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In order to offer personalized and non-personalized services, provided for by its website, THE PERFETTO.IT, as the Data Controller, must process some identification data necessary for the provision of the same.

In accordance with Art. 13 GDPR 679/2016 – "European Regulation on the protection of personal data" and in relation to personal data concerning you and that will be the subject of the processing, THE PERFECT REPLACEMENT. guarantees, within the framework of the regulatory provisions, that the processing of personal data takes place in compliance with fundamental rights and freedoms, as well as the dignity of the data subject with particular reference to confidentiality, personal identity, right and protection of personal data themselves.

This document describes the methods of management of the site with reference to the processing of the personal data of those who interact with the services provided: the information is made pursuant to the European Regulation on the protection of personal data" 679/2016 (hereafter GDPR) only for the site in question and not also for other sites that may be available to the user through links, for which the perfect replacement is not in any way responsible.

This information is therefore drafted and personalized for visitors to the site and this document cancels and replaces in full any other document that had previously been published on web privacy and cookies.

Specific information

Additional and contextual information specifications can be found on the pages of the site, prepared for particular on-demand services that provide forms for data collection.


Personal data can be collected automatically while browsing and using the site and the services provided for in it or can be entered voluntarily by the user.

Among the personal data collected by the Data Controller independently or through third parties, there may be, but not limited to: cookies, usage data, password, first name, surname and email.

Navigation data and other data

The it systems and software procedures responsible for the operation of this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected to be associated with identified data subjects, but which by their very nature could, through processing and associations with data held by third parties, allow users to be identified. This data category includes the IP addresses or domain names of the computers used by users connecting to the site, the Uniform Resource Identifier (URI) notation addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (successful). , error, ...) and other parameters related to the user's operating system and IT environment. This data is used for the purpose of obtaining anonymous statistical information about the use of the site and to check its proper functioning and is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site at the request of the competent authorities.

The possible use of cookies - or other tracking tools - by this site or by the owners of the third-party services possibly used by it, unless otherwise specified, has the purpose of identifying the user and registering the relative preferences for purposes strictly related to the provision of the service requested by the user himself.

Failure by the user to provide some personal data may prevent the site from providing its services.

Personal data voluntarily provided by you

At different points of this site the user has the possibility to transmit his personal data (e.g. e-mail address, name, ZIP code, other personal and non-personal data) also through the compilation of forms or the sending of e-mail messages. The provision of this data takes place on an optional, explicit and voluntary basis, and involves the subsequent acquisition of the sender's email address, necessary to respond to requests, as well as any other personal data entered for the purposes of the service and those further granted by the user. Specific summary information can be found on the pages that provide the forms, with the possible indication of the mandatory provision of the data necessary to take advantage of the specific service.

The user assumes responsibility for the personal data of third parties that may be published or shared through this site and guarantees that he has the right to communicate or disseminate them, freeing the Data Controller from any responsibility to third parties.


Personal data are processed, as best highlighted in the next paragraph, exclusively for purposes related to the perfect replacement activity and the obligations related to it; the legal bases can be found in the consent (e.g. for the processing of the "particular categories of personal data" or for marketing/profiling) and/or in the execution of a contract or service of our management of which the user is a party or in the execution of pre-contractual measures taken at the user's request and/or in fulfilling legal obligations to which the owner is subject and/or in the legitimate interest of the same.


The user's data is collected and processed for the following purposes:

  1. carrying out operations closely connected and instrumental to the management of relationships with users or visitors to the site, such as:

    • navigation;

    • registration and authentication;

    • consultation and/or discharge of any data and information stored in the area dedicated to the user;

  2. collection, storage and processing of user data to:

    • statistical analysis also anonymously and/or aggregated;

Further processing purposes could be put in place, subject to explicit consent, when necessary, in relation to the services that can be activated within the site and among these include, but not limited to: interaction with social networks and external platforms, social applications, payment management, interaction with support and feedback platforms, infrastructure monitoring, optimization and distribution of traffic , interaction with live chat, remarketing and behavioral targeting platforms, address management and sending of email messages, display of content from external platforms, commercial affiliation, heat mapping, management of user databases and management of support and contact requests.


The provision of data is optional, except for those indicated as mandatory to allow the user to access the services offered.

The processing of data for the performance of the purpose, referred to in point 1 of the previous paragraph, is mandatory and any non-communication, or incorrect communication, of any of the information may limit and/or prevent the full use of the features and services on the site.

With regard to the optional provision, more information is made regarding cookies on the site in the document "Cookies Policy" accessible both from this complete information and from the short information contained in the banner published on the site.

In addition, only with the express consent of the user the data may be used to make communications for market surveys or commercial information on the products and promotional initiatives of the Data Controller through postal mailing, e-mail, telemarketing, sms, mms.

At any time it will be possible to reread the information and possibly modify the consents previously provided, verify and/or change the status of the active services and possibly request additional services.


The processing of personal data can be carried out with or without the help of electronic and in any case automated means, also associating and integrating them with other databases, and also through cookies. In any case, the processing will be carried out in compliance with any precautionary measure, which guarantees its security and confidentiality, for the time necessary to carry out the service requested by the user, or required by the purposes described in this document, and the user can always request the interruption of the processing or the deletion of the data.

The perfect replacement has also prepared all cybersecurity measures, in compliance with the procedures indicated in the GDPR with the adoption of the security measures deemed adequate in order to minimize the risk of violation of user privacy by third parties, constantly updated and whenever it proves indispensable.

In particular, to access the reserved area, a keyword (password), consisting of eight alphanumeric characters, is provided, which will have to be modified on the occasion of the first access to the reserved area of the portal and then keep secret by adopting the appropriate precautions for its custody: the user passwords are not held by the writer Data Controller, therefore in case of loss they will be reset and the user can proceed with the entry of a new password.

The data are processed at the Data Controller's operational offices and in any other place where the parties involved in the processing are located. For more information, you can contact the Data Controller at the contact details specified below.


Personal data will be processed for as long as is strictly necessary to achieve the purposes, described above, to fulfill contractual, legal and regulatory obligations without prejudice to the prescribed and legal terms, in compliance with rights and in compliance with the consequent obligations.

In particular, criteria used to determine the retention period are established by specific legal rules (which regulate the sector in which the perfect replacement operates), and by tax legislation regarding the processing of administrative-accounting data.

With reference to the data collected for commercial purposes (referred to in point 2), the details are limited - for profiling activity - to 1 year from the date of acquisition and 2 years for direct marketing activity.

Finally, the personal data of the user of the site may also be stored up to the time allowed by Italian law to protect the legitimate interests of the Owner company (art. 2947, co. 1 and 3 c.c.)".


The processing of personal data will be carried out, within the limits of the general authorizations issued by the Guarantor for the protection of personal data, by means of subjects expressly and specifically authorized by the perfect replacement. The data may also be processed by third parties (outsourcers), which are used for the provision of services related to the purpose pursued, which our organization binds with specific contractual clauses or acts of formal appointment to External Managers for the processing from these posts in place. In all cases, these subjects will process the data in accordance with the instructions received from the Data Controller, according to operational profiles attributed to them in relation to the functions performed, limited to what is necessary and instrumental for the execution of specific operations within the requested services and exclusively for the achievement of the purposes indicated in this information. The list of data controllers, constantly updated, can be requested by sending a communication with the methods indicated in the following point concerning the rights of the data subject.


The data may be communicated, by this term meaning to give knowledge to one or more specific subjects, in the following terms:

  • to subjects, public and private, who can access the data by virtue of legal provisions, regulations or Community legislation, within the limits provided for by these rules (e.g. institutions and social security and welfare institutions, associations of local authorities, public administrations and bodies, associations, foundations, associations or bodies of an association and/or insurance type)

  • to subjects who need access to the data for auxiliary purposes to the relationship between the parties, to the extent strictly necessary to carry out the auxiliary tasks (these are mentioned as an indication, banks and credit institutions, service providers, carriers and shipping companies)

  • to our consultants, to the extent necessary to carry out their duties at our organization, upon our letter of assignment that imposes the duty of confidentiality and security.

  • companies (which provide ancillary services, including IT services), subject to the signing of appropriate contractual clauses that impose the duty of confidentiality and security.

The data will not be disclosed, by this term meaning to give knowledge to indeterminate subjects in any way, including through their making available or consultation, unless a specific consent, free and informed, granted for each type of processing.

Defence in court

The personal data of the user can be used for the defense by the Data Controller in court or in the stages preparatory to its possible establishment, from abuses in the use of the same or connected services by the user. The user declares to be aware that the Data Controller may be required to disclose the data at the request of the public authorities.


Data controller is the perfect replacement based in Via Monte Novegno 15 Torino (TO) – ITALY.

The Data Controller keeps an updated list of the appointed managers, and guarantees that the data subject will be seen at the aforementioned location.


Interested parties, to whom personal data refer, have the right to exercise at all times the rights (Right of access to personal data and other rights), in particular: right to obtain confirmation of the existence or not of their personal data, to access it and to know its content and origin, to verify its accuracy, to request its integration or updating, limitation of processing or portability. Rectification and blocking may be required if the data are incomplete, incorrect or collected in violation of current legislation and in this sense it is also possible to oppose their processing for legitimate reasons or to any automated decision-making process (including profiling), as well as it is possible to request, for the same reasons also cancellation provided that in accordance with current rules and if there are no other storage and processing obligations in charge of the perfect replacement. Interested parties also have the right to object to the processing of their personal data for marketing purposes (indicated in point 2), even if carried out with automated methods of contact; this right also extends to traditional ones and interested parties will be able to exercise these rights in whole or in part (e.g. only to communications by sms, e-mail or telephone or by opposing only the sending of promotional communications carried out through automated tools, etc.).

With regard to the exercise of their rights listed above, as well as to know the updated list of data controllers, the data subject can address their requests through specific communication by post addressed to the same Company, or through the e-mail box:, also by sending communication to the indicated e-mail address, in order to obtain timely feedback.

If the data subject has given consent to the processing for a specific purpose, the same always has the right to revoke it at any time without prejudice to the lawfulness of the processing based on the consent given before the withdrawal.

It should also be noted that the data subject always has the right to make a complaint to the Guarantor Authority for the protection of personal data for the exercise of his rights or for any other matter related to the processing of his personal data.


The Data Controller reserves the right to make changes to this privacy policy at any time by advertising it to users on this page. It is therefore advisable to consult this page often, taking as a reference the date of last change indicated at the bottom. In the event of non-acceptance of the changes made to this privacy policy, the user is required to cease the use of this site and related services and may request the Data Controller to remove his personal data. Unless otherwise specified, the previous privacy policy will continue to apply to personal data collected up to that time.