Website Data Privacy and Approval Policy
Updated to Reg UE 2016/679 (European Regulation Concerning Personal Data Protection)
2. Data Elaboration Holder and DPO’s Identity and Contact Info
Holder: Vega S.r.l. – Via Alcide De Gasperi 16 – 21053 Castellanza VA (Italy)
Contact e-mail: email@example.com
3. Elaborated Data Typology
Generally speaking, visiting and consulting the website does not imply that the user’s personal data will be collected and elaborated, with the exception of navigation data and cookies, as specified later on in this document.
In addition to the so-called “browsing data” (see below), personal data provided willingly by the user when benefiting form the website functionalities or when demanding to use its services, may be made object of elaboration. In accordance to the Privacy Code, Vega may also collect the user’s personal data by third parties when conducting their activities.
3. Navigation Cookies and Data
Cookies are tiny files stored within the user’s computer hard disk. There exist two major groups of cookies — technical cookies and profiling cookies. Technical cookies are necessary for the website to work properly and to allow the user to browse; without them, the user may not be able to properly view the website pages or use certain services. Profiling cookies are used to create a profile of the user in order to send advertising messages according to the user’s preferences as displayed while browsing.
Moreover, cookies may also be classified as:
- “session cookies”, which are immediately erased when closing the browser;
- “lasting cookies”, which are stored within the browser for a determined period of time. They are used, for example, for recognizing a particular device connecting to the website, making user authentication easier;
*“proper cookies”, produced and managed directly by the manager of the website visited by the user;
*“third parties” cookies, produced and managed by other people than the manager of the website visited by the user.
5. Cookies used by the website
This website makes use of the following groups of cookies:
- session and lasting proper cookies, needed to browse the website, for internal security purposes and system administration;
- session and lasting third parties cookies, needed to allow the user to benefit from multimedia elements on the website, such as images and videos;
- lasting third parties cookies, used by the website to send statistical information to Google Analytics, by means of which Vega is able to elaborate statistics about website accesses/visits. Used cookies are for statistical purposes only, and they collect information in aggregated form. By means of two cookies — one “lasting” and the other one “session”, expiring when the browser is closed — Google Analytics keeps a report including at which hour the website visit started and when it ended. Google data collection by means of cookies, and the following data elaboration, can be disabled by downloading and installing a browser plug-in from the following website:
In the following table, it is shown in details which cookies are used on this website.
|Language Selection, Saving of Technical Settings, Session Identification
This website may contain links to other websites (that is, third party websites). Vega does not access or check cookies, web beacons and other user tracking technologies that may be used by third party websites accessed by the user through this website; also, Vega does not check contents and materials published or obtained by means of third party websites and the related personal data elaboration modalities. It expressly disclaims any liability for such eventuality.
6. How to Disable Cookies
Google Chrome: https://support.google.com/chrome/answer/95647
Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies
7. Personal Data Storage
Personal data is stored and elaborated by computer systems owned by Vega and managed by Vega or third party technical service providers; for more information, please see the following “Data Accessibility and Communication Scope” section. Data is elaborated by a specifically authorized staff only, including personnel assigned to carry out extraordinary maintenance operations. Personal data is stored and kept all the time needed to reach the elaboration specific purposes.
8. Data Elaboration Purposes and Methods
Vega may elaborate common and sensitive personal data for the following purposes: to allow the user to benefit from services and functionalities offered on the website, to manage requests and reports from users, to send newsletters, to manage candidacies obtained through the website, etc.
Furthermore, with the user’s further and specific, optional consent, Vega may elaborate personal data for marketing purposes, that is, to send the user — at the indicated addresses — promotional material and/or commercial communications regarding the Company’s services. These communications may be sent either by traditional contact methods/means — such as mails, operator phone calls, etc. — or automated means — such as internet communications, faxes, emails, text messages, smartphone and tablet applications (APPS), social network accounts (such as Facebook or Twitter), automatic operator phone calls, etc.
Personal data is elaborated both in paper and electronic form, and put into the company informative system according to Reg. UE 2016/679 and security and confidentiality profiles, and inspired by principles of correctness and lawfulness.
9. Personal Data Security and Quality
Vega undertakes to protect the security of the user’s personal data, complying with the applicable legislation security norms in order to avoid data loss, illegitimate or illegal use of data and unauthorized access to the same, with particular reference to the Technical Disciplinary concerning minimum security measures. Furthermore, the information systems and computer programs used by Vega are configured in such a way as to minimize the use of personal and identifying data; such data is elaborated only to achieve specific purposes pursued from time to time. Vega makes use of multiple advanced security technologies and procedures to promote the protection of users’ personal data; for example, personal data is stored on secure servers, located in specific places with secure and controlled access. The user can help Vega to update their personal data and to keep it correct by communicating any change related to their address, qualification, contact information, etc.
10. Data Accessibility and Communication Scope
User’s personal data may be communicated to:
- all whose right of access to such data is recognized by virtue of regulatory provisions;
- our consultants and employees, as part of their duties;
- all natural and/or legal persons, public and/or private, when such communication is necessary or functional to carry out our activities, in the ways and for the purposes mentioned above.
11. Provision Nature of Personal Data
User’s provision of certain personal data is mandatory to allow the Company to manage communications, requests received by the user or to contact the user themselves to respond to their request. This type of data is marked in red on the relevant field, and in this case provision is mandatory in order to allow the Company to process the request which otherwise could not be processed. On the contrary, collection of not red-marked data is optional: failure to provide such data will not entail consequences for the user.
User’s provision of personal data for marketing purposes, as specified in the section “Data Elaboration Purposes and Methods” is optional, and refusing to provide them will have no consequence. Approval granted for marketing purposes is meant to be extended to sending of communications through automated and traditional methods and/or contact means, as explained above.
12. Rights of the Interested Party
Right to Access
- The interested party has the right to receive a report from the data elaboration manager whether their personal data is being elaborated or not. Should it be, the interested party has the right to obtain access to personal data and to the following information:
- purposes of elaboration;
- concerned personal data categories;
- recipients or categories of recipients whom the personal data have been or will be communicated to, particularly in case they are from third countries or international organizations;
- the provided retention period of personal data or, when not available, the criteria used to determine this period;
- the interested party’s right to request the data manager to rectify or delete their personal data, and to limit or oppose the elaboration of their personal data;
- the right to lodge a complaint with a supervisory authority;
- the existence of an automated decision-making process, including profiling and — at least in such cases — significant information on the logic used, as well as the importance and expected consequences of such elaboration for the interested party.
- In case personal data should be transferred to a third country or to an international organization, the interested party has the right to be informed about the existence of adequate safeguard procedures, according to Article 46 concerning transfers.
- The data manager may provide a copy of the personal data being elaborated. Should additional copies be requested by the interested party, the data manager may charge a reasonable fee contribution based on administrative costs. If the interested party submits the request by electronic means – and unless otherwise indicated by the interested party — information will be provided in a commonly used electronic format.
- The right to obtain a copy — as referred to in paragraph 3 — shall not affect the rights and freedoms of others.
Right to Amend
The interested party has the right to request and obtain from the data manager the correction of inaccurate personal data which concern them, without undue delay. Taking into account the purposes of elaboration, the interested party has the right to obtain the integration of incomplete personal data, also by providing an additional declaration.
Right to Cancellation (“Right to Be Forgotten”)
- The interested party has the right to obtain from the data manager the cancellation of personal data which concerns then, without undue delay. Moreover the data manager is obliged to delete such personal data without undue delay if one of the following reasons exists:
- personal data is no longer necessary to achieve the purposes for which they had been collected or elaborated;
- the interested party recalls the consent on which the elaboration process was based, in accordance with Article 6 (1) (a) or Article 9 (2) (a), and in case there is no basis for elaboration;
- the interested party opposes the elaboration process — according to Article 21 (1) — and there is no legitimate overriding reason to proceed with the elaboration, or in case the interested party opposes the elaboration process according to Article 21 (2);
- personal data has been processed unlawfully;
- personal data needs to be deleted to fulfill a legal obligation of the Union or Member State Law, to which the elaboration manager is subject;
- personal data has been collected in relation to the information society service offer referred to in Article 8, paragraph 1 of EU Reg. 2016/679
- In case the data elaboration manager had made personal data public — and he/she is obliged to delete it according to paragraph 1, taking into account available technologies and implementation costs — he/she must take reasonable steps — including technical measures — to inform the other data managers who are processing such personal data of the interested party’s request to delete any link, copy or reproduction of their personal data.
- Paragraphs 1 and 2 shall not apply in case data elaboration is necessary:
- to exercise the right to freedom of expression and information;
- to fulfill a legal obligation that requires elaboration according to the Union or Member State Law to which the data elaboration manager is subject, or for the proper performance of a task carried out in the public interest or as part of an official authority position to which the data manager is assigned;
- for public interest reasons in the field of public health, according to Article 9 (2) (h) and (i) and Article 9 (3);
- for archiving purposes carried out in public interest, for scientific or historical research or for statistical purposes, according to Article 89 (1), insofar as the right referred to in paragraph 1 risks making it impossible or may seriously affect the achievement of the purposes of such elaboration; or
- to assess, exercise or defend a right in court.
Right to Restricted Elaboration
- The interested party has the right to request of the data manager to restrict the elaboration process, and to obtain such limitation, when one of the following hypotheses occurs:
- the interested party disputes the accuracy of their personal data, for the period of time needed by the data manager to verify the accuracy of such data;
- elaboration is illegal and the interested party opposes the cancellation of their personal data, but asks instead that its use may be restricted;
- although no longer needed by the data manager for elaboration purposes, personal data is necessary for the interested party to verify, exercise or defend a right in court;
- the interested party opposes elaboration in accordance to article 21, paragraph 1, Reg EU 2016/679, as verification of the possible prevalence of the data manager’s legitimate reasons with respect to those of the interested party is pending.
- If the elaboration process is restricted in accordance with paragraph 1, personal data will be elaborated — exception made for storage purposes — only with the consent of the interested party or for establishing, exercising or defending a right in court, or to protect the rights of another natural or legal person or for reasons of significant public interest concerning the Union or a Member State.
- The interesting party, having obtained the elaboration restriction in accordance with paragraph 1, will be previously informed by the data manger when the restriction is revoked.
Right to Data Portability
The interested party has the right to receive — in a structured and commonly used form, readable by automatic devices — personal data concerning them and provided to a data manager. Also, the interested party has the right to transfer such data to other data managers without impediments on the part of the first data manager to whom such data had previously been sent if:
1. the elaboration process is based on the interested party’s approval, according to Article 6 (1) (a) or Article 9 (2) (a), or on a contract in accordance with Article 6 (1) b); and if
2. the elaboration process is carried out by automated means.
- In exercising their rights concerning data portability in accordance with paragraph 1, of technically feasible, the interested party has the right to obtain direct transmission of personal data from one data manager to another.
- Exercising the right referred to in paragraph 1 of this Article will not compromise Article 17. This right does not apply to the elaboration necessary for the proper performance of a task carried out in the public interest or as part of an official authority position to which the data manager is assigned.
- The right referred to in paragraph 1 must not affect the rights and freedom of others.
Right to Opposition
- The interested party has the right to object at any given time—for reasons concerning their particular situation—to the elaboration process of their personal data, in accordance to Article 6, paragraph 1, e) or f), including profiling on the basis of such provisions. The data manager refrains from further elaborate personal data unless they can demonstrate the existence of binding legitimate reasons—prevailing over the interests, rights and freedom of the interested party or for establishing, exercising or defending a right in court—to proceed with the elaboration.
- If personal data is elaborated for direct marketing purposes, the interested party has the right to object at any given time to the elaboration process of their personal data for such purposes, including profiling, so far as it is related to such direct marketing.
- If the interested party objects to elaboration for direct marketing purposes, personal data will no longer be elaborated for such purposes.
- The right referred to in paragraphs 1 and 2 will be explicitly brought to the attention of the interested party, and it will be presented clearly and separately from any other information no later than at the time of the first communication with the interested party.
- In the context of using information society services, and without compromising Directive 2002/58 / EC, the interested party may exercise their right to object by making use of automated means using technical specifications.
- Should personal data be processed for scientific of historical research purposes or for statistical reasons, according to Article 89 (1), the interested party has the right to object to personal data elaboration for reasons concerning their particular situation, unless such elaboration process is needed for the performance of a public interest task.
Automated Decision-making Process Concerning Individuals, Including Profiling
- The interested party has the right not to be subjected to decisions based solely on automated elaboration—including profiling — producing legal effects on them or significantly affecting them.
- Paragraph 1 does not apply when the decision:
- is necessary for the conclusion or execution of a contract made between the interested party and the data manager;
- is authorized by the Union or Member State Law to which the data manager is subject, which also specifies proper measures to protect the interested party’s rights, freedom and legitimate interests;
- is based on the explicit approval of the interested party.
- In the instances referred to in paragraph 2 (a) and ©, the elaboration holder has to implement proper measures in order to protect the rights, freedoms and legitimate interests of the interested party — at least the right to obtain human intervention from the elaboration holder, and the right to express their opinion and to challenge the decision.
- The decisions referred to in paragraph 2 are not based on the particular personal data categories referred to in Article 9 (1) — unless Article 9 (2) (a) or (g) applies, and proper measures to protect the rights, freedoms and legitimate interests of the interested party are in force.
Right to Lodge a Complain with a Supervisory Authority
It is acknowledged the interested party’s right to lodge a complaint with a supervisory authority according to art. 77 of the EU Reg. 2016/679
13. Personal Data Communication
Personal data communication is a necessary requirement for concluding a contract. We inform you that you are obliged to provide your personal data, and that failure in communicating such data implies the impossibility of establishing any relationship for work purposes.
14. Elaboration Approval Withdrawal
The interested party has the right to withdraw the approval given to the elaboration process of their personal data by sending a registered letter to the following address: Via Alcide De Gasperi 16, 21053 Castellanza (VA), Italy. This letter must be accompanied by a photocopy of their identity document, with the following text:
Withdrawal of the approval given to the elaboration of all my personal data.
At the end of this operation, the interested party’s personal data will be removed from the archives as soon as possible.
For more information on the elaboration process of personal data, or in order to exercise the rights referred to in paragraph 12, send a registered mail to the following address: Via Alcide De Gasperi 16, 21053 Castellanza (VA), Italy. Before providing or modifying any information, you may be asked to verify your identity and answer some questions. An answer will be provided as soon as possible.
Latest update: October 8, 2018