- What types of personal data are collected
The Personal Data Protection Policy governs the use and storage of personal data that is processed.SELECTION S.r.l. is the “Data controller” of the personal data that you as an interested party provide us.
The updated list of data supervisors and data processors is kept at the Data Controller’s office.
SELECTION S.r.l. collects the following types of personal data:
- Personal information
- Personal contact information
- Why the data is collected (purpose of treatment)
Your personal data is collected to provide the following services:
- without your express consent (Art. 6 letters b and e of the GDPR), for the following Service related Purposes:
- to enter into contracts for the Data Controller’s services;
- to fulfil the pre-contractual, contractual and tax related obligations resulting from current business relations with you;
- to fulfil the obligations established by law, by a regulation, by EU legislation, or by an order of the Authority;
- to exercise the rights of the Data Controller, for example the right to defence in court;
Please note that if you are already a customer, we may send you business communications relating to our services and products similar to those you have already used, unless you have not agreed to receive these communications.
- without your express consent (Art. 6 letters b and e of the GDPR), for the following Service related Purposes:
- How and where data is processed and stored (processing methods)
The personal data collected (identified in point 1) is processed in the operational offices and accounting offices located in Italy, in Via Fieschi, 20 16121 Genoa. Data storage and archiving takes place in the same offices.
No third party has access to the data, unless specifically required by law to fulfil the purposes indicated.
- For how long data is stored
The processing of your personal data is carried out by means of the operations indicated in art. 4 no. 2 GDPR and more specifically: collection, registration, organization, structuring, storage, consultation, processing, adaptation or modification, selection, extraction, comparison or interconnection, use, communication (by transmission, dissemination or any other provision), limitation, deletion or destruction of data.
Your personal data is processed with the support of the following means:
- paper version
- electronic/IT (management and accounting software, etc.)
Pursuant to Italian law, SELECTION S.r.l. will process personal data and will be required to keep the documents for the time necessary to fulfil the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the Service-Related Purposes and not more than 2 years from the collection of data for Marketing Purposes (or for a shorter period if we are informed that the receipt of such information is not desired) according to the Data Retention Policy.
After these periods, personal data will be irreversibly destroyed.
For more information on the program for the storage of personal data, see the Data Retention Policy.
- Access to data
Your data may be made accessible for the purposes referred to in paragraph 2.A above pursuant to art. 15 of the GDPR:
- to employees and collaborators of the Data Controller, in their capacity as data supervisors or data processors and/or system administrators;
- to third party companies or other subjects (indicatively banking institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) in order to carry out outsourced activities on behalf of the Data Controller, in their capacity as external data supervisors and processors.
- Data communication
Without the need for specific consent (Art. 6 letters b and c of the GDPR), the Data Controller may communicate your data for the purposes referred to in paragraph 2.A above to those subjects to whom such communication is obligatory by law for the accomplishment of the aforementioned purposes (business, accounting and administrative consultants, accounting firms, banking institutions, etc.) and other subjects such as judicial authorities, insurance companies for the provision of insurance services, and Supervisory bodies.
These subjects will process the data in their capacity as independent data controllers.
Your personal data will not be disseminated.
- Data transfer
Personal data is stored on servers located within the European Union.
In any case, it is understood that the Data Controller, if necessary, has the right to move the servers outside the EU. In this case, the Data Controller henceforth ensures that the transfer to a non-EU location will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided for by the European Commission.
- Provision of the data and consequences resulting from the refusal to provide it
The provision of data for the purposes referred to in paragraph 2.A above is obligatory. In its absence, we cannot guarantee the Services indicated in paragraph 2.A above.
The provision of data for the purposes of paragraph 2.B above is optional. You can therefore decide not to provide any data or to subsequently deny the right to process the data already provided: in this case, you will not be able to receive newsletters, business communications and advertising material concerning the Services offered by the Data Controller.
In any case, you will continue to be entitled to the Services referred to in paragraph 2.A above.
- Your rights as an interested party and how to exercise them
In your capacity as an interested party, you have the rights referred to in art. 15 of the GDPR according to the methods and within the limits established by current legislation. You have the right to:
- request confirmation of the existence of personal data concerning yourself (right of access);
- know its origin;
- receive intelligible communication about your data;
- have information about the logic, the methods, and the purposes of the data processing;
- request that the data be updated, corrected, supplemented, deleted, transformed into an anonymous form, or blocked when processed in violation of the law, including data no longer necessary for the purposes for which it was collected;
- receive, in cases of consent-based processing, the data you provided to the Data Controller, in a structured and readable form by a data processor and in a format commonly used by an electronic device;
- file a complaint with the Supervisory Authority.
You can exercise your rights at any time.
Requests should be sent to the Data Controller, by contacting SELECTION S.r.l. through the “Data Access Request Form” or through the e-mail address firstname.lastname@example.org or in writing to Via Fieschi, 20 16121 Genoa, Italy.
If you wish to make a complaint regarding how your personal data was handled, please contact the “Data Protection Officer” at email@example.com or in writing to Via Fieschi, 20 16121 Genoa, Italy.
The Data Protection Officer will examine your complaint and work with you to solve the problem.
If you believe that your personal data has not been handled appropriately according to the law, you can submit a complaint to the Supervisory Authority:
Italian Data Protection Authority (Public Relations Office – URP address: Piazza di Monte Citorio no. 121- 00186 – ROME, Italy; Tel.: +39 06.69677.2917; e-mail: firstname.lastname@example.org, email@example.com; Certified email: firstname.lastname@example.org).
Date: May 25th 2018
Type of data processed
Data voluntarily supplied by users
Optional, explicit, voluntary sending of email to the addresses identified on this website will result in acquisition of the sender's email address, necessary to respond to requests, and any other personal data the sender may include in the message.
Specific summary information will be reported or displayed on the pages on the website corresponding to particular services, available on request.
Optional nature of providing data
Users are free to spontaneously provide their personal data in request forms or provided in contact information in order to request sending of informative materials or other correspondence.
Failure to provide this data may make it impossible to respond to the request.
For the sake of completeness, note that in some cases (though not in ordinary operation of this website) the Authority may request news and information under section 157 of Legislative Decree no. 196/2003 for the purposes of control of personal data processes. In these cases, note that the site administrator is obliged to respond, and will be subjected to administrative sanctions in the event of failure to do so.
Personal data is processed using automated data processing tools only for time strictly necessary to achieve the purposes for which the data was collected.
Specific security measures are observed to prevent data loss, unlawful or incorrect use and unauthorised access.
DATA SUBJECTS' RIGHTS
A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist and to know their content and origin, to check their accuracy and to request integration or updating, or rectification (section 7 of Legislative Decree no. 196/2003).
Under the same section, data subjects are entitled to request erasure, anonymization or blocking of data that have been processed unlawfully, and in all cases to object to their treatment on legitimate grounds.
Requests in this regard should be sent to the Data Controller, identified above.
The content of all e-mails and attachments shall be treated as confidential and intended only for the recipient(s) to whom the e-mail is addressed.
If you receive an e-mail by mistake, please notify us immediately and delete it from your computer. The content of e-mails may not be copied or disclosed. All abusive use of the information contained herein by third parties or parties not identified in the e-mail may be prosecuted under the law. This notice is provided under section 13 of Legislated Decree no. 196 of 30/06/2003 in relation to personal data processing. Data on the user's e-mail address shall be processed for the purposes of sending material providing commercial information; the data will not be disclosed to third parties and will be treated in compliance with the legal requirements of confidentiality and security.
Notice on cookies
Cookies do not record any personal information, and any identifiable data will not be memorised. You may block saving of some or all cookies if you wish; this may, however, compromise the way in which you can use the website and the services offered. To proceed without modifying cookies options, simply continue browsing.
What types and categories of cookie are used, and for what purposes?
Below is an explanatory list.
"Technical" cookies are essential to permit the proper functioning of websites and allow users to browse sites and make use of their features (for instance, by permitting memorisation of previous actions or permitting saving of the user's session and/or performance of other activities strictly necessary for the functioning of websites).
This category also includes "analytic" cookies, which help us to understand how users interact with websites, supplying information on the most recent page visited, the number of sections and pages visited, the amount of time spent on websites and everything that happened during the browsing session, for instance, if there was an error message, helping us to understand the difficulties users may encounter in using websites. This information may be associated with details on the user such as IP address, domain or browser; they will, however, be analysed together with information from other users so that no one user may be distinguished from the others. These cookies are collected and grouped together in anonymous form and allow us to improve site performance.
Lastly, "functional" cookies allow websites to remember users' choices (such as username) for more personalised, optimised browsing. Functional cookies are not essential for the functioning of the website, but improve the quality and experience of browsing. If you do not accept these cookies, the performance and functioning of the website may be inferior, and your access to site content may be limited.
"Targeting" or "profiling" cookies are used to present content more appropriate to the user and his or her interests. They may be used to display targeted advertising, to publish advertising inserts customised on the basis of the user's interests, or to limit the number of times the user sees a given advertisement. They also help to measure the effectiveness of advertising campaigns on websites; the Data Controller may use these cookies to remember the sites the user visited and share this information with third parties, including agencies and advertisers who may use their own cookies to collect information on the activities performed by users on websites.
"Sharing" (or social network) cookies are necessary to permit the user to interact with websites through his or her own account on a social network and are used, for example, to express appreciation and share a website with one's social contacts.
The site uses, or may use, the following types of cookie, or combinations thereof:
- "session" cookies which are memorised on the user's computer for merely technical and functional reasons, to permit transmission of session identifiers necessary to permit safe, efficient browsing of the website; they are deleted when the browser is closed at the end of the "session" (hence the name);
- "persistent" cookies, which are stored on the computer's hard disk until they expire or are deleted by users. Persistent cookies permit automatic recognition of users who come back to the website (or other users who use the same computer).
Third party cookies
How do cookies work, and how can they be deleted?
The operating methods and options for limiting or blocking cookies may be regulated by changing the settings of your internet browser. The majority of internet browsers are initially set up to accept cookies automatically, but users may change these settings to block cookies or be warned whenever cookies are sent to their devices. There are a number of different ways of managing cookies; please refer to the instruction manual or help screen of your browser to determine how to control and adjust settings. Users may change the predefined configuration and disable cookies (block them permanently) by setting the highest level of protection.
Below are the paths to follow to manage cookies on the following browsers:
How to disable third party services' cookies:
Google Analytics services:
Interaction with social networks and external platforms:
- +1 button and Google+ social widgets (Google Inc.):
The +1 button and Google+ social widgets are services for interaction with the Google+ social network supplied by Google Inc.
- Like button and Facebook social widget (Facebook, Inc.):
The "Like" button and Facebook social widgets are services for interaction with the Facebook social network supplied by Facebook, Inc.
- Tweet button and Twitter social widgets (Twitter, Inc.):
The Tweet button and Twitter social widgets are services for interaction with the Twitter social network supplied by Twitter, Inc.
- Pin button and Pinterest social widgets (Pinterest, Inc.):
The Pin button and Pinterest social widgets are services for interaction with the Pinterest social network supplied by Pinterest, Inc.
- Linkedin button and social widgets (Linkedin):
The Linkedin button and social widgets are services for interaction with the Linkedin social network supplied by Linkedin Inc.
- Youtube and third-party services of Google Inc.:
Youtube is a social network for viewing video content managed by Google Inc. and permitting integration of content in your own pages.
- Vimeo of Vimeo, LLC:
Vimeo is a social network for displaying video content managed by Vimeo, LLC and permitting integration of content in your own pages.
Third party cookies are not controlled directly by the Data Controller, and so if you wish to revoke your consent to use of these cookies you must contact the third parties' internet sites or go to the website www.youronlinechoices.com/en/ to obtain information on how to delete or manage cookies on the basis of the browser you use and to manage your preferences regarding third-party profiling cookies.