INFORMATION NOTE ON THE PROCESSING OF PERSONAL DATA ART. 13 REGULATION (EU) 2016/679
Please note: personal data encompass any information concerning a natural person (herein, “Interested party”) that may be identified or identifiable, even indirectly.
Angelini Design is committed to protecting and safeguarding the personal data of its Clients and of the Users of its Website (http://www.angelinidesign.com/it/), fully respecting security and transparency criteria, and to protect the information gathered, according to principles of lawfulness and data minimization. Users’ data will be processed using both electronic and manual tools, taking all safety measures to guarantee their confidentiality and integrity.
1. Data processed via the Website
a. Website navigation data
The computer systems, cookie technology and software procedures used to operate the Website acquire certain personal data whose transmission is implicit in the use of Internet communication protocols and in navigating the Website.
Although not collected to be associated with identified subjects, by their very nature these types of information – such as IP addresses – could allow for user identification through processing with other third party data.
b. E-mail address and other personal data
The Website does not require users to register to access or send forms containing personal data.
The “Contacts” section of the Agency’s various offices provides a list of e-mail addresses users can contact to request information or communicate with the company.
By e-mailing such addresses, Users may spontaneously provide some personal data, such as their name, telephone number, home address, e-mail address, etc.
In this case, Angelini Design will be able to collect and process the information that the Interested party has voluntarily provided. This information will be processed for purposes related to the communication itself and to the fulfillment of requests made by the User; data will be stored for a maximum period of 18 months.
If the aforementioned e-mail addresses are used to submit applications and résumés, these documents will be processed for purposes related to the examination, evaluation and selection of candidates, and for possible job offers.
c. Third-party data provided by the Interested party
Should the e-mail communications addressed to Angelini Design contain other parties’ personal data, the User who sent such personal data to the Agency will be considered the Data Controller regarding them, and will consequently assume all legal obligations and responsibilities towards the “interested third parties”.
2. Purposes of processing, legal basis and consent
Angelini Design will process the data Users provide for the following Service purposes:
– to allow the Website to function and to allow Users to browse the Website;
– to carry out the maintenance and technical assistance that is necessary to ensure the Website and the services connected to it are working properly, including any implementation also for new functionalities;
– to give feedback to requests by Users and by those who spontaneously send their personal data;
– to allow Angelini Design s.r.l. to exercise its rights in court and to repress any unlawful conduct.
The legal basis for processing personal data for these purposes is art. 6, par.1, letters b) and f) of the GDPR, as the processing is necessary for the provision of a services, the navigation of the Website, or for the pursuit of the Data Controller’s legitimate interest.
Furthermore, pursuant to art. 6, par. 1, letter c) of the GDPR, the Data Controller may process the data in order to fulfill any obligations determined by the laws in force, by regulations or by European legislation, or to satisfy requests made by the authorities.
Pursuant to art. 6 of the GDPR, said purposes do not require the User’s express consent. Providing personal data is not mandatory, but refusing or requesting cancellation may result in the inability to browse the Website and/or in the inability to receive feedback or information from the company.
3. Data processing methods
Users’ data are processed by means of the activities set forth in art. 4, n. 2) of the GDPR and in particular: collection, registration, organization, structuring, storage, consultation, processing, adaptation, selection, extraction, comparison, access, use, interconnection, communication, cancellation and destruction of data.
Users’ data are processed using automated and non-automated tools, only for the time strictly necessary to achieve the purposes for which they were collected and, in any case, no longer than 24 months from their collection for the purposes of Service, except for longer periods of conservation required by legal obligations and/or imposed by the Authority and any exceptions pursuant to art. 5, par. 1, letter f) of the GDPR.
Any résumés sent will be kept for a maximum period of 18 months, if the company deems it useful to maintain the documents for future job openings that might be in line with the candidates’ characteristics.
4. Recipients of the data
Data access may be made granted, exclusively for the purposes mentioned above, to the following subjects:
– employees and/or collaborators of Angelini Design s.r.l. or of its associated, controlling, controlled, investor or investee companies, as well as those who, for whatever reason – and therefore independently of the type of relationship – have access to personal data processed on behalf of the Data Controller in their capacity as persons entrusted and/or internal data processors and/or system administrators; – third-party companies or other subjects (by way of example: associations or professional firms that provide services and consultancy services to Angelini Design s.r.l., and in particular but not exclusively the Agency’s IT system management suppliers, telecommunication networks and providers) in their capacity as external data processors.
Angelini Design s.r.l. may communicate Users’ data to Supervisory Authorities, Judicial Authorities or Law Enforcement Agencies, who will process them, at their express request, as independent data controllers for institutional purposes and/or by law, as well as to all other subjects to whom data must be communicated by law in order to accomplish said purposes, without requiring the Users’ express consent, as provided by art. 6, par.1, letter c) of the GDPR.
User data will not be disseminated.
5. Data transfer
Data management and storage will take place on servers located within the European Union, belonging to Angelini s.r.l. and/or to third-party companies entrusted and duly appointed as Data Processors. The data will not be transferred outside the European Union.
In any case, where necessary, the Agency will have the right to move the location of the servers in Italy and/or in the European Union.
Should the data be transferred onto servers located in non-EU countries, the Agency ensures that said transfer will take place in accordance with the provisions of the law, through agreements that guarantee an adequate level of protection and/or
standard contractual clauses provided at the European level.
6. Rights of the Interested parties
Users and Interested parties have the right to exercise the following rights:
– Right of access: in particular, interested parties have the right to obtain from the Data Controller confirmation of the existence (or not) of their personal data, to access all relative information, and to obtain a copy of it (art. 15 of the GDPR ).
– Right to rectification of personal data, or to their integration if they are incomplete (art. 16 of the GDPR).
– Right to be forgotten: the right to have data cancelled for any one of the reasons listed in art. 17, subsection 1 of the GDPR, and in compliance with the exceptions as per art. 17, par. 3 of the GDPR.
– Right to limit processing if any of the reasons provided for by the GDPR occur (art. 18 of the GDPR).
– Right to data portability: the right to receive personal data concerning the User in a structured, common-use format, and to transmit such data to another data controller (art. 20 of the GDPR).
– Right to object to processing: in whole or in part, at any time: a) for legitimate reasons, of all personal data, except as provided for the Data controller in art. 21, par. 1 of the GDPR; b) of personal data for purposes of direct marketing, including profiling related to such marketing (art. 21 of the GDPR).
– Right not to be subjected to a decision based solely on automated processing, except as provided for in art. 22, par. 2 of the GDPR.
– Right to file a complaint with the Supervisory Authority. The Italian Supervisory Authority is the Data Protection Authority (Garante per la protezione dei dati personali –http://www.garanteprivacy.it/).
7. How to exercise rights
To exercise the rights referred to in the previous article, the Interested party may, at any time, contact Angelini Design s.r.l by sending:
– an e-mail at firstname.lastname@example.org;
– a registered letter addressed to the Data Controller, Angelini Design s.r.l., Via del Colosseo 23, 00184 Rome, FAO Data Processor.
The complete and updated list of data processors is kept at the Agency’s headquarters.
8. Updates on the information on personal data processing
The present information note is subject to revisions and changes, also due to adjustments to regulatory changes. At every access, Users will be able to refer to the updated version.