In accordance with Article 13 – EU Regulation 2016/679
Relevant Legislation:
- EU Regulation No. 679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data
- Italian Legislative Decree No. 196 of June 30, 2003 and subsequent amendments (hereinafter as “Privacy Code”).
- Recommendation no. 2 of May 17, 2001 on minimum requirements for online data collection in the European Union, adopted by the European Data Protection Authorities, meeting in the Working Party established by Article 29 of Directive No. 95/46/EC (hereinafter as “Article 29 Working Party Recommendation”).
The Company acts as “Data Controller,” by which is meant “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data”. Specifically, the processing of personal data may be carried out by individuals specifically authorized to carry out processing operations on users’ personal data and, for this purpose, duly instructed by the Company. In application of the regulations on personal data processing, users who consult and use the Company's website assume the quality of “data subjects,” by which is meant the natural persons to whom the personal data being processed refer. Please note that the information does not extend to other websites that users may consult through links, including Social Buttons, on the Company's website. Specifically, Social Buttons are digital buttons, that is direct links to Social Network platforms (such as, but not limited to, LinkedIn, Facebook, Twitter, YouTube), configured in each individual “button.” By performing a click on such links, users will be able to access the Company's social accounts. Social Networks Managers, to which the Social Buttons refer, operate as independent Data Controllers; consequently, any information regarding the methods in which these Data Controllers carry out processing operations on users' personal data can be found in the related Social Network platforms.
- Personal data subject to processing:
In consideration of interaction with this website, the Company may process the following users’ personal data:
a. Navigation data: information systems and software procedures responsible for the functioning of this website acquire, in the course of normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. Such information is not collected in order to be associated with identified interested parties, but which by its very nature could, through processing and association with personal data held by third parties, allow users to be identified. This category of personal data includes the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment. These personal data are used only to obtain anonymous statistical information on the use of the website and to check its proper functioning. Navigation data do not persist for more than (12 months), subject to any need for crimes investigation by the Judicial Authority.
b. Personal data voluntarily conferred: lthe optional, explicit and voluntary transmission of personal data to the Company, by filling in the forms on the website, entails the acquisition of the e-mail address and all further users' personal data required by the Company in order to comply with specific requests. With reference to the processing of personal data provided by filling in the contact form placed on this website, please refer to the relevant “contact form information".
- Purpose and legal basis of personal data processing
With regard to the personal data referred to in point 1), let. a) of this Information Notice, the users' personal data are processed, automatically and “obligatorily” by the Company in order to enable the same navigation; in this case the processing is carried out on the basis of a legal obligation to which the Company is subject, as well as on the basis of the legitimate interest of the Company to ensure the proper functioning and security of the website; therefore, the users' express consent is not necessary. With regard to the personal data referred to in point 1), let. b), of this Information Notice, the processing is carried out in order to provide information or assistance to users; in such case, the processing is based on the execution of specific requests and the fulfillment of pre-contractual measures; therefore, the users' express consent is not necessary. .
- Nature of provision of personal data
Without prejudice to what has been specified for navigation data in relation to which conferment is obligatory as it is instrumental to navigation on the Company's website, users are free to provide or not to provide personal data in order to receive information or assistance from the Company. With reference to the processing of personal data provided by completing the contact form placed on this website, please refer to the relevant “Contact Form Information Notice”.
- Methods and duration of personal data processing
The processing of personal data is carried out by the persons authorized to process personal data, specifically identified and instructed for this purpose by the Company. The processing of users' personal data is carried out through the use of automated tools with reference to the data of access to the website pages. With reference to the processing of personal data conferred by filling in the contact form placed on this website, please refer to the relevant “Contact Form Information Notice”. In any case, the processing of personal data is carried out in full compliance with the provisions aimed at ensuring the security and confidentiality of personal data, as well as, among other things, the accuracy, updating and relevance of personal data to the purposes stated in this Information Notice. Notwithstanding the fact that the navigation data referred to in point 1, let. a), do not persist for more than 12 months, the processing of personal data is carried out for the time strictly necessary to achieve the purposes for which they were collected or, in any case, according to the deadlines provided for by the law. It should also be noted that the Company has adopted specific security measures to prevent loss, illicit or incorrect use of personal data and unauthorized access to them.
- Recipients of personal data
Limited to the purposes identified in this Information Notice, your personal data may be disclosed in Italy or abroad, within the territory of the European Union (EU) or the European Economic Area (EEA), for the fulfillment of legal obligations. For more information with reference to the recipients of users' personal data conferred by filling in the contact form placed on this website, please refer to the relevant “Contact Form Information Notice”. Personal data will not be transferred outside the territory of the European Union (EU) or the European Economic Area (EEA). Personal data will not be subject to dissemination and therefore will not be disclosed to the public or to an indefinite number of individuals.
- Rights under Articles 15, 16, 17, 18, 20 and 21 of EU Regulation 2016/679
Users, as data subjects, may exercise the rights of access to personal data provided by Article 15 of the EU Regulation and the rights provided by Articles 16, 17, 18, 20 and 21 of the EU Regulation regarding rectification, erasure, restriction of processing of personal data, data portability, where applicable and opposition to the processing of personal data.
The above mentioned rights can be exercised by writing to the following e-mail address:
digitallaw&dataprotection@vargroup.it
If the Company fails to provide feedback within the timeframe prescribed by the regulations or the response to the exercise of rights is inadequate, users may lodge a complaint to the Italian Data Protection Authority.
Below you can find the contact details:
Garante per la Protezione dei Dati Personali
Piazza Venezia n. 11 - 00187 Roma
Fax: (+39) 06.69677.3785
Telephone switchboard: (+39) 06.69677.1
E-mail: protocollo@gpdp.it
- Data Protection Officer
The Data Protection Officer can be contacted at the Company's headquarters and at the following e-mail address: dpo@sesa.it