- CONTENT OF LEGISLATIVE DECREE N. 231/01
With the utmost clarity and transparency we want to explain:
- what personal data we process and why we need to do so;
- what personal data are processed by third parties and the reason;
- the rights who surf the site and how to exercise them;
- our commitments.
THE OWNER OF YOUR PERSONAL DATA PROCESSING
Information according to and for the purposes of art. 6, EU Regulation no. 679/16, to articles 13-14, EU Reg. 2016/679 (hereinafter, GDPR).
The EU Regulation for the protection of personal data n. 679/16 has the purpose of ensuring that the processing of your personal data is carried out in compliance with the rights of fundamental freedoms and the dignity of persons, with particular reference to confidentiality and personal identity. Therefore, it is our duty to inform you about our privacy and data confidentiality management policy.
AZATEC CONSULTING S.r.l. – Registered office: Via Tito Minniti Sn – Section 127 – Lot 53 Santa Margherita di Belice (AG) – Operational office: via Brembo 27, 20139 Milan – Telephone: 02 3663 9440 – as DPO (Data Processing Officer), in the person of its representative legal, informs you, according to and for the purposes of GDPR Articles 13-14, that your data will be processed for the following purposes:
AZATEC CONSULTING S.r.l. assumes to respect and protect the personal data by choice and explicitly provided by you in compliance with the law focused to ensuring the security, accuracy, updating and relevance with respect to the purposes defined in the contrac. The personal data provided by customers are used for the only purpose of executing the signed service contract and are disclosed to third parties only if this is strictly necessary and functional for this purpose. The data is processed by personnel appointed as responsible (contractually designated) for data processing, only when it is needed for the performance of the service.
The DPO inspects personal identification data (name, surname, company name, address, telephone, e-mail – customer data stored and encrypted) – hereinafter “personal data” – supplied by you to advance the request for quotations relating to requested services or checking an applications for a job.
Your personal data are processed:
- without your express permission (according to Article 6, paragraph 1 of the GDPR) for the following service purposes:
- to complete the data collection for the drafting of the offer
- to fulfill the pre-contractual, contractual and tax obligations deriving from existing relationships with the customer
- to carry out the tasks established by law, by a regulation, by community legislation or by an order of the Authority
- to apply some rights, for example the right to defense in Court
- only with your specific and distinct permission (according to Article 7 of the GDPR), for the following marketing purposes:
- to send via e-mail, post and/or text message and/or telephone contacts, newsletters, commercial communications and/or advertising material on products or services and survey of the degree of satisfaction with the quality of services
- to send commercial and/or promotional communications from third parties authorized and controlled by us in terms of privacy via e-mail, post and/or sms and/or telephone contacts.
We would like to point out that if you are already our customers, we will be able to send you commercial communications relating to the services and products similar to those you have already used, unless you disagree.
- Processing methods
According to art. 5 GDPR the processing of your data will be based on principles of accuracy, lawfulness and transparency and can also be carried out through automated methods designed to store, manage and transmit them (by means of the operations indicated in art.4 n.2 GDPR) and will take place through suitable tools to guarantee security and confidentiality through the use of suitable procedures that avoid the risk of loss, unauthorized access, illicit use and dissemination.
Your personal data are subjected to both paper and digital processing.
The DPO will process personal data for the time necessary to fulfill the purposes and in any case for no more than 10 years from the termination of the relationship for the aims of service and obligations imposed by law.
- Communication of data
The data may be disclosed to the other employees and collaborators of the DPO in their position as data processors of the same, as well as may also be viewed by the external party who oversees our IT system and which our structure has appointed as external manager; Your data may also be disclosed to companies and/or professional firms that provide – in outsourcing – assistance, consultancy or collaboration to the DPO, in accounting, administrative, fiscal, legal, tax matters, to public administrations for institutional functions within the limits established by law or regulations and to third party service providers to whom communication is required for the implementation of the activities covered by our services, if we are entrusted with a task that requires their intervention (contractual sub-managers). We inform you that all our suppliers are appointed external sub-managers and subject to a validation and control process in terms of privacy and quality of the services requested.
Without the need for express authorization according to art. 6, paragraph 1 of the GDPR, the DPO may communicate your data for the purposes referred to in art. 2.A) to Supervisory Entities, Judicial Authorities, as well as to those subjects to whom communication is mandatory by law for the achievement of the purposes.
Your data will not be disclosed in any other way.
- Storage times
Your personal data will be kept for the time to carry out the existing relationships between the parties and in any case not for more than 10 years from the termination of the existing contractual relationship for the provision of the service as required by law.
After this retention period, the Data will be destroyed and/or deleted, without prejudice to future communications by the Owner or decisions of authority under the law.
- Data transfer
The data may also be disclosed to suppliers (cloud and/or data store), as data co-owner controllers, who have signed an agreement with our company. These offices – with particular attention to the offices established in non-EU countries – have been given precise operating instructions through contractual clauses which guarantee that the data will be processed in accordance with the principles established in the EU Reg. destination.
The interested party can make use of their rights towards each co-owner Controller.
- Nature of the provision of data and consequences of refusal to respond
The provision of data for the reasons referred to point 2.A) is mandatory. In their absence, we will not be able to guarantee the requested services.
The supplying of data for the purposes referred to point 2.B) is optional. You can therefore decide not to provide any data or to deny the possibility of using data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the DPO.
However, you will continue to be entitled to the Services according to point 2.A).
- Rights of the interested party
You have the right to ask the DPO for accessing data concerning you, their correction or cancellation, the integration of incomplete data, the limitation of their use; to receive the data in a structured format, commonly used and readable by an automatic device; to revoke any authorization given in relation to the use of your data at any time, in whole or in part to the use of the data; to set a complaint with the Authority, as well as to exercise the other rights recognized to you according to Articles 15-22 EU Regulation n.679 / 16.
- Procedures to make use of rights
You can exercise your rights at any time by sending an e-mail to the e-mail address: firstname.lastname@example.org
The interested party has the right to set a complaint with a supervisory authority.
- DPO, responsible
AZATEC CONSULTING S.r.l. – Registered office: Via Tito Minniti Sn – Section 127 – Lot 53 Santa Margherita di Belice (AG) – Operational office: via Brembo 27, 20139 Milan – Telephone: 02 3663 9440
The DPO makes use of internal data processors and external sub-managers appointed to achieve the tasks specified in point 2 (technical purposes related to the provision of the service and commercial purposes).
The updated list of managers, sub-processors, data controllers and recipients of the data is kept at the registered office of the DPO.
This information may be subject to changes. If substantial changes are made to the use of customer data by AZATEC CONSULTING S.r.l., this will notify the user by publishing them with the utmost emphasis on its pages.
- Data acquired by navigation
The computer systems and software procedures of our site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interests, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit 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 operating system and the user’s IT environment. The data could be used to discover responsibility in case of hypothetical computer crimes against the site: except for this possibility, the data on web contacts persist for a time not exceeding that necessary for the purposes for which they are collected and subsequently treated.
- Cookies Policy
What and why they are collected
A “cookie” is a small text file created by some websites to store information on the user’s computer when he accesses the site. Cookies are sent from a web server to the user’s browser and stored on the user’s computer; they are then re-sent to the website at the time of subsequent visits.
- a) technical cookies:
cookies for browsing a website and using its features, such as to allow correct viewing of pages or access to restricted areas. Therefore, disabling these cookies does not allow these activities.
They are not used for other purposes and can be divided into:
- navigation or session cookies, to guarantee the normal navigation and use of the website
- functionality cookies, to allow the user to browse according to a series of selected criteria (e.g. the language) in order to improve the service provided to the user.
- b) performance cookies:
to collect information on the efficiency of a website’s responses to user requests anonymously, for the unique purpose of improving the functionality of the website (e.g. which pages are most frequently visited by the user, and if errors or delays occurred in the delivery of the web pages)
- c) profiling cookies:
focused to gain user profiles and used to send advertising messages in line with the preferences expressed by the user in the context of surfing the net.
- d) third party cookies
by visiting the website www.azatec.com, the user may also receive cookies on his device from sites managed by other organizations (so-called “third-party cookies”): this happens because the site may contain elements such as, for example, specific links to web pages of third-party websites or web services. These cookies can be sent to the user’s browser by third-party companies directly from their websites which can be accessed by browsing the site www.azatec.com
- e) Google Analytics cookies (_utma, _utmz, _gat, _ga, _gid) –
Google Analytics is a web analytics tool that allows a site owner to understand how visitors interact with the same. The Google Analytics tool uses proprietary cookies to monitor visitor interactions with respect to the site that uses its features. These cookies are used to store information, such as the time at which the current visit occurred, any previous visits to the site by the same visitor and the site that reported the web page to the visitor.
They are available at: https: //www.google.com/intl/it/analytics/privacyoverview.html
Use of the visitor’s IP address through Google cookies
Each computer and device connected to the Internet is assigned a unique number as an Internet Protocol (IP) address. Since these numbers are typically assigned in blocks based on country, an IP address can often be used to identify the country, province, and city from which a computer connects to the internet.
Google Analytics collects the IP address of website visitors to provide an indication of their geographical location. This method is known as IP geolocation. Google Analytics does not report information relating to the actual IP addresses of visitors. By using a method known as IP masking, Google Analytics communicates information so that only a part of the IP address is used for geolocation, instead of the full address.
Browser add-on for disabling cookies by Google Analytics
- “Data Protection Officer”, (DPO)
AZATEC CONSULTING S.r.l. has appointed an independent third party to control and design our information and privacy management system. In case of doubts, needs, requests for explanations on privacy, you can provide a detailed explanation of the problem you wish to report to the email email@example.com
The DPO will analyze your requests and, based on the responsibilities assumed, may negotiate in the ways permitted by the regulation.
Questions, complaints, and suggestions
Anyone interested in more information, to contribute with their own suggestions or make complaints or disputes regarding the privacy policies of the company or the way in which the data is processed can write to firstname.lastname@example.org.
WHO IS THE OWNER OF THE PROCESSING OF YOUR PERSONAL DATA
The data controller is Azatec Consulting Srl based in Via Tito Minniti Sn, Section 127 Lotto 53, 92018 Santa Margherita di Belice (Ag)
Operational headquarters: Via Brembo 27, 20139 Milan
Telephone: +39 02 36639440
FOR WHAT PURPOSES WE USE THE DATA OF THE PEOPLE NAVIGATING THE SITE
The personal data collected are used by Azatec Consulting to:
- improve navigation and services;
- allow the provision of services such as newsletters, registration for events, courses and other initiatives organized by Azatec;
- prepare offers and estimations;
- create and planning special offers, promotions and content customized to the needs of the user;
- collect statistical data;
- search and select new staff for open job positions.
IN WHICH CASES THE PERSONAL DATA ARE PROCESSED WITHOUT PRIOR PERMISSION
(Article 6, letters b, c, f, GDPR)
- to carry out the pre-contractual and contractual obligations due to a professional assignment;
- to comply with the provisions of law and regulations (national or community);
- to apply the rights and the possible one of defense in court.
For these activities, the lack of data or any express refusal prevents them from carrying out the assigned task.
IN WHICH CASES ARE PERSONAL DATA PROCESSED AFTER REQUEST FOR CONSENT
(Article 7, GDPR)
- organization of events;
- marketing activities such as promotions or other advertising or simply informative material.
In these cases, providing data is optional. You can decide not to give consent or to withdraw it.
WHAT KIND OF PERSONAL DATA WE PROCESS
- name, surname, company, email, telephone and website in the contact request form
- name and email in the “Contact us” form on the home page;
- name, surname and telephone number for registering for our events and workshops through any platform which can also be accessed through our website;
- in the case of curriculum vitae, all personal data contained and essential for selecting candidates.
WHAT THIRD PARTY SERVICES WE USE, WHAT KIND OF DATA DO THEY COLLECT AND FOR WHAT PURPOSE
To understand what site users like, improve our services and create advertising campaigns that really meet the public, we use the services of Google Analytics, Facebook and LinkedIn.
Some text strings owned by Google, Facebook and LinkedIn are installed on the site and allow users to be monitored anonymously.
Google Analytics provides us with statistics on the use of the site and the Facebook and LinkedIn pixels allow us to set up targeted advertising campaigns.
THE USER’S RIGHTS
The user can ask to be informed about his personal data that we have collected. You can modify it, delete it, or request the end of a given service connected to the data. To do this, the user can contact us at email@example.com
The deletion of some data may result in the discontinuities of services if these data are essential to proceed.
THE COMMITMENTS OF AZATEC CONSULTING Srl TO PROTECT YOUR PERSONAL DATA
We undertake not to disclose to third parties the data that users provide us while browsing the site.
We also undertake to request explicit authorization for each new service in which the processing of personal data is necessary.