INFORMATION ON THE TREATMENT OF PERSONAL DATA

Notice pursuant to and by effect of article 13, D.Lgs. 30 June 2003 n. 196


In observance of D.Lgs. 30 June 2003 n. 196 (Privacy Code) and successive amendments, we hereby give notice of the required information regarding the treatment of the personal data supplied by users. This information should not be considered valid for other websites which are potentially accessible via links provided on the websites of the domain holder, who disavows all responsibility for the websites of third parties.

This notice is also given in accordance with art. 13 of d.lg. n. 196/2003 – code for the protection of personal data.  
The information is also based on Recommendation n. 2/2001, which was adopted on 17 May 2001 by European authorities for the protection of personal data, meeting as a group under the authority of art. 29 of directive n. 95/46/CE. The group defined the minimum requisites for the collection of personal data online, concentrating in particular on the methods, timescales and nature of the information which controllers must give to users when the latter connect to a web page, notwithstanding the reason for connecting. This policy also takes account of Directive 2002/58/CE, as updated by Directive 2009/136/CE concerning Cookies as well as the regulations laid down by the guarantor for the protection of personal data of 08.05.2014 concerning Cookies.


1. THE CONTROLLER: according to article 28 of the Data Protection Code, the controller is the pro tempore legal representative of RODACCIAI SPA, whose registered office is in via Aurelio Saffi 34 – 20123 Milan.

THE DATA PROCESSOR: according to article 29 of the Data Protection Code, the IT Area Manager acts as the internal data processor.

 

2. TYPES OF DATA
Personal and identifying data.
Personal data is taken to mean any information relative to a physical person, directly or indirectly identified or identifiable by reference to any other type of information including a personal identification number. Identifying data are personal data which allow a person to be directly identified (for example first name, surname, date of birth, address, e-mail address, telephone number, etc.).

Browsing Data
As per normal procedures, the IT systems and software used to run this web site acquire some of the user’s personal data. Consent for the transmission of this data is implicitly given by users as per normal Internet protocol.

This information is not collected in order to identify particular subjects, but could by its very nature be used to identify users through data processing and associating it with data held by third parties.
This type of data includes IP addresses or domain names used by individuals who connect to the web site,  the URI (Uniform Resource Identifier) of requested resources, the time of request, the method adopted to send the request to the server, the size of the file received in reply, the numerical code indicating the state of the reply given by the server (‘your request was successful’, ‘an error occurred’, etc.), and other parameters relative to the operating system and to the computer environment of the user.

Use in court
The user’s personal data can be used in the legal defence of the Controller in court or during the preparatory stages of legal action, or against abuses of the service by the user. Data can also be used to ascertain responsibility in the case of potential computer crimes committed against the site.

Site maintenance
Users’ personal data can be processed for maintenance reasons.

Data given voluntarily by users
The free, explicit and voluntary sending of e-mails to addresses listed on the site and/or the compilation of data collection forms involves the subsequent acquisition of the address of the sender, which is necessary in order to reply to requests, as well as other personal data submitted.



Specific information
Specific information could be present on the pages of the website, related to specific services or the processing of data given by the user or by interested parties.



Cookies
Our policy on Cookies can be consulted through the following link



3. PURPOSE OF DATA PROCESSING FOR WHICH CONSENT IS TO BE GIVEN WHERE REQUESTED (ART. 23 D.LGS. 196/03)

Personal and potentially sensitive data voluntarily given, shall be subject to processing for the following purposes, until otherwise requested:

- Navigation on this site;

- Any contact request, or sending information requested by the user;

- Signing up to the data controller’s newsletter;

- Sending speculative CVs;

- Administrative and accounting activities in general.

In order to correctly apply the provisions regarding the protection of personal data, data processing for administrative and accounting purposes is related to organizational, administrative, financial and accounting activities, regardless of the nature of the data processed. Internal organizational tasks, the fulfillment of contractual and pre-contractual obligations, and IT activity also take advantage of data processing. 

4. METHODS OF PROCESSING - TREATMENT
Data processing is both automatic and manual, using methods and tools which guarantee maximum security and privacy by specialised employees, in compliance with articles 31 and  segg. D.Lgs 196/03. Personal data shall be conserved for a period not exceeding the fulfilment of the aims for which they were collected and subsequently processed.

5. COMMUNICATION AND DISSEMINATION

 Data which are subject to processing will not be disclosed to third parties, but may be communicated to companies contractually linked to RODACCIAI SPA, abroad and within the European Union, in accordance with article 42 of D.Lgs. n. 196/2003. Personal data may be sent abroad to countries outside the EU within the limits laid out by articles 43 and 44 lett. b) of  D.Lgs. n. 196/2003, in order to comply with contractual obligations or other relative purposes. Data can be communicated to third parties in the following categories: 
- IT management service providers used by RODACCIAI SPA and telecommunications networks (including e-mail);

- companies in the Rodafin S.p.A. group, for administrative and accounting purposes;

- Consultants and advisory bodies;

- Authorities or public bodies responsible for the application of relevant laws and / or regulations (on request) .

The subjects belonging to the abovementioned categories are considered responsible for processing the data, or work as completely independent data controllers . The list of subjects is constantly updated and is available at the head office of RODACCIAI SPA . Any further communication and distribution of data will be dependent on the explicit consent of users.

6. NATURE OF ACCEPTANCE AND REFUSAL

The user is free to provide personal data other than that specifically requested as part of navigating the web page. The provision of data is optional but necessary in order to optimize user experience of the site and in order to enjoy services given by the controller on processing data. The absence of user details (e -mail) may result in the inaccessibility of the service; for example, in the impossibility of receiving a reply from the controller, of completing a job application or sending a CV, or of signing up to the newsletter.

7. USERS'RIGHTS

Users can assert the rights guaranteed by art. 7, 8, 9 and 10 of Legislative Decree no. 30 June 2003 n. 196 by contacting the data processor or the relevant manager by emailing info@rodacciai.com

Users have the right, at any time, to obtain confirmation of the existence of data and to know its origin and origin, verify its accuracy, and request the integration, updating or correction of the data (article 7 of the code for the protection of personal data).

According to the same article, users have the right to request anonymity or the cancellation or suspension of data in violation of the law, and to oppose data processing in any case, for legitimate reasons.

Users wishing to contact the controller are asked to provide their email address, name, address and / or telephone numbers, to enable the correct handling of the request.

8. CHANGES TO THIS PRIVACY POLICY

The controller reserves the right to modify, update, add or remove portions of this privacy statement at his/her discretion and at any time . Users are responsible for checking periodically for updates to the privacy policy. In order to facilitate this, the disclosure shall always include the date when the information was last updated. Use of the site after the publication of changes constitutes acceptance of them .

Update Date : May 14, 2015