Privacy Policy

I – INFORMATION CONCERNING THE PRIVACY POLICY OF THE WEBSITE

  1. This section contains information concerning the management of the website promigroup.com with regard to the processing of the data of users of promigroup.com
  2. This information notice is provided pursuant to and for the purposes of article 13 of Italian Legislative Decree 196/2003, “Code concerning the protection of personal data”, as well as pursuant to and for the purposes of article 13 of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data for data subjects interacting with promigroup.com, and can be reached at the address corresponding to the home page:

www.promigroup.com

  1. The information is provided only for promigroup.com and not for any other websites that may be consulted by the user via links contained therein.
  2. The purpose of this document is to provide information about the methods, timing and nature of the information that data controllers must provide to users when connecting to the web pages of promigroup.com, regardless of the purposes of the connection itself, in accordance with Italian and European laws.
  3. The information may be changed due to the introduction of new relevant regulations; therefore, the user is kindly requested to periodically check this page.
  4. If the user is below the age of 16, pursuant to article 8, paragraph 1, of Regulation (EU) 2016/679, the processing of personal data shall be lawful only if and to the extent that such consent is given or authorised by his/her parents or guardian.

II – DATA PROCESSING

1 – Data Controller

  1. The data controller is the natural or legal person, public authority, service or other body that – alone or jointly with others – determines the purposes and means of processing personal data. The data controller also deals with security profiles.
  2. The data controller for this website is: PromiGroup S.r.l. To receive any explanation, or to exercise the user’s rights, the data controller can be contacted at the following e-mail address: info@promigroup.com

2 – Data Processor

  1. The data processor is the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller.
  2. Pursuant to article 28 of Regulation (EU) 2016/679, concerning the appointment of the data controller, the data processor for the website promigroup.com is: Mr. Piero Antonio Fretto.

3 – Data processing location

  1. The data processing generated by the use of promigroup.com takes place at the headquarters of PromiGroup S.r.l, via Figini 16 Muggiò 20835.
  2. In case of need, the data connected to the newsletter service may be processed by the data processor or any persons appointed by the data processor for such purpose at the relevant site.

III – COOKIES

1 – Type of cookies

  1. The website promigroup.com uses cookies to make the user’s browsing experience easier and user friendlier: cookies are small strings of text used to store certain information that may concern the user, his/her preferences or the device for accessing the Internet (computer, tablet or mobile phone), and are mainly used to adapt the operation of the website to the user’s expectations, offering a more customized browsing experience and storing the choices made before.
  2. A cookie consists of a reduced set of data transferred to the user’s browser from a web server and can only be read by the transferring server. This is not an executable code and does not transmit viruses.
  3. Cookies do not record any personal information, and any identifiable data will not be stored. If desired, you can prevent some or all cookies from being saved. However, in this case the use of the website and the services offered may be compromised. To proceed without changing the cookie options, simply continue browsing.

The following are the types of cookies used by the website:

2 – Technical cookies

  1. Numerous technologies are available to store information on the user’s computer and have it collected by websites, that of HTML cookies being the best known and most widely used. HTML cookies are used for navigation and to facilitate access and use of the website by the user. They are necessary for the transmission of communications over the electronic network or for the supplier to provide the service requested by the customer.
  2. The settings to manage or disable cookies may vary depending on the Internet browser being used. However, the user can manage or request the general deactivation or cancellation of cookies by changing the settings of his or her Internet browser. Such deactivation may slow down or prevent access to certain parts of the website.
  3. Technical cookies allow the website to be used securely and efficiently.
  4. The cookies that are inserted into the browser and retransmitted by Google Analytics or through the statistics service of bloggers or the like are technical only if used for the purpose of optimising the website directly by the owner of the website itself, which can collect information on the number of users and how they visit the website in aggregate form. Under these conditions, such rules as provided for technical cookies will also apply to analytics cookies, in terms of both information and consent.
  5. As far as duration is concerned, you can distinguish between temporary session cookies, which are automatically deleted at the end of the browsing session and are used to identify the user and therefore avoid logging in to every page being visited, and permanent cookies, which remain active in the PC up to expiration or cancellation by the user.
  6. Session cookies may be installed in order to allow access and stay in the reserved area of the portal as an authenticated user.
  7. They are not stored permanently but only for the duration of the navigation until the browser is closed, and disappear when the browser is closed. Their use is strictly limited to transmitting session identifiers consisting of random numbers generated by the server required to allow a safe, efficient exploration of the website.

3 – Profiling cookies

  1. Profiling cookies are designed to create profiles based on the user and are utilized to send advertising messages in line with the preferences expressed by the user while browsing the web.
  2. When these types of cookies are used, the user will be required to give his or her explicit consent.
  3. Article 22 of Regulation (EU) 2016/679 and Article 122 of the Data Protection Code will apply.

IV – PROCESSED DATA

1 – Method of data processing

  1. Like all websites, this website also uses log files where information collected in an automated form during users’ visits to the website is stored. The information that may be collected includes the following:

– internet protocol (IP) address;
– browser type and parameters of the device used to connect to the website;
– name of the internet service provider (ISP);
– date and time of visit;
– the website the visitor visited prior to the website (referral), and the website visited afterwards;
– where applicable, the number of clicks.

  1. The above information is processed in an automated form and collected in an exclusively aggregated form in order to verify the correct functioning of the website, and for security reasons. Such information will be processed based on the legitimate interests of the data controller.
  2. For security reasons (i.e. through spam filters, firewalls, and anti-virus software), automatically recorded data may also include personal data such as the IP address, which could be used, in compliance with applicable laws, to block attempts to damage the website or to cause harm to other users, or in any case to carry out any other form of harmful activity or offence. This data is never used to identify or profile users. The sole purpose of processing is to protect the website and its users. Such information will be processed based on the legitimate interests of the data controller.
  3. If the website allows the insertion of comments, or in case of specific services requested by the user, including the possibility to send the Curriculum Vitae for a possible working relationship, the website will automatically detect and record some identification data of the user, including the email address. Such data is deemed to be voluntarily provided by the user when requesting the service to be provided. By entering a comment or other information, the user expressly accepts the privacy policy; in particular, he or she agrees that the contents thus entered are freely disseminated to third parties as well. The received data will be used solely for the provision of the requested service and only for the length of time necessary for the provision of the service.
  4. Such information as disclosed by the users of the website through the services and tools made available to them is provided by the user knowingly and voluntarily, exempting this website from any liability for breaching the law. It is up to the user to verify that he or she has permission to enter personal data of third parties or contents protected by national and international standards.

4 – Support in the configuration of your browser

  1. The user can also manage cookies through the settings of his or her browser. However, deleting cookies from the browser may remove the preferences set for the website.
  2. For further information and support, you can also visit the help page of the browser you are using:

– Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

– Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences

– Safari: http://www.apple.com/legal/privacy/it/

– Chrome: https://support.google.com/accounts/answer/61416?hl=it

– Opera: http://www.opera.com/help/tutorials/security/cookies/

5 – Social Network Plugins

  1. This website also incorporates plugins and/or buttons for social networks, in order to enable content to be shared easily via your favourite social networks. These plugins have been programmed so that they do not set any cookies when accessing the page, in order to safeguard users’ privacy. Where provided by social networks, any cookies may be set up only when the user voluntarily and actually uses the plugin. Where the user browses while being logged in the social network, then he/she has already consented to the use of cookies conveyed through this website at the time of the subscription to the social network.
  2. The collection and the use of information obtained through the plugin are governed by the respective privacy policies of the social networks, to which you are kindly asked to refer:

Facebook: https://www.facebook.com/help/cookies

Twitter: https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter

Pinterest: https://about.pinterest.com/it/privacy-policy

AddThis: http://www.addthis.com/privacy/privacy-policy

Linkedin: https://www.linkedin.com/legal/cookie-policy

USER’S RIGHTS

  1. Article 13, paragraph 2, of Regulation (EU) 2016/679 lists the user’s rights.
  2. The website promigroup.com therefore intends to inform the user that he or she may exercise the following rights:

– the right to obtain from the data controller access to personal data (Article 15 of the EU Regulation), the right to updating (Article 7, paragraph 3, point a) of Italian Legislative Decree 196/2003), the right to rectification (Article 16 of the EU Regulation), the right to supplementation (Article 7, paragraph 3, point a) of Italian Legislative Decree 196/2003), the right to restriction of processing (article 18 of the EU Regulation), the right to object to processing for legitimate reasons (Article 21 of the EU Regulation), and the right to data portability (Article 20 of the EU Regulation);

– the right to obtain the erasure (Article 17 of the EU Regulation), transformation into anonymous form or blocking of unlawfully processed data, including the data that does not have to be stored in relation to the purposes for which it was collected or subsequently processed (Article 7, paragraph 3, point b) of Italian Legislative Decree 196/2003);

– the right to obtain the attestation that the data updating, rectification, supplementation, deletion, blocking and transformation operations have been brought to the attention – for example, with regard to their content – of those to whom the data has been disclosed or disseminated, except in the case where such fulfilment proves impossible or involves a manifestly disproportionate use of means compared to the protected right (Article 7, paragraph 3, point c) of Italian Legislative Decree 196/2003);

  1. Requests can be addressed to the data controller, without formalities, or, alternatively, using the model provided by the Guarantor for the Protection of Personal Data, or by sending an email to: info@promigroup.com
  2. If data processing is based on Article 6, paragraph 1, point a) – express consent to use – or on Article 9, paragraph 2, point a) – express consent to the use of genetic, biometric, health-related data revealing religion or philosophical beliefs, trade union membership, racial or ethnic origin, political opinions – , the user shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
  3. Likewise, in case of breach of the law, the user shall have the right to lodge a complaint with the Guarantor for the Protection of Personal Data, as the authority in charge of data processing control in the Italian State.
  4. For a more in-depth examination of your rights, please refer to Article 15 and the following articles of Regulation (EU) 2016/679 and Article 7 of Italian Legislative Decree 196/2003.

VI – TRANSFER OF DATA TO NON-EU COUNTRIES

  1. This website might share some of the collected data with services located outside the European Union area. In particular, with Google, Facebook and Microsoft (LinkedIn) through social plugins and the Google Analytics Service. The transfer is authorized and strictly governed by Article 45, paragraph 1, of Regulation (EU) 2016/679, for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.
  2. The data will not be transferred to any third countries that do not comply with the provisions of Article 45 and the following articles of the EU Regulation.

VII. SECURITY OF PROVIDED DATA

  1. This website processes users’ data in a lawful, correct manner, taking all proper security measures aimed at preventing any unauthorised access, any disclosure, any unauthorised change or destruction of data. Processing is carried out using IT and/or electronic tools, in an organised manner and strictly in connection with the above purposes.
  2. In addition to the data controller, in some circumstances, categories of authorised persons involved in the management of the website (administrative, sales, marketing and legal staff as well as system administrators) or external parties (such as third party suppliers of technical services, postal services, hosting providers, IT companies and communication agencies) may have access to personal data.

VIII. CHANGES TO THIS DOCUMENT

  1. This document, published at the address: promigroup.com constitutes the privacy policy of this website.
  2. It may be subject to changes or updates. In case of significant changes and updates, these will be reported through specific notifications to users.
  3. The previous versions of the document will still be available on this page.
  4. The document was updated on 16/06/2018 to comply with the relevant regulatory provisions, and in particular in compliance with Regulation (EU) 2016/679.