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Privacy policy

ROMO1881 S.r.l., fiscal code and VAT number 10673000963, with headquarter in Milan, Galleria del Corso n. 2 (“ROMO1881” or, also, the “Company”), works continuously to protect the online privacy of the users of the websites that refer or make reference to this privacy policy (the “Site”).
This document (the “Policy”) was written to explain the ways in which your Personal Data, as defined below, is processed in the context of using the Site.
The Policy aims to provide you with the information you need in order to give your explicit and informed consent to the processing carried out through the Site, should you agree to it.
Generally speaking, the information or Personal Data that you give to ROMO1881 though the Site, or that is collected in other ways through the Site, in the context of using the services it offers (the “Services”), as defined hereinafter, is processed in accordance with the internationally recognized principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity and confidentiality

CONTENTS

1. Data Controller and Data Protection Officer
2. Personal Data Subject to Processing
(a) Name, Contact Details and Other Personal Data
(b) Job Applicants
(c) Special Categories of Persona Data
(d) Data Willingly Provided by the Data Subject and Minors’ Personal Data
(e) Browsing Data
3. Purpose of the Processing
4. Legal Grounds and Obligatory or Voluntary Nature of the Processing
5. Recipients of Personal Data
6. Transfer of Personal Data
7. Storage of Personal Data
8. Data Subject Rights
9. Changes

1. DATA CONTROLLER AND DATA PROTECTION OFFICE

ROMO1881, as already identified at the beginning of the Policy, is the Data Controller for all of the Personal Data processed through the Site and can be contacted at the following email address: privacy@roncoroni1881.it

2. PERSONAL DATA SUBJECT TO PROCESSING

Following your use of the Site, the Company will process your Personal Data, which may include – in part depending on how you choose to use the Services – identifiers such as your name, surname, fiscal code, province of residence, telephone number, email address, identification number such as customer number, an online identifier or one or more pieces of information
about your physical, physiological, psychic, economic, cultural or social identity that are identifiable or can be used to identify you (the “Personal Data”).
Your Personal Data can be collected either because you willingly provided it (for example, when you create an account in order to receive the Services offered) or by simply analyzing your use of the Site.
The following types of Persona Data are processed through the Site:

(a) Name, Contact Details and Other Personal Data
In various sections of the Site, in particular those relative to creating an account, you will be asked to enter information such as your name, surname, telephone number, email address and etc.
Furthermore, if you participate in a survey or any promotions through the Site, as well as when you communicate with the Company through the Site or Customer Service, the Company will be able to collect the additional information that you decide to provide.

(b) Job Applicants
Registering on the section of the Site for job applicants, at the address http://www.roncoroni1881.it/jobs (“Jobs”), you can access a reserved area (the ‘Application’) where you can provide the Company with various types of Personal Data, such as work or professional information (for example, the university that you attended, foreign language skills, professional qualifications, expectations and desired place of work, links to your professional profiles on social networks and etc.) and attach your photo, CV and cover letter.
When the Company receives an Application, it will be able, even if you have not indicated the information on your application, to view your professional profiles on social networks (for example, Linkedin) and relevant professional websites, if publicly accessible, in order to gather further information useful for determining your compatibility with the position of interest to you

(c) Special Categories of Persona Data
You might provide the Company with information that might contain personal data through the Site (for example, through the Customer Service information request form or through the Application).
Since these fields are open, you might use them to communicate (voluntarily or not) certain sensitive categories of Personal Data, such as information that reveals racial origin or ethnicity, political opinions, religious or philosophical beliefs, union membership, genetic data, biometric data processed solely to identify a human being, data relative to health, sexual activity or sexual orientation.
The Company asks that you refrain from sending such Personal Data unless strictly necessary. In fact, these special categories of Personal Data can only be subject to processing with your explicit consent and in accordance with current regulations. The Company would therefore like to stress the importance of providing your explicit consent to the processing of these special categories of personal data, should you decide to share such information.

(d) Data voluntarily provided by the data subject
As noted above, you can communicate various kinds of information to the Company through the Site, and this information might contain the Personal Data of other people.
In such a case, you become an independent data controller, assuming all of the relevant legal obligations and responsibilities. In this regard, you fully indemnify us against any complaint, claim, request for damages in consequence of the processing that the Company might receive from the third party whose Personal Data was processed through your use of the Site in violation of applicable personal data protection laws. In any case, should you provide or in some other way process the Personal Data of third parties through your use of the Site, you guarantee from that point forward – assuming all relevant responsibility – that any processing is based on the consent of the third party in question or on other applicable legal grounds that legitimize the processing of the data in question.

(e) Browsing Data
The computer systems and software procedures responsible for making this Site function, during the normal course of business, collect some personal data which are transmitted implicitly when using Internet communication protocols. This information is not gathered for the purposes of its association with the identified data subjects, but by its very nature, it could enable the users to be identified when processed and associated with data held by third parties.  This category of data includes the IP addresses or domain names of the computers used by visitors to the Site, the addresses of the requested resources in URI (Uniform Resource identifier) form, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code that indicates the status of the response provided by the server (successfully delivered, error and etc.) and other parameters relative to the user’s operating system and IT environment.  This data is only used to process anonymous statistical information about the use of the Site, to check that it is functioning smoothly and to identify anomalies and/or abuse and is erased immediately after processing.  The data might be used to determine responsibility in the case of computer crimes that damage the Site or third parties: apart from this eventuality, data on web contacts is not stored for more than seven days.

3. PURPOSE OF THE PROCESSING

The Company will use your Personal Data, collected through the Site, for the following purposes:

  • To provide you with access and make it possible for you to register for an account on the Site; verify your identity and help you, in case you lose or forget the login or password for your account on the Site; send you the newsletter that you requested as a Service by signing up and that contains only informational material and no advertising or provide you with any other Service that you have requested (the “Provision of Services”) including, for example,
    business contacts, technical information downloads, 3D model downloads and etc.;
  • To review Applications from job seekers and contact those who have sent Applications through the Site (“Recruitment”).
  • To send you marketing, promotional and advertising communications, market research and surveys via email, SMS, MMS, apps, paper post, telephone and/or through the Company’s official pages on social networks; as well as for marketing, in the broad sense, including prize competitions, draws and free gifts with purchase, of products and/or services offered by the Company and/or the products and/or services of third parties (“Marketing”);
  • To send you marketing communications via e-mail for products and services similar to those that you have purchased through the Site (“Soft Marketing”).
  • To create your profile through the use of tracking cookies, if allowed, and so collect and analyze information about the choices that you make on the Site, as well as your overall Site activity if you are a registered user, and so collect information about your questions and browsing activity. This profile will be used to offer you information about other products and/or services that the Company thinks might interest you and to show you advertising that might be relevant to your tastes. All of the algorithms used in this process are regularly tested to ensure that you are not offered products that do not interest you (“Profiling”).
  • Discharge legal obligations that require the Company to collect and/or further process certain types of Personal Data (“Compliance”).
  • Prevent or identify any kind of abusive use of the Site or any fraudulent activity and so permit the Company to protect itself in Court (“Abuse/Fraud”).

4. LEGAL GROUNDS AND OBLIGATORY OR VOLUNTARY NATURE OF THE PROCESSING

The legal grounds for processing your Data, in accordance with the purposes listed above in Section 3, are the following:

  • Provision of Service: processing is necessary for this purpose in order to provide you with the Services and, therefore, to fulfil our contract with you.
    It is not mandatory to provide the Company with your Personal Data for this purpose, but if you do no provide it, it will not be possible to provide you with any Services. The same is true for the Service newsletter, which you will receive after specifically requesting it by entering an e-mail address. You can opt out of receiving the newsletter by following the instructions in Section 8 below.
  • Recruitment: the Company processes your Personal Data for this purpose in order to review your Application and it is therefore necessary in order to begin the selection process and, if possible, offer you a position. It is not obligatory to provide your Personal Data for this purpose, but if you do not provide it, it will not be possible to consider your Application. If you wish to provide special categories of Personal Data (for example, information related to health, religion and etc.), the Company will need your explicit consent.
  • Marketing: processing for this purpose is based on your consent. It is not obligatory to give your consent for this purpose and you are free to withdraw it at any time without any consequences (except for no longer receiving marketing communications from the Company). You can withdraw your consent by following the instructions in Section 8 below.
  • Soft Marketing: processing for this purpose is based on the Company’s interest in sending you marketing communications via e-mail for products and services similar to the ones you have already purchased. You can opt out of receiving these communications, without any consequences (besides no longer receiving communications of this kind from the Company) using the link at the bottom of each of these e-mails.
  • Profiling: processing for this purpose is based on your consent. It is not mandatory to give your consent for this purpose and you are free to withdraw it at any time without any consequences (except that you will not benefit from the customization of the commercial offers that you receive). You can withdraw your consent by following the instructions in Section 8 below.
  • Compliance: processing for this purpose is necessary for discharging legal obligations. When you provide Personal Data to the Company, they must be processed in accordance with the applicable regulations, which might entail their storage and communication to the Authorities to meet accounting, fiscal or other obligations.
  • Abuse/Fraud: information collected for this purpose will be used solely for preventing and/or identifying possible fraudulent activity or abusive use of the Site and therefore permit the Company to protect itself in Court.

5. RECIPIENTS OF PERSONAL DATA

Your Personal Data can be shared with the following subjects (the “Recipients”):

  • Subjects who work primarily as data officers or persons, companies or professional firms that provide accounting, administrative, legal, taxation, financial and debt collection assistance and consulting to the Company relative to the provision of Services;
  • Subjects with whom it is necessary to interact for the provision of Services (for example, e-mail providers);
  • Subjects hired to carry out technical maintenance activity (including the maintenance of network equipment and electronic communication networks);
  • Persons authorized by the Company to process Personal Information as required for actions strictly related to the provision of Services, whether they have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality (e.g. employees);
  • Subjects, institutions or authorities to whom it is obligatory to communicate your Personal Data for purposes of Compliance, Abuse or Fraud or by order of the authorities.

6. TRANSFER OF PERSONAL DATA

Some Personal Data might be shared with Recipients outside the European Economic Area.
The Company ensures that the processing of Personal Data by such Recipients is carried out in accordance with the applicable regulations. In fact, the transfer of data can be based on an adequacy decision or on the Standard Contractual Clauses approved by the European
Commission.
For more information, please write to the Company as instructed in Section 8 below.

7. STORAGE OF PERSONAL DATA

Personal Data processed for the purpose of Service Provision will be preserved solely for the time strictly necessary for the fulfilment of said purpose (e.g. for managing the contract).
In any case, since this Personal Data is processed in order to provide Services, the Company may store it for a longer period, in particular since it might be needed for protecting its interests from possible complaints relative to the Services.
Personal Data processed for the purpose of Recruitment will be stored either for the entire period during which the relative position remains open or for six (6) months, whichever period is shorter. The Company reserves the right to contact applicants before this deadline to request the extension of the storage period for their Personal Data or to request an updated Application. Should the Company receive no reply, the Personal Data will be erased.
Personal Data processed for the purpose of Marketing will be stored until you withdraw your consent. You will, however, be asked periodically to renew your consent. Once you withdraw your consent, the Company will no longer use your Personal Data for this purpose, but may continue to store it, in particular for the period necessary to protect its interests from possible complaints based on the relative processing.
Personal Data processed for the purpose of Profiling will be stored until you withdraw your consent. You will, however, be asked periodically to renew your consent.
Once you withdraw your consent, the Company will no longer use your Personal Data for this purpose, but may continue to store it, in particular for the period necessary to protect its interests from possible complaints based on the relative processing.
Personal Data processed for the purpose of Soft Marketing will be stored until you withdraw your consent through the link that you will find at the bottom
of every Soft Marketing e-mail.
Personal Data processed for the purpose of Compliance will be stored for the period provided for by specific legal obligations or the applicable regulations.
Personal Data processed for the purpose of Abuse/Fraud will be stored for the time strictly necessary for this purpose and in any case as long as the Company needs to store it in order to protect itself in Court to communicate said data to the competent Authorities.

8. DATA SUBJECT RIGHTS

You have the right to ask the Company, at any time:

  • For access to your Personal Data (or a copy of your Personal Data), as well as further information about the way it is being processed;
  • To amend or update your Personal Data, should it be incomplete or out of date;
  • To erase your Personal Data from the Company database;
  • To limit the Company’s processing of your Personal Data;
  • To obtain a copy of your Personal Data in a structured, commonly used and machine readable format; you may also:
  • Object to the processing of your Personal Data (e.g. Soft Marketing and Profiling);
  • Withdraw your consent for Marketing purposes.

When you request Services, you select the communication channel(s) through which you wish to be contacted for Marketing purposes (email, SMS, MMS, app, paper post, telephone and/or the company’s social network pages).
You may withdraw your consent for Marketing relative to any of these communication channels following the instructions indicated below.
You may also withdraw your consent to Marketing sent via e-mail and stop receiving Soft Marketing using the link found at the bottom of every e-mail of this type. The same method may be used to stop receiving the newsletter, if you have requested it as a Service.
Consent to Profiling via cookies may be withdrawn following the instructions indicated above in Section 2.
In addition to the above, you may also exercise your rights writing to the Company at the following e-mail address: privacy@roncoroni1881.it
In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Italian Data Protection Authority) should you hold that the processing of your Personal Data does not comply with current regulations.

9. CHANGES

The present Privacy Policy has been in force since May 2020.
The Company reserves the right to change or simply update its contents, in part or entirely, including due to changes in the applicable regulations.
The Company will inform you of such changes as soon as they are introduced and they will be binding upon publication on the Site.
We therefore ask that you please visit this section regularly in order to stay up to date on the most recent version of the Privacy Policy and therefore stay up to date on the data collected and the way in which the data is used.

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