anonymous as soon as they are no longer necessary for the processing purposes indicated above, without prejudice to the exercise of your right to object and to withdraw consent at any time, as applicable. In any case, it may be necessary to preserve personal data for longer periods, for example it is necessary to fulfill legal obligations, or to ascertain, teach or defend a right in court or where this is permitted by applicable law and regulations. Please consider contracts that personal data contained in, commercial communications and correspondence may be subject to data retention periods established by law and up to 10 years, in accordance with the ordinary limitation period in Italy.
Duration of the Marketing Consent
The consent given in relation to marketing communications (and / or marketing based on your interests) will be considered valid until it is revoked by you, or no communication / interaction occurs between us for a period of 24 months to confirmation of your interest (such as purchase orders, your requests for quotes and/or technical information, sending you our marketing communications/newsletters without unsubscribing on your part, etc.).
4. Communication to third parties and international transfers of personal data
ASSA ABLOY may share your personal data with our personnel duly authorized to process personal data. We may also communicate your personal data to other subjects, who can be qualified as independent data controllers or as data processors according to the case, for example with:
a) Current or future subsidiaries of ASSA ABLOY for the related marketing purposes or for the Group's administrative, legal and commercial purposes; and / or
b) Entities or institutions that need to receive your personal data on the basis of legal provisions and / or regulations, such as administrative, judicial and law enforcement authorities in the exercise of their duties and functions; and / or
c) In the event of extraordinary transactions (e.g. mergers and acquisitions, transfers, sales, etc.) to a buyer or potential future buyer of our business;
d) Service providers who will act as data controllers on the basis of ASSA ABLOY's instructions contained in a data processing agreement (DPA) pursuant to art. 28 GDPR. By way of example, such service providers may include, by way of example, companies that manage or maintain the IT infrastructure on which the site and other IT tools of the Company are based, the call center of service providers o pre or post sales assistance, logistics operators in case it is necessary to deliver a product to the user, agencies specialized in the management of promotional and marketing services, including the sending of commercial and marketing communications.
Some of the recipients of your personal data may be located outside the European Union (EU) / European Economic Area (EEA) in countries that do not guarantee an adequate level of protection of personal data on a par with that existing in the EU / EEA. In these cases, ASSA ABLOY will adopt adequate guarantees pursuant to art. 46 of the GDPR to ensure the protection of the personal data of data subjects during such international data transfers, such as the implementation of the Model Contractual Clauses adopted by decision of the European Commission, currently Decision 2010/87 / EU. For more information on the guarantees adopted by ASSA ABLOY for the international transfer of personal data, please contact us at the e-mail address privacy.it.openingsolutions@assaabloy.com.
5. Privacy rights
You can contact the Company at any time at the addresses indicated at the beginning of this Privacy Notice and at the email address privacy.it.openingsolutions@assaabloy.com to request the updated list of our data processors and exercise your privacy rights pursuant to articles. 15 ss. GDPR:
Right of access: You have the right to obtain from us confirmation of the existence or not of personal data concerning you and, if so, to request access to such personal data. The access information includes, among others, the purposes of the processing, the categories of personal data processed, the recipients or categories of recipients to whom the personal data have been or will be communicated, the sources of the personal data, the duration of storage. and the technical security measures adopted to safeguard personal data in case of transfer outside the EEA. However, this is not an absolute right and the interests of other people may limit the right of access. You can contact the Company at any time at the addresses indicated at the beginning of this Privacy Notice and at the email address privacy.it.openingsolutions@assaabloy.com to request the updated list of our data processors and exercise your privacy rights pursuant to Articles. 15 ss. GDPR:
Right of rectification: In certain circumstances, you have the right to obtain from us the rectification, i.e. the correction of inaccurate personal data concerning you and also the right to obtain the integration of incomplete personal data, also by providing a supplementary declaration.
Right to erasure: In certain circumstances, you have the right to obtain the erasure of your personal data. In such cases, we will take steps to erase, or permanently make unintelligible, such personal data.
Right to restriction of processing: In certain circumstances, you have the right to obtain from us the restriction of the processing of your personal data. In this case, the data will be marked and may only be processed by us for certain purposes.
Right to object to processing: In certain circumstances, you have the right to object, at any time, for reasons related to your particular situation, to the processing of your personal data by us and we may be required to refrain from processing your data personal data, as in the case of the processing of personal data for direct marketing purposes, including profiling if it is connected to this purpose. If you exercise this right, your personal data will no longer be processed by ASSA ABLOY for the purposes referred to in this Privacy Notice unless the Company demonstrates compelling legitimate reasons pursuant to the GDPR to continue processing (eg fulfillment of a legal obligation and / or the ascertainment, exercise or defense of a right in court).
Right to data portability: in certain circumstances, you have the right to receive the personal data concerning you and that you have provided to us in a structured, commonly used and machine-readable format and the right to transmit such data to another entity .
Automated decision making: You have the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you unless, such decision:
- is authorized by Union or Member State law to which ASSA ABLOY is subject
- is necessary for the conclusion or performance of a contract between you and ASSA ABLOY;
- is based on your explicit consent.
In the latter two cases, you will still have the right to obtain human intervention from ASSA ABLOY as well as to express your opinion and contest the decision.
Furthermore, you have the right to lodge a complaint with the competent supervisory authority which in which in Italy is the Garante per la Protezione dei Dati Personali (hereinafter the "Garante”).
Please take into consideration that in certain cases provided for in art. 2-undecies of the Privacy Code, the exercise of the aforementioned privacy rights could be limited, delayed or excluded. In such circumstances, ASSA ABLOY will promptly provide you with a reasoned communication in relation to the aforementioned limitation, delay or exclusion. In any case, you can contact the Garante in order to request a verification that the limitation, delay or exclusion of the exercise of your privacy rights are based on legitimate reasons.
In any case, you have the right to revoke your consent, possibly given for one of the purposes of the processing indicated in this information, by sending an e-mail to the address: privacy.it.openingsolutions@assaabloy.com for the attention of: ASSA ABLOY, the Data Protection Manager, or where relevant by accessing the area reserved for you on the "My Profile" website, changing your consent preferences. The withdrawal of consent does not affect the lawfulness of the processing based on consent before the withdrawal.
For more detailed information on how ASSA ABLOY processes the personal information collected in relation to any requests relating to the management of your personal data, consult the Privacy Policy - Request for Access to Personal Data.
6. How can we make changes to this privacy statement?
We may update this privacy policy from time to time in response to changing legal, regulatory or operational requirements. We will notify you of such changes (including when they take effect). As for the continued use of the website after such updates, it will constitute acceptance of these changes. If you do not accept updates to this privacy policy, you should stop using our website.
7. Information
For more information on your rights, you can contact us by e-mail at privacy.it.openingsolutions@assaabloy.com for the attention of: ASSA ABLOY, the Data Protection Manager.