Privacy Notice and Cookie Policy


Privacy and Cookie Policy

Privacy Policy pursuant to Article 13 of (EU) Regulation No. 679/2016

This document has been drawn up pursuant to Article 13 of (EU) Regulation No. 679/2016 (hereinafter “Regulation”) in order to allow users to know our privacy policy, to understand how their personal information is handled when using our site (www.assuteurope.com, hereinafter “Website”) and, if applicable, to give consent to the processing of their personal data expressed and conscious. The information and data provided by users or otherwise acquired in connection with the use of navigation services and access to the reserved area of the Website (hereinafter “Services”), will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that inspire the activity of ASSUT EUROPE SpA.
According to the rules of the Regulation, the treatments carried out by ASSUT EUROPE SpA will be based on the principles of lawfulness, fairness, transparency, limitation of purposes and retention, minimization of data, accuracy, integrity and confidentiality, as well as the principle of accountability pursuant to art. 5 of the Regulation.

 

1.  HOLDER OF THE TREATMENT AND DATA PROTECTION OFFICER “DPO”

ASSUT EUROPE SpA, with legal office in Via Gregoraci 12, Rome (hereinafter “ASSUT EUROPE SpA” or “Holder”) constantly strives to protect the online privacy of its users. Therefore, before sending any personal data to the Holder, we invite you to read this privacy notice carefully, as it contains important information on the protection of personal data.
The Data Protection Officer (“DPO”) ex art. 37 and ss. of the Regulation, domiciled at our office, can be reached at the address indicated in the “Contact” section of this Policy. 

 

2.  PERSONAL DATA OBJECT OF THE TREATMENT

Personal data processed may consist of an identifier such as a name, an identification number, location data, an online identifier or one or more characteristic elements of the physical, physiological, psychological, economic, cultural or social identity suitable to make the individual identified or identifiable, depending on the type of services requested.
In particular, the personal data processed through the Website are as follows. 

 

a) Navigation data

IT systems and software procedures used to operate the Website automatically acquire, during normal operation, some information concerning web browsing, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects but by nature it could, through associations and processing with data held by third parties, allow users or navigators to be identified. This category includes information on IP addresses, domain names of computers used by users who connect to the site, addresses in URI notation (Uniform Resource Identifier) of the requested resources, time of the request, the method used in submitting the request to the web server, the size of the file obtained in response, numerical code indicating the status of the response given by the web server (good end, error, etc.) and other parameters related to the operating system and the user’s computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of this Website and to check its correct functioning, to identify anomalies and / or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site or third parties.
Specific information is given in the sections of the website set up for particular services, also accessible after registration, where personal data are requested to the user.

 

b) Special categories of Personal Data

In using the “Contacts ”section (https://www.assuteurope.com/en/contacts), there may be a processing of personal data falls into the category of special categories of Personal Data pursuant to art. 9 of the Regulations, textually “[…] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”. We invite our users not to publish this data unless strictly necessary. Indeed, we remember that in the face of the transmission of special categories of Personal Data, but in the absence of specific manifestation of consent to process such data (eventuality that also allows to send a curriculum vitae), ASSUT EUROPE SpA can not be held responsible in any way, nor can receive disputes of any kind, since in this case the processing will be allowed as having data object made manifestly public by the interested party, in accordance with the art. 9.1.e) of the Regulations. However, we specify the importance, as mentioned above – of expressing the explicit consent to the processing of the special categories of Personal Data, where the user decides to share this information.
ASSUT EUROPE SpA, in any case, for the purposes of the selection, could analyze the professional social profiles freely available on the Internet (eg: via LinkedIn).

 

c) DATA COLLECTED THROUGH COOKIE

What are cookies

Browsing this site involves the receipt of cookies, short strings of text that the websites visited send to the user’s browser (the program used to browse, for example, Chrome, Explorer, Mozilla, etc.) where they are stored before being re-transmitted to the same websites during subsequent visits. During the navigation, the user can also receive on his computer cookies from websites or web servers other than the one he / she is visiting (so-called “third-party” cookies). Specific information is given in the sections of the website set up for particular services, also accessible after registration, where personal data are requested to the user. It is possible to distinguish technical cookies, which allow the carrying out of activities closely linked to the operation of the site and can be used freely, and profiling cookies, used to display advertisements to the user in line with the preferences expressed by the same in the course navigation and for which it is necessary to acquire the user’s consent.
Through this site the user’s browser can receive technical cookies and third-party profiling cookies.

Technical cookies

In particular, technical navigation cookies are used, in order to memorize navigation preferences and improve navigation on the site, and analytical cookies (in particular Google Analytics provided by Google Inc. – hereinafter “Google”), that collect, in an anonymous and aggregate form, statistical information on the browsing modes of users (for example, number of pages visited and accesses, time spent on the site), useful to understand in which aspects the website can be improved.
For more information about the processing of data by Google through the Google Analytics service, the user can visit the webpage http://www.google.com/analytics/learn/privacy.html, and read the privacy policy of Google on the webpage http://www.google.com/intl/it/policies/privacy/.
The use of these cookies does not require the acquisition of the user’s consent, which can however decide to disable their use. Furthermore, Google Analytics cookies can be specifically rejected using the appropriate tool provided by Google (https://support.google.com/analytics/answer/181881?hl=it&ref_topic=2919…).

d) Third party profiling cookies

Through some pages of this Website you can also receive in your browser even third-party profiling cookies, for example to allow the display of contents hosted on external platforms and interact with them (eg YouTube) or connected to the Google AdWords service (aimed at displaying to the user, in the course of navigation, announcements based on the websites previously visited). For this reason, when accessing these pages is proposed a banner to inform the user and allow him to give his consent to the receipt of these cookies, closing the banner or clicking on any other element of the page.  Assut Europe does not have access to the information collected from third-party cookies, which are used independently by the operators of the aforementioned services. For more information on how to process the data collected through these cookies users are invited to consult the information notes on privacy provided by the parties who make available this services. In particular, the third-party cookies used on the site are the following:

The user can disable the cookies affixed by the third parties listed above by clicking on the links indicated. If there are no links, you can refer to the following site www.youronlinechoices.com/it/ which allows you to manage user preferences in terms of cookies.

e) How to manage cookies in your browser

The user can set his browser in such a way as to be warned of the presence of cookies and decide whether to accept a specific cookie or to automatically refuse all cookies. Below are the references on how to manage the activation / deactivation of cookies for the main browsers:

If you decide to refuse cookies, it is also possible that some interactive features offered by the Site may not be used, in whole or in part.

 

3.  PURPOSE OF THE TREATMENT

Users’ personal data will be processed for the following purposes:
3.1 allow browsing of the Site and the provision of services made available by the Owner, including the management of the security of the Site;
3.2 fulfill any obligations under applicable laws, regulations or community legislation, or satisfy requests from authorities;
3.3 for the compilation of statistics, without the possibility to trace the identity of the interested party;
3.4 analyze the curricula and re-contact the candidates who submitted their candidacy through the “Work with us” section;
3.5 send, directly or through third-party providers of marketing and communication services, newsletters and communications for the purpose of direct marketing through email, SMS, MMS, push notifications, fax, paper mail, telephone with operator, in relation to products supplied by other companies of the Assut Europe group;
3.6 for the purpose of carrying out profiling activities, by collecting and analyzing information on selections and choices made within the Site, in order to send personalized offers on other products and / or services;
3.7 to communicate / transfer personal data to third companies, such as companies of the Assut Europe Group in order to send newsletters and communications for marketing purposes through email, SMS, MMS, push notifications, fax, paper mail, telephone with operator.

Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.

 

4. LEGAL BASIS AND OBLIGATORY OR OPTIONAL NATURE OF TREATMENT

The legal basis for processing personal data for the purposes set out in section 3.1 is the art. 6.1.b) of the Regulations as the treatments are necessary for the provision of services or for the response of the requests of the interested party. The legal basis for processing personal data for the purposes referred to in section 3.2 is, instead, art. 6.1.c) of the Regulations (“the processing is necessary to fulfil a legal obligation to which the Owner is subject”). The provision of personal data for these purposes is optional, but failure to provide it would make it impossible to activate the services requested.
It should be noted, however, that the treatment referred to in section 3.3 is not performed on the basis of personal data and, therefore, can be freely performed by the Owner.
With specific reference to the purpose 3.4 and the connected analysis of the professional social profiles freely available on the Internet as per section 2.b, the legal basis of the processing is the art. 6.1.f) of the Regulations, that is the legitimate interest of ASSUT EUROPE SpA to verify any risks on the suitability of the candidate to cover the specific open position.
The legal basis for processing personal data for the purposes set out in sections 3.5, 3.6 and 3.7 is art. 6.1.a) of the Regulations as the treatments are based on consent. The consent is optional and can be revoked at any time without any consequence (except for the fact that it will no longer receive marketing communications and / or profiling activities will no longer be carried out). The consent previously granted can be revoked following the instructions provided in Paragraph 8 of this Policy.
For processing carried out for the purpose of sending direct advertising material or direct sales or for carrying out market researches or commercial communications in relation to products or services of the owner similar to those used by the user, ASSUT EUROPE SpA may use e-mail addresses pursuant to and within the limits permitted by art. 130, paragraph 4 of the Privacy Code (Legislative Decree no. 196/2003) and of the provision of the Authority for the protection of personal data of June 19, 2008 even without explicit consent. The legal basis of data processing for this purpose is art. 6, paragraph 1, f) of the Regulations. The possibility of opposing this treatment at any time, initially or in the event of subsequent communications, remains in an easy and free manner also by writing to the addresses indicated in the “Contact” section of this statement, as well as obtaining immediate confirmation that confirms the interruption of this treatment (Article 15 of the Regulations).

5. RECIPIENTS OF PERSONAL DATA

The personal data collected may be shared, for the purposes set out in section 3 of this privacy policy, with:
5.1. subjects that typically act as data controllers pursuant to art. 28 of the Regulations, ie subjects that cooperate with the Owner for the pursuit of the aforementioned purposes, including those delegated to perform technical maintenance activities (collectively “Recipients”); the list of external data processors may be asked to the Owner or to the DPO by writing to the addresses indicated in the “Contact” section of this policy;
5.2. subjects, bodies or authorities to whom it is mandatory to communicate personal data in accordance with the provisions of law or orders of the authorities;
5.3. persons authorized by the Owner, pursuant to art. 29 of the Regulations, to the processing of personal data necessary to carry out activities strictly related to the provision of services, which are committed to confidentiality or otherwise have an appropriate legal obligation of confidentiality.
The updated list of subjects that may process personal data, as data controllers is available, by sending a written request to the Owner at the addresses indicated in the “Contact” section of this policy.

6. TRANSFER OF PERSONAL DATA

Regarding the possible transfer of data to countries not belonging to the European Economic Area, the Owner informs that the processing will take place according to one of the methods permitted by the law in force, such as the consent of the interested party, the adoption of Standard Clauses approved by the European Commission, the selection of subjects adhering to international programs for the free circulation of data (eg EU-USA Privacy Shield) or operating in countries considered safe by the European Commission. It is possible to have more information, upon request, from the Owner to the above contacts.

7. CONSERVATION OF PERSONAL DATA

Personal data processed for the purposes set out in section 3.1 will be kept for the time strictly necessary to achieve those same purposes. In any case, as these are treatments carried out for the provision of services, the Owner will keep personal data for the time envisaged and permitted by Italian law to protect its interests. (art. 2946 c.c. and ss.).
Personal data processed for the purposes set out in section 3.2 will be kept until the time required by the specific obligation or applicable law.
Further information regarding the data retention period and the criteria used to determine this period may be requested by sending a written request to the Owner at the addresses indicated in the “Contact” section of this policy.
In any case, the possibility is reserved for the Owner to keep the personal data for the period of time foreseen and allowed by Italian law to protect their interests (art. 2947 c.c.).

 

8.  RIGHTS OF THE INTERESTED

Pursuant to Articles 15 et seq. of the Regulations, the interested party has the right to ask Assut Europe, at any time, to access its Personal Data, the correction or cancellation of the same or to oppose their treatment, request the limitation of processing in the cases provided for by art. 18 of the Regulations, as well as obtaining, in a structured format, in common use and readable by automatic device, the data, in the cases provided for by art. 20 of the Rules.
Requests must be sent in writing to the Owner or to the DPO at the addresses indicated in the “Contact” section of this policy.
In any case, the interested party is always entitled to propose a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulations, if it considers that the processing of its Personal Data is contrary to the law in force.

9. MODIFICATIONS

The Owner reserves the right to modify or simply update the content of this policy, in part or completely, also due to changes in the applicable legislation. The Owner therefore invites its users to regularly visit this section to take cognizance of the most recent and updated version of the privacy policy in order to be always updated on the data collected and on the use made of it by Assut Europe.

To exercise the above rights or for any other request it is possible to write to the Owner at the address indicated above or through the dedicated contacts privacy@assuteurope.com and, to contact the DPO, privacy@assuteurope.com, preferably inserting the wording “Request exercise of privacy rights” in the communication object.

 

Document updated to 25 May 2018