This information is provided pursuant to art. 13 of EU Regulation 2016/679, the European Data Protection Regulation (hereafter “Regulation” or “GDPR”) to users who interact with the services available on the website https://www.promosgroup.it. This information does not concern other websites, pages or online services that may be accessed via any hypertextual links published on the website but referring to resources external to the domain https://www.promosgroup.it.
1. DATA CONTROLLER RESPONSIBLE FOR THE PROTECTION OF PERSONAL DATA
The Data Controller, pursuant to articles 4 and 24 of EU Regulation no. 2016/679, is: PROMOS S.R.L., Via San Zeno, 173 – 25124 Brescia (BS), Italy, e-mail: privacy@promosgroup.it, Tel: +39 030 2422862.
The Data Security Manager (RPD and/or DPO), pursuant to art. 37 of the Regulation, can be reached at the following e-mail address: dpo@promosgroup.itdpo@promosgroup.it.
2. TYPES OF PERSONAL DATA WE COLLECT
a) Data acquired during navigation
The systems and applications devoted to the operation of this website will collect data, during their normal operation, the transmission of which is implicit in the use of the communication protocols typical of the Internet. The data in this case are not collected in order for association with identified data subjects, but by their nature could be processed and associated with data controlled by others so as to identify the users. This category of data would include the IP addresses or domain names of the computers used by users who connect to the website, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of connection, the method used in submitting the request to the server, the dimensions of the file obtained in reply, the numerical code indicating the status of the response given by the server (successful outcome, error, etc.) and other parameters relative to the operating system and information environment of the user. These data are used for the sole purpose of obtaining anonymous and aggregate statistical information about the use of the website and to control its correct function. The data may also be used for ascertaining liability in case of hypothetical information crimes against the website.
b) Data provided voluntarily by the data subject
PROMOS also collects personal data provided voluntarily by the users when they interact with services on the website or when they fill out data collection forms. This may occur when requesting the newsletter or other information, or when communicating with the company for other reasons.
In the sections of the website where user data are collected, there is always a link to this Privacy Policy or other specific information about the uses made of personal data.
If users, when accessing the services of the website, supply third party data, they guarantee that these are provided with consent to communication of their personal data, if necessary.
c) Cookies
For more information about the cookies used on this website, see our cookies policy at the following link: https://www.promosgroup.it/en/cookies
d) Specific Information
In case of further personal data collection, specific information will be given to the data subjects (see, for example, the information in the section “Work with us”).
3. Purposes and legal bases for processing data. period of data conservation
Any personal data provided will be processed for the following purposes:
a) Navigation of the website.
PURPOSE: to enable users to navigate the website.
LEGAL BASIS: need to respond to specific requests of data subjects and perform the contracts stipulated with them.
NATURE OF SUPPLY: necessary for anyone who wishes to navigate the website and use the relative services.
b) Newsletter.
PURPOSE: to enable users to subscribe to the newsletter via electronic mail.
LEGAL BASIS: consent of the data subjects. After consenting, data subjects can revoke it or withdraw their permission at any time. To do so, it is sufficient to use the “Unsubscribe” option provided in every e-mail sent, or to contact the data controller.
NATURE OF SUPPLY: consent to the use of personal data for subscribing to the newsletter, although optional, is necessary in order for the subscriber to receive it. In case of non-consent, it will not be possible to receive the newsletter but it will, in any case, be possible to navigate all the sections of the website.
c) Requests of contact
PURPOSE: to enable users to obtain information about our services and receive information, using the form on the “contacts” page. We collect the information contained in your requests, such as: e-mail address of the sender (necessary to respond to your requests), fist and last name and other information provided in the message.
LEGAL BASIS: it is necessary to process personal data to perform any contract stipulated with a data subject or to apply precontractual measures enacted at the request of that party.
NATURE OF SUPPLY: Personal data are necessary to fulfill the request presented via the “contacts” section as, if not provided, it will be impossible for the data controller to fulfill the request.
d) Data collected via the “Work with us” form.
PURPOSE: The data provided in sending your resumé or by filling out the special form on the website, will be processed exclusively for the purpose of recruiting and selecting personnel.
LEGAL BASIS: performance of precontractual measures applied at the request of the data subject and responding to a request of the data subject.
NATURE OF SUPPLY: the data provided are necessary in applying for employment with the company.
To view the complete information about our use of the data relative to your resumé, we refer you to this link: https://www.promosgroup.it/en/privacy-notice-for-work-with-us/
4. PROCESSING METHODS AND PERIOD OF DATA CONSERVATION
The personal information of data subjects will be collected and processed with electronic devices and, to a lesser degree, using manual devices, only for the time necessary to fulfill the purposes of the data controller. The logics and procedures of processing are related to the purposes specified in this information sheet. Depending on the specific purpose for which they are processed, the personal data are accessible to the personnel authorized to process them, and to the data processors. Fully automated decisional processes that produce legal effects for the data subjects, or affect them in significant ways, are not used.
The personal data of users will be processed for the time necessary to manage their interaction with the website and to secure their use of the relative goods and/or services. Once these purposes have been achieved, the data will be conserved for the time required by law for administrative, accounting and fiscal purposes and to validate any rights and interests of the data controller.
Data processed for purposes of marketing and profiling of data subjects are kept until consent is revoked or withdrawn by the data subjects, in accordance with the most recent provisions of the Guaranteeing Authority for the Protection of Personal Data. Resumés will be kept for a maximum term of 12 months from receipt.
5. RECIPIENTS OF PERSONAL DATA
Personal data may be communicated to third parties who perform activities necessary for the provision of the services offered by the website, who process the data as data processors or independent data controllers. Specifically, the data will be processed by the following parties or categories of parties:
• companies affiliated with the data controller or partners that provide IT services;
• companies and consultants, engaged in assistance and consulting services on legal, accounting and fiscal matters;
• parties supplying services for the management of the information system and telecommunications networks, including e-mail;
• government authorities ensuring compliance with legal obligations;
The data processed for the purpose of sending newsletters are not communicated to third parties but may be processed by other companies responsible for processing, pursuant to art. 28 of the Regulation.
Through the icons of the social networks present on the website, some user data may also be conveyed to the social networks (LinkedIn). With respect to these uses, which are made externally to this website, you are referred to their specific privacy policies.
All the parties listed above are required to use the information received only for the purposes of processing as indicated above, and to keep the data confidential, intact and inaccessible to unauthorized third parties. The data of our users are not made public.
6. TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES
Data subjects’ information may be transferred outside the European Union, if the servers used by the parties with which PROMOS has stipulated specific contracts are located there. In that case, the data controller will take appropriate measures, as required by the Regulation, to protect the personal data of data subjects.
7. RIGHTS OF DATA SUBJECTS
The articles from 15 to 22 of the GDPR grant data subjects specific rights. Art. 15 recognizes the right of data subjects to access their personal data and obtain a copy of it. The right to obtain a copy of their data shall not infringe on the rights and freedoms of others.
With the request of access, the data subjects have the right to obtain from the data controller confirmation or denial of the fact that their data are being processed and to know the purposes and categories of data processed, the third parties to which they have been communicated and whether the data have been transferred to a country outside Europe with adequate guarantees. Data subjects also have the right to know for how long their personal data will be used, in respect of the aforementioned purposes. With respect to their personal data, data subjects may request correction of incorrect data and completion of incomplete data, as well as deletion (right to oblivion) at the conditions indicated by art. 17 of the Regulation, and may also request limitation of processing and portability of data.
Data subjects have the right at any time to oppose the use or revoke consent to use of their data with regard to purposes of marketing and profiling if connected to marketing.
To cancel the subscription to the newsletter it will be sufficient to click the “unsubscribe” option provided in the e-mails, or write at any time to privacy@promosgroup.it.
The data controller will issue a statement to the data subject certifying that the operations mentioned above have been notified to those to whom the data had been notified and disclosed, unless this should be found to be impossible or imply the use of means clearly disproportionate to the right protected.
To exercise the above rights, it will be necessary to contact the data controller at the e-mail privacy@promosgroup.it, or at the address of the registered office.
Before responding, it may be necessary to identify data subjects by asking them to supply a copy of their identity document. The data controller will provide a written answer without undue delay and, in any case, no later than one month after receipt of the request.
8. CLAIMS WITH THE GUARANTOR FOR THE PROTECTION OF PERSONAL DATA
Data subjects who believe that their personal data may have been used in violation of the provisions of the Regulation or local legislation on the subject of data protection have the right to file a claim with Guarantor for the Protection of Personal Data, with office in Rome, pursuant to art. 77 of the Regulation, as well as with the courts of law.
9. UPDATES
This privacy policy may undergo amendments and/or additions following any amendments and/or additions to the legislation, the update or provision of new services or intervening technological innovations. Any changes will be published on the website and, if necessary, communicated to the data subjects via e-mail.
Latest version February 2024