Privacy Policy


With specific reference to your personal data as defined under Article 4(1)(1) of Regulation (EU) 2016/679 (“General Data Protection Regulation – GDPR”) in your capacity as “Data Subject”, the enterprise, THD S.p.A., (VAT and  Tax Identification Number 02111430357), acting through its pro temporelegal representative, based in Correggio (RE), via Industria 1 ITALY, in its capacity as “Controller” under Article 4(1)(7) of the GDPR, hereby provides you with this notice to inform you of its privacy policy and so you can understand how it manages your personal data when you use its services on“Website”).


1.1. The Personal Data collected via the website are exclusively browsing data. Browsing data is personal data whose transmission is implicit in the use of internet communication protocols. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning.


2.1. The “Controller” of the processing of your personal data, as specified in Article 4(1)(7) of the GDPR is the enterprise, THD S.p.A ., (VAT and Tax Identification Number 02111430357), acting through its pro temporelegal representative, based in Correggio (RE), via Industria 1 – ITALY; you can contact the Controller by email at

2.2. The “Data Protection Officer”, as specified in Article 37 of the GDPR is the lawyer Sara Mandelli of BALDI & PARTNERS, who can be contacted by email at

2.3. Please note that any changes or updates to the data of the above specified Data Protection Officer will be duly published on the website of the undersigned Controller


3.1. In accordance with Article 5(1)(b) of the GDPR, we hereby inform you that the Controller will process your personal data collected via the Website to: a)improve the use of this Site ; b) allow browsing on this Website.


According to the purposes specified in paragraph 3 above, the Controller processes your Personal Data according to the following legal basis:

4.1 Provision of Service: processing for this purpose is necessary to be able to deliver the Services you request and, therefore,service provided by   this site. You are not required to give your Personal Data to the Controller for this purpose, but failure to do so means we will not be able to provide you with the Service.


5.1 In order to pursue any of the purposes described in paragraph 3 above, the Controller will disclose your Personal Data to its collaborators, who will act as persons authorized to process personal data.

Furthermore, for the purposes described in paragraph 3 above, your Personal Data will be processed by third parties belonging, by way of example, to the following categories:

a) entities providing IT system management services, including server hosting and backup services;

b) entities that provide the Controller with tax, legal, judicial and compliance advice;

The entities listed above operate, in some cases, independently as separate data controllers, and in other cases, as data processors specifically appointed by the Data Controller in accordance with Article 28 of the GDPR.

Disclosure of your data to the above categories does not require your consent, as it is based on the legitimate overriding interest of the Data Controller, given that such disclosure is necessary for the purposes mentioned in paragraph 3 above.

You can ask the Controller for the complete, updated list of the entities to which your Personal Data may be disclosed.

The personal data processed by the Controller are not disclosed.

5.2 Transferring personal data outside the European Union

THD S.p.A . does not intend to transfer your personal data to any non-EU countries.


6.1 The Controller will store Personal Data collected for the purposes  specified in paragraph 3 above for as long as strictly necessary to provide the services requested.


7.1 Your data will be processed in both paper form and/or using electronic and/or computerized and/or telecommunications media and instruments; the logic involved and the procedures used are strictly connected to the purposes specified and, in any case, adopting methods that ensure the security and confidentiality of the data in compliance with the provisions of Article 32 of the GDPR.


8.1. With regard to your Personal Data that are processed by the Controller THD S.p.A.  We hereby inform you that you are entitled to exercise the following rights under Articles 15 to 21 of the GDPR and, in particular:

  • Right of access– Article 15 of the GDPR: the right to obtain from the Controller confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data – including a copy of them – and the following information:
    1. the purposes of the processing
    2. the categories of personal data processed
    3. the recipients to whom the personal data have been or will be disclosed
    4. the envisaged period for which the personal data will be stored or the criteria applied
    5. the existence of the Data Subject’s right to request from the controller rectification or erasure of personal data or restriction of processing
    6. the right to lodge a complaint
    7. where your personal data are not collected from you, any available information as to their source
    8. the existence of automated decision-making, including profiling;
  • right to rectification – Article 16 of the GDPR: the right to obtain without undue delay the rectification of inaccurate personal data concerning you and the right to have incomplete personal data completed;
  • right to erasure(‘right to be forgotten’) – Article 17 of the GDPR: the right to obtain the erasure of personal data concerning you without undue delay, where one of the following grounds applies:
  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • you withdrew your consent and there is no other legal ground for the processing;
  • you successfully objected to the processing of your personal data;
  • your personal data have been unlawfully processed;
  • your personal data have to be erased for compliance with a legal obligation;
  • your personal data were collected in relation to the offer of services referred to in Article 8(1) of the GDPR.

The right to erasure shall not apply to the extent that processing is necessary for compliance with a legal obligation or for the performance of a task carried out in the public interest or for the establishment, exercise or defense of legal claims.

  • right to restriction of processing– Article 18 of the GDPR: the right to obtain restriction of processing where one of the following applies:
  • the accuracy of the personal data is contested by the data subject;
  • the processing is unlawful and the Data Subject opposes the erasure of the personal data and requests the restriction of their use instead;
  • the personal data are required by the data subject for the establishment, exercise or defense of legal claims;right to object– Article 21 of the GDPR: the right to object to the processing of your personal data unless the controller demonstrates compelling legitimate grounds for the processing;
  • right to data portability– Article 20 of the GDPR:  the right to receive the personal data concerning you, which you have provided to the Controller, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance, where the processing is based on consent and the processing is carried out by automated means.  In exercising your right to data portability, you also have the right to have the personal data transmitted directly from the Controller to another, where technically feasible;
  • right to lodge a complaint with the Italian Data Protection Authority (Garante), Piazza Venezia 11 , 00187 Rome (RM).

8.2. In accordance with Article 12(1) of the GDPR, THD S.p.A .  undertakes to provide the communication under Articles 15 to 22 of the GDPR in a concise, transparent, intelligible and easily accessible form. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. When requested by the data subject, the information may be provided orally, provided that the identity of the data subject is proven by other means.

8.3. In accordance with Article 12(3) of the GDPR, the Controller informs you that it undertakes to provide information on action taken on a request under Articles 15 to 22 to you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

8.4. If you, the Data Subject want to exercise your rights as specified in more detail in this Article, you can use the contact information specified in Article 2 of this “Notice”.

THD S.p.A.

(In its capacity as Data Controller)