Introduction

This policy on the treatment of personal data (see ‘Policy’ below) exists in compliance with article 13 of UE Regulation 679/2016 (General Data Protection Regulation – see ‘GDPR’ below).

The circular describes how and for what purposes your personal data will be handled during your navigation of the site www.engitel.com (see ‘Website’ below) and the use of various functions and services that occur within the site.

In this policy, the terms ‘you’ and ‘your’ refer to the user of the site and its relative functions/services in their capacity as an interested party in the handling of personal data.

A) Holder of the Personal Data Treatment

The official Holder of the treatment of your personal data is Engitel S.p.A (see ‘Holder’ below).

You are entitled to speak to the Holder for questions, requests or clarifications relating to this policy or the general handling of your personal data, using the following contact details:

  • Email address (subject: ‘Privacy’): privacy@engitel.com
  • Address: Via Zarotto 6, Milan
  • Telephone: 02 6693337

B) Personal Data Categories

The holder deals with the following categories of personal data during your navigation of the site and the use of its relative functions/services:

  1. information and data relating to your navigation of the site and the devices that you use to navigate the site and use its functions and services (such as but not limited to: information relating to the pages and sections of the site that you visit, your activity on the site, the time you spend on individual pages and sections of the site, your IP address, the browser you’re using, the type of device used and data concerning your geographical position on the condition that you have previously agreed to such treatment - information due to Cookies or similar tools issued by pages of the site);
  2. Should you wish to receive a demo of our products through filling in the relevant form in the ‘Products’ section of the site (or through communication with the Holder), personal data and information will therein be requested to send the contact request and manage your communication (such as but not limited to: name, surname, email address for potential replies but excluding the content of the information or request that you are submitting).
  3. Should you wish to respond to job offers displayed on the site using the email address given, personal data and information will therein be requested for managing your communication (such as but not limited to: name, surname, email address for potential replies but excluding the content of the information or request that you are submitting).
  4. Should you wish, for any reason, to contact our company using the email address given, personal data and information will therein be requested for managing your communication (such as but not limited to: name, surname, email address for potential replies but excluding the content of the information or request that you are submitting).
  5. In the case of possible interaction, on your part, between the content of the site and your social media networks (likes or tweets, for exampl, data and information concerning the relevant profiles will be processed.

Furthermore, and more generally, the Holder may process the following categories of personal data collected outside the site.

  1. Information and personal data taken from tickets (both electronic and non-electronic), gathered from interested or third parties
  1. Information and personal data acquired at events and meetings according to the appropriate policy made available for an interested party when the information is gathered.
  1. CVs acquired (even non-electronic versions), for the same reasons as seen in c) above

Personal data such as that referred to in category a) are gathered automatically by the Holder during your navigation of the site. This information is not collected with any intent to identify users, but, by its very nature, could, through processing and links with data possessed by third parties, enable the identification of the user. In any case, this data is only used to obtain statistical information of an anonymous nature on the use of the site to monitor that it is working properly.

Personal data as referred to in every other category is provided directly and intentionally by you..

C) Outcome of Not Providing Personal Data

The treatment of personal data such as that referred to in category a) in the previous section is necessary for the Holder in order to guarantee you an optimal navigation experience and to offer you all of the site’s functions and services. It is, however, possible to limit the handling of such personal data by utilising certain functions made available by the site (with reference, in particular, to use of Cookies and similar tools – refer to the site’s Cookies policy) or by your device or browser/navigation application. In such a case, the navigation of the site could be limited and some of its functions or services could be inaccessible.  

For the treatment of personal data from categories other than a), it is necessary to fulfil contractual obligations (meaning to agree to you accessing and using specific functions/services of the site such as but not limited to receiving a demo) and laws (with reference to the execution of standard obligations at the Holder’s expense); consequently you are obliged to provide the aforementioned personal data in order to use certain services and functions of the site as they are requested.

Should you not provide the above data, it will not be possible for the Holder to provide the functions and services of the site that you have requested.

D) Purpose of Data Handling and Relevant Legal Bases

Your personal data will be handled for the following purposes and according to the following legal bases.

 

Purpose

Legal Base

  1.  

To allow navigation of the site, access to its pages and sections, use of its functions and services (therein including interaction with social network profiles)

Necessary on a contractual basis (art. 6(i)(b) GDPR)

  1.  

 To allow your request for product demos 

Necessary on a contractual basis (art. 6(i)(b) GDPR)

  1.  

To take in your replies to our job offers by means of the email address offered and/or forwarding a hard copy of an interested party’s CV

Necessary on a contractual basis (art. 6(i)(b) GDPR)

  1.  

To allow the Holder to take in requests put in by administrative, jurisdictional or public security authorities (such as but not limited to: the laws of art. 210 c.p.c and 248 c.p.p)

Necessary for the fulfilment of legal obligations to which the Holder is subject (art. 6(i)(c) GDPR)

  1.  

To allow the holder to assess, check or protect their rights in a legal or non-legal setting or in any case in the event of a dispute or controversy (instituted by you, the Holder, a third party or a legal or administrative authority)

Necessary for pursuing the legitimate interests of the Holder (art. 6(i)(f) GDPR)

  1.  

To check that the site is working correctly to make changes or updates and provide an optimal navigation experience

Necessary for pursuing the legitimate interests of the Holder (art. 6(i)(f) GDPR)

  1.  

To allow the Holder or a third party responsible for this to check the correct navigation of users on the site

Necessary for pursuing the legitimate interests of the Holder (art. 6(i)(f) GDPR)

  1.  

To allow the Holder to get in touch with an interested party following the latter’s request (shown in the buying of tickets, processing of data at events and meetings etc.)

Necessary for pursuing the legitimate interests of the Holder (art. 6(i)(f) GDPR)

With specific reference to the purposes declared in numbers 5,6 and 7, the following must be specified:

 

Purpose

Pursuing of Legitimate Interests

  1.  

To allow the holder to assess, check or protect their rights in a legal or non-legal setting or, in any case, in the event of a dispute or controversy (instituted by you, the Holder, a third party or a legal or administrative authority)

It is in the Holder’s interests to defend their rights in cases of controversy

  1.  

To check that the site is working correctly to make changes or updates and provide an optimal navigation experience

It is in the Holder’s interests to improve the site to provide users with an optimal navigation experience

  1.  

To allow the Holder or a third party responsible for this to check the correct navigation of users on the site and/or the correct working of transactions executed

It is in the interests of the Holder to defend themselves from fraud, malicious intent or wrongful actions by users of the site

  1.  

To allow the Holder to get in touch with an interested party following the latter’s request (shown in the buying of tickets, processing of data at events and meetings etc.)

It is in the interests of the Holder to take in requests from potential partners, clients or people interested in their products or services.

Should you want more (or more specific) information concerning the above assessment of the Holder regarding the balance between legitimate interests pursued and interests or rights and the fundamental freedoms of interested parties, you can contact the Holder using the contact details in section A.

E)    Categories of Personal Data Recipients

In order to fulfil the purposes laid out above, your personal data will be handled even by third parties that are not the Holder.

Such parties will handle your personal data both on behalf of the Holder (thus, managing it) and as independent holders (upon appropriate communication from the Holder).

Specifically, the following categories of recipients will handle your personal data:

    1. Service providers necessary for the correct working of the site and its functions/services (such as but not limited to: ICT service providers, hosting service providers, platform providers and data processing applications);
    2. Legal, administrative and/or public security authorities in conformity with legal arrangements with the aim of investigating and pursuing illicit activities, preventing and safeguarding against risks and threats to security and public order as well as any reasons linked to the protection of the rights and freedoms of individuals.

Should you wish to familiarise yourself with the particulars of all the recipients listed above, you can contact the Holder using the contact details in section A.

F)   Transferring Personal Data Outside the European Economic Area

Personal data transferred out of the European Economic Area will only be transferred to countries that guarantee an adequate level of personal data protection, on the basis of a judgement of suitability by the European Commission (for example, the United States).                                                    
In the event of a transfer to countries outside the European Economic Area that do not guarantee an adequate level of personal data protection, the transfer will only take place:

  1. Upon adoption of appropriate guarantees (such as but not limited to: the signing of data transfer agreements that embody the standard contractual clauses approved by the European Commission);
  2. Should it be necessary for the conclusion of a contract or the fulfilment of contractual obligations between you and the Holder
     

In any case, should this eventuality occur, the Holder will take care to provide you with, along with your actual request, detailed information regarding the method of transferring data to third countries, the eventual appropriate measures taken and the ways to obtain copies of the data or the place in which it has been made available.

G)    Periods of Storing Personal Data

Your personal data will be stored for a period of time that depends on the type and purpose of the data handling. At the end of the storing period, personal data will be deleted or made irreversibly anonymous. Personal data storing periods are laid out below:

  1. Data relating to your navigation of the site and/or the devices that you use, except in cases where this is used for investigating responsibility in cases of hypothetical offenses or damages of the site or third parties, will be stored for no more than 7 (seven) days;
  2. Data relating to commercial transactions carried out on the site (therein including payment data) will be stored until the conclusion of every administrative, fiscal or civil stage (such as but not limited to: the deadline for withdrawal or contesting a payment). Data relating to billing will be stored for 10 (ten) years;
  3. Data relating to your registration to a restricted area will be stored until you make a request to delete your account (or a potential other recognised right will take over from the regulations in force);
  4. Data and information relating to contact between you and the Holder will be stored until the requests have been completed;
  5. Data relating to the passing on of commercial communication (including from third parties that are commercial partners), market research and statistical studies carried out upon the permission of the interested party will be stored until the interested party exercises their right to oppose this or the data is deleted (also through selection of the appropriate function in communication – unsubscribe link);
  6. Data relating to the passing on of commercial communication (including from third parties that are commercial partners), market research and statistical studies carried out upon the permission of the interested party will be stored until the interested party exercises their right to oppose this or the data is deleted (also through selection of the appropriate function in communication – unsubscribe link) or once two (2) years have passed since your last interaction with the site.

If, at the end of the period above, personal data must be used for specific purposes (for example, for the protection of the rights of the Holder in the event of a contention), it will be stored until the conclusion of said purposes (for example, until the end of the contention).

At the end of the periods laid out above your personal data will be deleted or made unintelligible to the Holder.

H)    Treatment of Personal Data through Automated Decision-Making Processes

Handling of your personal data through automated decision-making processes (therein including profiling in compliance with the laws in art. 22, paragraphs 1 and 4 of the GDPR) is not anticipated.

I)    Your Rights regarding the Treatment of Personal Data

You are entitled to request access to the personal data that concerns you from the Holder, in compliance with art. 15 GDPR.

In the exercising your rights, you may request information about:

  • The purpose of the data handling;
  • The personal data categories in question;
  • The recipients or the categories of recipients to whom personal data has been or will be communicated in particular if the recipients are third countries or international organisations;
  • Where possible, the anticipated personal data storing period or, where this is not possible, the criteria used to determine said period;
  • The existence of the right to ask the Holder to modify or delete personal data or the limitation of the handling of personal data that concerns you or opposing said handling;
  • The right to make a complaint to a supervisory authority;
  • All information regarding the sources of personal data not gathered from you yourself;
  • The existence of an automated decisionmaking process, including the profiling in art. 22, paragraphs 1 and 4 of the GDPR and, at least in such cases, any significant information on the reasoning used as well as the estimated importance and consequences of such data handling for you.

You are also guaranteed the following rights:

  1. The right to revoke your permission, in compliance with art. 7(3) GDPR, without jeopardising the legality of data handling that has already occured and the legality of data handling that occured on another legal basis;
  2. The right to obtain from the Holder the correction of inaccurate data or the integration of incomplete personal data, in compliance with art. 16 GDPR;
  3. The right to obtain from the Holder the deletion of personal data, in compliance with art. 17 GDPR. The exercising of this right could be not guaranteed by the Holder (or the Holder could only partially recognise requests) insofar as the handling of personal data the deletion of which has been requested is required to fulfil legal obligations and investigations or the exercising or the defence of a right in a legal setting;
  4. The right to obtain from the Holder the limitation of data handling, in compliance with art. 18 GDPR;
  5. Within the limits envisaged by the regulations, the right to obtain from the Holder the portability of personal data handled following your permission or on a contractual basis in compliance with art. 6, paragraph 1, letters a) and b) of the GDPR; in the event of the exercising of this right, it will be the responsibility of the Holder to provide you with all the data that concerns you, acquired with your permission or in execution of contractual obligations, in a structured and interoperable format; where it is technically possible, said personal data can be transferred, in the same way, even to third parties chosen by you and indicated using the appropriate request.
  6. The right to oppose the handling of your personal data, in compliance with art. 21 GDPR, except for if the Holder shows, upon receiving such a request, the existence of legitimate, cogent reasons to proceed with the data handling which surpass your interests, rights and freedoms, or for the investigation, exercising or defence of a right in a legal setting.

The requests above must be sent using the contact details in section A.

The Holder will take steps to process requests without unjustifiable delay.

With specific reference to the right to revoke permission, this can be exercised even through selecting the relevant functions made available at the foot of every communication of a commercial nature (or relating to participation in market or statistical research).

In the event of a negative, delayed or unsatisfactory response or no response at all to your requests, or in any case should you maintain that the Holder is treating your data in an illegitimate or non-transparent way, you can liaise with a supervisory authority.

If you are an Italian citizen, reside in Italy, work in Italy, or maintain that the alleged violation by the Holder of your personal data took place in Italy, you can liaise with the Guarantor for the Protection of Personal Data -www.garanteprivacy.it – to obtain adequate protection of your rights.

If you are a citizen of another EU member state, reside in or work in another EU member state or maintain that the alleged violation by the Holder of your personal data took place in another EU member state, you can consult the following web page http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm for more information about the relevant supervisory authority.

J)    Policy Changes or Updates

Should the policy be modified or supplemented, the Holder will make every reasonable effort to inform interested parties of said modifications (for example, by means of specific communication with users signed up to any reserved areas, or through relevant communication – in the form of a banner or a similar tool – on the site’s homepage).

We invite you, however, to periodically check the section of the site in which the policy is displayed and to consult the most recent version (when the policy came into effect is written in the epigraph).