Circular letter on personal data processing performed by the website: pursuant to art. 13 of the European General Data Protection (GDPR – 2016/679)


Oleodinamica Borelli di Borelli Claudio, as data controller, give to data subjects the following information on personal data processing.

This circular letter is referred to and is valid only for this website ( and not for other websites surfed by the user through links available in The data controller isn’t responsible of processing done by third part websites. Please take a look to data processing policy when you visit a third part website.



The data controller is Oleodinamica Borelli di Borelli Claudio, VAT number: IT00094250354 and established in Via Galvani 2, 42011 Bagnolo In Piano (RE) – Italy. You can contact the data controller by the following mail address:



We process personal data only when a legal basis, established by law, is available. In the following list you can found all the information concerning the purposes of processing, types of personal data processed, the legal basis and retention time.


Purposes of processing Types of personal data Legal Basis Retention time
Browsing on the website – to guarantee the proper funcionality and cybersecurity of both the website and other users. Surfing data Legitimate interests pursued by the controller to promote his own business through the websites and to defend users and website against possible cyber attacks Data controller will keep the surfing data for the time strictly necessary reach the processing purposes. For what concern cookies retention time, more information are available consulting the website’s Cookie Policy.
To manage commercial and information requests received through the contact forms or other communication channels available on the website; Identification data

Data concerning contact details and postal address

Legitimate interest of Data Controller consisting in the management of communication with data subjects to satisfy specific forwarded requests

To the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

This data will be processed for the time strictly necessary to manage your request.

After this process, this data would be deleted or processed for other purpose (ex. to manage the service provision).

User’s registration to the website Identification data

Data concerning contact details and postal address

Other necessary data requested in registration form.

To the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; The data controller will keep this personal data until account cancellation.
To send newsletter and other commercial communications following the registration of the user through the newsletter form. Data concerning contact details and postal address Explicit consent of data subjects Your e-mail address will be kept until the revocation of your consent, by sending an unsubscribing request to our adress or clicking the unsubscription link when available in our communications.

After yout subscription request the sending of newsletter will be interrupted.

To carry out promotional activities, send advertising material and complete market researches directly with the user; Identification data

Data concerning contact details and postal address

Surfing data

Explicit consent of data subjects We will process your data for marketing purposes until your consent revocation.



Surfing data: The computer systems and software procedures responsible for the functioning of this website acquire, during their normal operation, some personal data, the transmission of which is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified Data Subjects, but by their very nature could allow users to be identified through processing and association with data held by third parties.

This category of data includes:

  • IP addresses or domain names of computers utilized by users connecting to the site;
  • the URI (Uniform Resource Identifier) addresses of the requested resources;
  • the time of request;
  • the method used in submitting the request to the server;
  • the size of file obtained in response;
  • the numeric code indicating the status of response given by the server (good result, error, etc.),
  • other parameters relating to the operating system and the user’s IT environment.

This data is used only to obtain anonymous statistical information on the use of the site and to check its correct functioning, and is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes that damage the site.

The site could also automatically process data through sending of cookies to the user. Cookies are small strings of text sent during consultation on the website and, based on their purpose and the value assumed, they allow the site and/or third parties to collect information related to the user. The use of this electronic tool is analytically described through the Cookie Policy of the website.

Personal data sent by the user: The optional, explicit and voluntary sending of data to this site entails the subsequent acquisition of contact details of the sender concerned, which is necessary to respond to requests as well as any other personal data sent spontaneously by the latter.

Here below are the methods used by the website to collect personal data and not through third-party users.

  1. Contact form: Through the contact form present on the website, the user is required to provide personal identification data and contact details as well as other information that may be specifically requested by the Data Subject. Data is entered and sent spontaneously by the user who wishes to be contacted by the site owner, as well as the Data Controller, to receive information related to specific requests. Data collected will be exclusively used to respond to requests forwarded and will be processed further only if a business relationship is established between the user and Data Controller
  2. Registration and login to reserved area: The personal information entered in the registration form of the reserved area is necessary to create the personal profile in order to gain access to it. Data is entered and sent spontaneously by the user who wishes to access said area. All data sent and collected through the reserved area will be utilized to respond to specific requests of the registered user (e.g. for recovery of access credentials, information on Data Controller’s activity, management of the business relationship, etc.), as well as to facilitate subsequent business relationships with the Data Subject. Registration is eventually required for the use of E-Commerce-related functions found on the site.
  3. Newsletter and data processing pursuing marketing purposes: Through newsletter service or any other eventual channels used by the Data Controller (social channels, messaging services …), the site carries out promotional business activities to users and customers by sending e-mails or other electronic communications containing commercial and marketing information. Processing will be undertaken in compliance with and within the ethical limits and regulations without causing damage to the rights and freedom of the Data Subjects. For the purpose of providing newsletter service or other direct and indirect marketing activities, data communication is subject to the prior consent of the Data Subject if the email address or other details are collected through the site where, in order to forward the data to the system, it is necessary to tick the option with which express consent is given for such purpose. In the formula for gathering consent, it is possible to navigate to this document thanks to the reference to this Extended Information on data processing



Your personal data may be transmitted only to third party qualified data controller as police, public authorities, supervisory bodies and other public and private subjects who have the faculty to process personal data. This third subject may be:

  • Companies which provide IT system and website management services (as e-commerce and secure payment infrastructure, web development consultants, etc.);
  • Companies and professional offices which provide business assistance and consultancy (IT technologies, accounting, etc.);
  • Companies which provide technical or consultancy services concerning market research, marketing and business promotion;
  • Public institutions for the fulfillment of legal obligations related to commercial relationship, and so far as crime or cyber-attacks to our systems or to other website visitors be detected or to manage the litigations.

More information related to the subjects who may process your personal data are available by contacting the data controller.



The communication of your personal data is mandatory when the processing is necessary to browse on the website, to carry out commercial and information requests received through the contact forms, to provide the services or to perform the contract with customers. If this personal data wouldn’t be transmitted it will be impossible to carry out data subject’s requests.

In the other cases the transmission of data it’s optional and, when necessary, dependent to data subject’s explicit consent.



You are informed of the existence of your right to request access to your personal data, rectify and cancel the same, restrict the processing of data concerning yourself, object to their processing, data portability (Articles 15 to 22 of the EU Regulations 2016/679 GDPR);

You can exercise your rights and know the third parties to whom data may be communicated by writing to the e-mail address:

If the data processing has his foundation on your explicit consent (art. 6, § 1, lect. a), you have the right to revoke this consent whenever you want, without to prejudice the lawfulness of previous processing activities.

You are entitled to file your complaints with the control authority at the Supervisory Authority address for the protection of personal data, by sending a certified e-mail to the address, or with the control authority of another EU member country.

This circular letter was updated on 20/07/2020.