Privacy Policy

INFORMATION ON THE PROCESSING OF PERSONAL DATA pursuant to Article 13, Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR)

I. Delta Pictures S.r.l., the protection of privacy and the processing of personal data

Delta Pictures S.r.l., headquartered in via G. Boglietti 2 (13900) Biella (VAT IT02154000026), share capital Euro 50,000.00 i.v. (hereinafter also just Delta) pays deep attention to the issues of protection of personal data processed, not only because they are subject to specific legislation, but especially because the safeguard of data is a cardinal principle of Delta.

Personal data are critical to our Society and include those to be provided by users on the sites listed here.

These are the reasons why we constantly strive to provide our users with a web experience that fully respects and protects the processing of personal data.

This information refers to this website operated by Delta Pictures S.r.l. as the Data Controller also in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (hereinafter only GDPR).

II. Principles

The privacy policy and standards used by Delta to protect personal data are based on the following principles:

Principle of accountability. The processing of personal data is managed over time by appropriate responsibilities identified within the corporate organization.

Principle of transparency. Personal data are collected and subsequently processed according to the principles expressed in Delta’s adopted privacy policy and stated in this privacy policy.

Principle of collection relevance. Personal data are processed lawfully and fairly; are recorded for specified, explicit and legitimate purposes; are relevant and not excessive for the purposes of processing; and are kept for as long as necessary for the purposes of collection.

Principle of purpose of use. The purposes of personal data processing are made known to the data subjects at the time of collection. Any new data processing, if unrelated to the stated purposes, is activated after new information to the data subject and possible request for consent, when required by the GDPR.

Principle of safety. Personal data are protected by technical, computer, organizational, logistical and procedural security measures against the risks of destruction or loss, even accidental, and unauthorized access or unauthorized processing.

These measures are updated periodically according to technical progress, the nature of the data and the specific characteristics of the processing, constantly monitored and verified over time.

Third parties performing support activities of any kind for the provision of services by Delta companies in relation to which they perform personal data processing operations are designated by the latter as Data Processors, pursuant to Article 28.4 of the GDPR, and are contractually bound to comply with measures for the security and confidentiality of processing.

Third-party sites that can be accessed through this website are not covered by this policy. Delta disclaims any responsibility for them. The categories of cookies used and the type of processing of personal data by these companies are regulated in accordance with the policy made by these companies.

Delta also assumes no responsibility for:

the rules and methods of handling personal data of other Web sites, which can be reached from our pages through links and cross-references;
The contents of any e-mail services, Web spaces, chat forums provided to users.

III. General scope of communication of personal data

The personal data provided may be communicated to third parties to fulfill legal obligations, in execution of orders from public authorities legitimized to do so, or even to assert or defend a right in court.

Data may be disclosed:

to all those entities (including Public Authorities) that have access to personal data by virtue of regulatory or administrative measures;

to companies, consultants or professionals that may be entrusted with the installation, maintenance, updating and, in general, the management of Delta’s hardware and software or which it uses for the provision of its services;to employees and/or collaborators of Delta;

to all those public and/or private entities, individuals and/or legal entities (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Offices of Labor, etc.), if the communication is necessary or functional for the proper fulfillment of the contractual obligations undertaken, as well as the obligations arising from the law;
to companies that send newsletters and/or other informational communications transmitted on Delta’s behalf (CRM platforms).

IV. Data processing for support and customer care purposes

Delta will process user data for general customer care and support activities and thus to respond to requests for information from users or to respond to complaints and reports.

The legal basis for this processing is Delta’s legitimate interest in responding to users’ requests for information (Art. 6.1.f of the GDPR).

This legitimate interest of Delta also coincides with the legitimate interest of the users themselves who make the requests and who, therefore, as part of their relationship with Delta, can be reasonably expected to expect that their personal data will be used by Delta to provide them with feedback.

Providing user data for support and customer care purposes is optional; refusal will result in Delta being unable to respond to requests for information from users or to respond to complaints and reports.

V. Data processing for profiled marketing purposes

Subject to your express consent, Delta will process your personal information to send you, via e-mail, informational and promotional communications, including newsletters, referring to Delta or third-party services and/or products of specific interest to you.

The legal basis for this processing is the express consent of the user (Art. 6.1.a) of the GDPR).

The sending of “profiled” communications may be based on (i) the interests and/or consumption habits expressed by the user when browsing Delta’s sites or other Internet sites; (ii) the answers made by the user to questions, surveys or questionnaires presented on Delta’s sites.

You may revoke your consent given and/or object, at any time, to the processing of your data for profiled marketing purposes by contacting Delta or the DPO at the contact details given in Section XI, or by exercising the options in each marketing email sent by Delta.

Providing data for the purpose of profiled marketing is optional: there is no legal or contractual obligation on you to provide such data for this purpose and/or to consent to the processing of your personal data for this purpose.

Failure to consent to the processing of data for profiled marketing purposes will result in the inability for the user to receive advertising material related to the services offered by Delta and/or third parties as well as the inability for Delta Pictures to send newsletters to the user of his/her specific interest.

VI. Data processing for disposal purposes

Subject to the user’s express consent, Delta will process the user’s personal information to transfer it to Delta’s partner companies. These partner companies will act as autonomous data controllers to send you promotional communications and/or newsletters referring to their products and/or services via email.

The legal basis for this processing is the express consent of the user (Art. 6.1.a) of the GDPR).

You may revoke your consent at any time and/or object, at any time, to the processing of your data for purposes of transfer to third parties by contacting Delta the DPO at the contact details given in Article XI, or by exercising the options in each marketing email sent by Delta Pictures or the partner company to which your personal data has been transferred. Revocation of consent does not extend to communications sent prior to such revocation.

Providing data for the purpose of transfer is optional: there is no legal or contractual obligation on you to provide such data for this purpose and/or to consent to the processing of your personal data for this purpose.

Failure to consent to the processing of data for the purpose of divestment will result in your inability to receive promotional communications and/or newsletters regarding products and/or services of Delta’s partner companies.

VII. Sensitive/judicial data

Delta Pictures does not process sensitive or judicial data.

VIII. Security measures adopted for the protection of collected data and processing methods

The protections activated against personal data aim, in particular, to minimize the risks of destruction or loss, even accidental, of data, unauthorized access or processing that is not permitted or does not conform to the purposes of collection. Periodic “Risk Analysis” activities are conducted to verify adherence to the defined standards and, if necessary, to adopt new security measures as a result of organizational changes and technological innovations or changes in the type of data collected. Security measures are constantly monitored and periodically audited.

The processing of the user’s personal data will be mainly carried out with the help of electronic or otherwise automated means, in the manner and with the appropriate tools to ensure their security and confidentiality in accordance with the GDPR.

The information acquired and the manner of processing will be relevant and not excessive in relation to the type of services rendered. Data will also be managed and protected in environments whose access is under constant control.

IX. Retention of personal data

Personal data will be stored according to the following logics:

for profiled marketing purposes, until consent is revoked, if any. Any personal data provided by the user for profiled marketing purposes will be retained for five years from the date of the last interaction, of which there is evidence, with the email sent for profiled marketing purposes (e.g., click and open), unless consent is revoked previously. At the end of the aforementioned retention period, there is a possibility that Delta will contact you in order to ask you whether you wish to continue to receive marketing communications from Delta, in the absence of a positive and explicit response from you, your personal data about you will be deleted or archived in accordance with applicable law;
for purposes of defense in court, until the judgment becomes final;
For purposes of complying with regulations, for as long as necessary for this purpose;
for the purpose of performing any requested service, for the time necessary to execute the request;
for customer care purposes, the data will be deleted once the customer care service is completed and, in any case, within a maximum period of three months after the last email exchange with the data subject.

X. Transfer of personal data to third countries

Delta is based within the European Union. Therefore, the processing of user data is safe from a regulatory perspective as it is governed by the GDPR.

If the transfer of the user’s personal data takes place to a country outside the EU and for which the European Commission has issued an adequacy opinion, the transfer is deemed to be safe from a regulatory point of view in any case. This article indicates from time to time the countries to which your personal data may possibly be transferred and where the European Commission has issued an adequacy finding.

Delta may transfer your personal data to the United Kingdom. In fact, the European Commission ruled in its decision of June 28, 2021, that the UK offers an adequate level of personal data protection under the GDPR.

Your personal data may be transferred to the U.S. under the terms of the European Commission’s adequacy decision. With this decision, the European Commission has decided that the U.S. offers personal data protection comparable to that offered by the European Union.

User data may also be transferred to countries outside the EU and for which the European Commission has not issued an adequacy finding.

Therefore, you are invited to regularly access this article to check whether the transfer of your personal data takes place in third countries.

XI. Data Controller

Delta, as the Data Controller, can be contacted at the following numbers:

Address: Delta Pictures S.r.l., with registered office at Via G. Boglietti 2 (13900) Biella.

Phone: (+39)015.247.16.79.

Email: [email protected].

Or by accessing the contact form on Delta’s sites.

Delta has also appointed a Data Protection Officer (DPO), who can be contacted by users of the Site to exercise their rights under the GDPR.

The contact of the DPO is as follows: [email protected].

XII. Rights of the data subject

Pursuant to Article 13 of the GDPR, Delta informs you that you have the right to:

to ask Delta or the DPO for access to and rectification or erasure of personal data or restriction of processing concerning you or to object to its processing, as well as the right to data portability;
revoke consent at any time without affecting the lawfulness of processing based on the consent given before revocation;
Propose a complaint to a supervisory authority (e.g., the Data Protection Authority).

The above rights may be exercised by a request addressed without formality to Delta or the DPO at the contacts listed in Article XI above.

In particular, Delta informs you that the right to portability means that you have the right to receive in a structured, commonly used, machine-readable format the personal data about you that you have provided to Delta, and you have the right to transmit such data to another data controller without hindrance from Delta.

XIII. Changes

Delta reserves the right to make changes to this policy at any time, giving appropriate publicity to users on Delta’s sites and ensuring in all cases an adequate and similar protection of personal data. In order to view any changes, the user is encouraged to consult this policy on a regular basis.