PURPOSE AND LEGAL BASIS OF PROCESSING
Personal data are processed, both manually and electronically, for the following purposes:

• to send you a quotation, in case of contact through the forms at https://www.multiwarm.it/ and https://www.multiwarm.it/richiedi-preventivo/
• to handle your complaint, in case of contact through the form at https://www.multiwarm.it/contatti-e-supporto/

The legal basis for processing is the pre-contractual or contractual relationship.
Providing your data is necessary to achieve the purposes listed above.

With your consent, your data may also be processed for:

• sending commercial, promotional, or advertising information about our products and services via email, SMS, postal mail, or phone call. The legal basis for this processing is your explicit consent.
• sharing your data with other companies in the Termal Group, which may independently send commercial, promotional, or advertising information using the contact methods you provided. The legal basis is your explicit consent.

You may withdraw your consent at any time by writing to privacy@hokkaido.it.
Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

The Controller does not collect special categories of personal data as defined by the Regulation, nor information about your browsing behavior.

DATA COMMUNICATION
Data resulting from the use of the website may be disclosed to:
• entities responsible for managing the website
• technological and instrumental partners used by the Controller to provide the requested services
• public bodies or authorities legally entitled to access the data

Personal data provided by users who submit information requests or other communications are used only to perform the requested service.
They are disclosed to third parties only when necessary for that purpose.

Data are generally not transferred outside the European Union.
If a transfer outside the EU becomes necessary, it will occur only:
• to recipients that ensure an adequate level of protection,
• to countries recognized as adequate by the competent Authorities, or
• to entities offering appropriate safeguards through legal and contractual instruments such as Standard Contractual Clauses.

TYPES OF DATA PROCESSED
Browsing data
The IT systems and software procedures that enable this website to function collect certain personal data during normal operation.
Transmission of such data is implicit in the use of Internet communication protocols.

These data are not collected to be associated with identified users, but, by their nature, they could allow user identification through processing and association with data held by third parties.

This category includes:
• IP addresses or domain names of computers used by users connecting to the site
• URI (Uniform Resource Identifier) addresses of requested resources
• time of the request
• method used to submit the request to the server
• size of the file obtained in response
• numerical code indicating the status of the response (success, error, etc.)
• other parameters related to the user’s operating system and IT environment

These data are used only to obtain anonymous statistical information on website usage and to check its proper functioning.
They are deleted immediately after processing.
Data could be used to determine liability in case of potential cybercrimes against the site.

Data voluntarily provided by the user
The voluntary, explicit submission of emails to the addresses indicated on this website involves the acquisition of the sender’s personal data, required for operational, administrative, accounting, or logistical purposes, or to respond to specific requests.

OPTIONAL NATURE OF DATA PROVISION
Except for browsing data, users are free to provide personal information when requesting the company’s services.
Failure to provide such data may make it impossible to obtain the requested service.

DATA PROCESSING METHODS
Personal data are mainly processed through automated systems.
They are stored using appropriate and preventive security measures designed to minimize the risk of destruction or loss, even accidental, of the data, as well as unauthorized access or processing that is unlawful or inconsistent with the stated purposes.

DATA RETENTION PERIOD
Data will be stored only for the time necessary to achieve the purposes for which they were collected, unless different legal obligations apply.
After this period, personal data will be deleted or anonymized.
Personal data will be retained for 24 months from your request or from the last relevant contact.

MINORS
No personal data should be entered on the website by minors without the prior consent of their parents or guardians.
The Controller encourages all parents and guardians to teach minors how to use their personal data online safely and responsibly.

The Controller undertakes not to knowingly store or use any personal data collected from minors for any purpose, including disclosure to third parties.

LINKS TO OTHER WEBSITES
This website may contain hyperlinks to other websites, provided to offer a better service to users.
The Controller is not responsible for the content of any external websites accessed through its own site.

The presence of a hyperlink to another website does not imply approval or acceptance of responsibility by the Controller regarding the content of that site, including its data protection policy or how it handles user information.

RIGHTS OF DATA SUBJECTS
With regard to the processing of personal data, you may contact the Controller by writing to privacy@hokkaido.it to exercise your rights under the Regulation.

Specifically, you have the right to:
• Access your personal data, obtaining details on the purposes of processing, categories of data, recipients, retention period, and the existence of automated decision-making processes, including profiling, as well as meaningful information on the logic involved and potential consequences, where not already described in this Privacy Notice.
• Request the rectification of inaccurate personal data without undue delay.
• Request the erasure of your data in cases provided by law.
• Request restriction of processing or object to it, where permitted by applicable law.

If you believe your rights have been violated, you may lodge a complaint with the competent supervisory authority.

COOKIE POLICY
This website uses cookies and similar technologies to ensure proper functioning and improve the user experience of online applications.
A cookie is a text file stored on a computer’s hard drive.
Cookies help analyze web traffic, signal when a specific website is visited, and allow web applications to send information to individual users.

Below is detailed information about the use of cookies and similar technologies, how they are used by the Controller, and how to manage them.
This website uses both session cookies and persistent cookies.

• Session cookies track browsing data, such as visited pages or selected options. They are deleted when the browser is closed.
• Persistent cookies allow the website to recognize the user on subsequent visits.

On this site, the Controller may use the following types of cookies:

TECHNICAL COOKIES – Necessary
These cookies are essential for website navigation and ensure secure and efficient browsing.
This category includes both persistent and session cookies.

Without these cookies, the website or some parts of it may not function properly.
They are therefore always used, regardless of user preferences.

Their duration is limited to the browsing session or may extend longer to remember user choices.
Disabling strictly necessary cookies may affect the browsing and usability of the website.

ANALYTICAL COOKIES – Preferences and statistics
These cookies are used to collect and analyze website traffic and user behavior.
They include first-party or third-party cookies used to monitor the system and improve website performance (performance cookies).

Preference cookies allow the website to remember information that affects its behavior or appearance, such as your preferred language or location.

Statistical cookies help website owners understand how visitors interact with the site by collecting and transmitting information anonymously.

These cookies are installed only with the user’s consent.
Disabling them does not affect website functionality.

MARKETING COOKIES
These cookies are used to track user browsing and create profiles based on their interests, habits, and choices.
They allow the delivery of advertising messages aligned with the user’s preferences expressed during online navigation.

These cookies are installed only with the user’s consent.
Without consent, marketing cookies are blocked, limiting advertising personalization but not the overall functionality of the website.

LIST OF COOKIES USED ON THIS WEBSITE
A detailed list of the cookies used on this website is provided in the banner, where users can indicate which categories of cookies, besides technical ones, may be installed.

TOTAL OR PARTIAL DISABLING OF COOKIES
Disabling all or part of the technical cookies may affect the use of website functionalities.

Disabling third-party, analytical, or profiling cookies does not affect website navigation.

You can set your cookie preferences by clicking on the initial banner or the icon.

Settings can be defined separately for different websites and web applications.
Most browsers allow different settings for first-party and third-party cookies.

Below are instructions for disabling cookies in some common browsers:

Edge

1. Open Microsoft Edge

2. Go to Settings and more > Settings > Privacy, search, and services

3. Under Clear browsing data, select Choose what to clear

4. Select a time range

5. Select “Cookies and other site data” and click Clear now

Chrome

1. Click the Chrome menu icon

2. Go to Settings

3. In “Privacy and security,” click Cookies and other site data

4. Click See all cookies and site data, then Remove All

5. Confirm by clicking Clear All

Firefox

1. Click the menu button and select Options

2. Go to Privacy & Security

3. Under Enhanced Tracking Protection, select Custom and check the Cookies box

4. Use the drop-down menu to choose the types of cookies to block

5. Close the “about:preferences” page; changes are saved automatically

Internet Explorer

1. Click the Tools button and select Internet Options

2. Go to the Privacy tab, select Advanced, and choose whether to accept, block, or be prompted for first-party or third-party cookies

Safari

1. Go to the Safari menu (top right of the browser) and select Preferences

2. In the pop-up window, select the Security icon (lock)

3. Under “Accept cookies,” select “Never”

SOCIAL MEDIA POLICY
The Controller uses certain social media platforms to promote company events and services, collect comments and feedback on user experience, and respond to information requests.

The following social profiles and instant messaging services are used:

• LinkedIn
  Social profiles are managed by the Controller’s collaborators appointed as Authorized Persons for processing and/or Data Processors under Article 28 of EU Regulation 2016/679.
  User personal data are processed according to the policies of the platforms used.
  Personal or sensitive data included in comments or public posts on social channels may be removed.
  Data shared by users via private messages sent directly to channel managers will be processed in compliance with applicable data protection laws and this privacy policy.