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1. Introduction

Pamasoft (hereinafter "we", "us" or "our") respects the privacy of users of its website pamasoft.com (the "Site"). This Privacy Policy describes how we collect, use, store and protect users' personal data in compliance with the General Data Protection Regulation (GDPR - EU Regulation 2016/679) and applicable Italian legislation.

2. Data Controller

The Data Controller of personal data is:

• Company Name: Elleffe sas
• VAT Number: 05657500483
• Address: Via E. Fermi, 75 - 51100 Pistoia, Italy
• Email: privacy@pamasoft.com
• PEC: pamasoft@pec.it

3. Types of Data Collected

We collect the following categories of personal data:

3.1 Voluntarily provided data

• Contact data: name, surname, email address, phone number, company name, job title
• Communication data: messages sent via contact form or email
• Professional data: information related to business sector, company size, technological needs

3.2 Automatically collected data

• Browsing data: IP address, browser type, operating system, pages visited, visit duration, referrer
• Cookies and similar technologies: data collected through technical and analytical cookies (see Cookie Policy)
• Analytical data: aggregated statistics on site usage via Google Analytics

4. Purposes and Legal Basis of Processing

Personal data is processed for the following purposes:

Purpose	Legal Basis
Response to contact requests and quotes	Performance of pre-contractual measures (Art. 6.1.b GDPR)
Sending newsletter and commercial communications	Data subject's consent (Art. 6.1.a GDPR)
Site management and maintenance	Legitimate interest (Art. 6.1.f GDPR)
Statistical analysis and service improvement	Legitimate interest (Art. 6.1.f GDPR)
Compliance with legal obligations	Legal obligation (Art. 6.1.c GDPR)

5. Processing Methods

Personal data is processed using manual, IT and telematic tools, with logic strictly related to the indicated purposes and, in any case, in a way that guarantees the security and confidentiality of the data itself. Processing is carried out through:

• Collection, recording and storage
• Organization, modification and selection
• Use, consultation and communication
• Deletion and destruction

6. Data Retention

Personal data is retained for the time strictly necessary to achieve the purposes for which it was collected:

• Contact data: until consent is withdrawn or for 24 months from last contact
• Browsing data: up to 26 months (Google Analytics)
• Contractual data: 10 years for tax and accounting compliance
• Marketing data: until consent is withdrawn

7. Data Recipients

Personal data may be communicated to:

• Authorized personnel: Pamasoft employees and collaborators specifically authorized for processing
• Data processors: IT service providers, hosting, email marketing, CRM (e.g. AWS, Google, Microsoft)
• Competent authorities: upon request for legal compliance
• Consultants: accountants, lawyers, legal auditors

Data will not be disseminated or transferred to third parties for commercial purposes without the explicit consent of the data subject.

8. Extra-EU Data Transfer

Some data may be transferred to countries outside the EU (e.g. USA) for the use of cloud services (AWS, Google Analytics). In such cases, we ensure that:

• Transfer takes place to countries deemed adequate by the European Commission
• Standard Contractual Clauses approved by the European Commission are applied
• Providers are certified according to recognized standards (e.g. Privacy Shield successors)

9. Data Subject Rights

In accordance with articles 15-22 of the GDPR, the data subject has the right to:

• Access (Art. 15): obtain confirmation of the existence of personal data and request a copy
• Rectification (Art. 16): correct inaccurate or incomplete data
• Erasure (Art. 17): request deletion of data (right to be forgotten)
• Restriction (Art. 18): restrict processing in specific circumstances
• Portability (Art. 20): receive data in structured format and transmit it to another controller
• Objection (Art. 21): object to processing for legitimate reasons
• Withdraw consent: withdraw consent at any time
• Complaint: lodge a complaint with the Data Protection Authority

How to exercise your rights

To exercise the rights listed above, the data subject may contact us at the following addresses:

• Email: privacy@pamasoft.com
• Postal mail: Elleffe sas - Via E. Fermi, 75 - 51100 Pistoia
• PEC: pamasoft@pec.it

We commit to responding to requests within 30 days of receipt.

10. Data Security

Pamasoft adopts appropriate technical and organizational measures to ensure an adequate level of security, including:

• SSL/TLS encryption for communications
• Firewall and intrusion detection systems
• Regular backups and disaster recovery
• Access control and authentication
• GDPR staff training
• Data breach management procedures

11. Cookies and Tracking Technologies

The Site uses technical and analytical cookies. For more information, see our Cookie Policy managed via Cookie Script.

12. Minors

The Site is not intended for minors under 16 years of age. We do not knowingly collect personal data from minors. If we become aware that we have collected data from minors without parental consent, we will proceed with immediate deletion.

13. Privacy Policy Changes

We reserve the right to modify this Privacy Policy at any time. Changes will be published on this page with indication of the last update date. We invite you to consult this page periodically to stay informed.

14. Contacts

For any questions or clarifications regarding this Privacy Policy, you can contact us:

• Email: privacy@pamasoft.com
• Phone: +39 012 345 6789
• Address: Via E. Fermi, 75 - 51100 Pistoia, Italy

15. Supervisory Authority

The competent supervisory authority in Italy is:

• Garante per la Protezione dei Dati Personali
• Piazza Venezia, 11 - 00187 Rome
• Email: garante@gpdp.it
• Website: www.garanteprivacy.it