Privacy policy

PRIVACY POLICY

pursuant to art. 13 and 14 of EU Regulation 2016/679 ("GDPR")



This page describes how the site is managed with regard to the processing of personal data of users who consult it.

This privacy policy is provided pursuant to art. 13 and 14 of Reg. EU - European Regulation on the protection of personal data to those who interact with the web services of IEN Industrie S.p.A. accessible electronically from the address:

https://www.ienindustrie.com/

corresponding to the home page of the official website of IEN Industrie S.p.A.

This privacy policy is provided exclusively for this website of IEN Industrie S.p.A. and not for other websites that may be consulted by the user through links.

This privacy policy is also inspired by Recommendation n. 2/2001 that the European authorities for the protection of personal data, gathered in the Group established by art. 29 of Directive No 95/46/EC, adopted on 17 May 2001 to identify certain minimum requirements for the collection of personal data online. In particular, the manner, timing and nature of the information to be provided by the controllers to users when they link to web pages, irrespective of the purpose of the link.

The Recommendation and a summary description of its purposes can be found on the official website of the Data Protection Authority.



1. TO WHOM ARE YOU PROVIDING YOUR DATA? WHO WILL PROCESS THEM?

IEN Industrie S.p.A.

Head office: Via Toniolo, n. 26, 61032 - Fano (PU)

VAT: 01301170419

Tel.: + 39 0721 853711

e-mail: info@ienindustrie.com



2. WHAT DATA DO WE ASK FOR, COLLECT AND/OR PROCESS?

We will ask and/or process the following information:

  • Name and contact details, such as, but not limited to, name and surname, e-mail address, address, telephone number;
  • Account credentials, such as, but not limited to, the password and other security information used for authentication and login;
  • Financial information, such as, but not limited to, bank account, credit and debit card numbers for processing payments;
  • Usage Information, such as, but not limited to, behavioral information about how you navigate our Services and which elements of our Services you most frequently use and information about the products and/or services you wish to order, wish list, preferences, interests and so on. Other information shared by you through our websites, apps, web stores, and other products;
  • Information about your computer, device, and connection, such as, but not limited to, your IP address, browser type, browser version, and location.



3. CAN CHILDREN UNDER THE AGE OF 14 ACCESS THE SITE?

If you are under the age of 13, please do not use or access the Services.

IEN Industrie S.p.A. does not knowingly collect or store personal information (as defined in the United States Children’s Online Privacy Protection Act) about persons under the age of 13.

In the event that IEN Industrie S.p.A. becomes aware that personal information of children under the age of 13 has been collected in the provision of the Services, it will take appropriate action to delete this information.



4. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA? WHAT ARE THE LEGAL BASES FOR OUR PROCESSING?

a) Legal purposes and necessary for the provision of services by IEN Industrie S.p.A. in the context of navigation on the website.

Legal basis: Article 6, par. 1 point b) of the GDPR: " Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”.


b) Personal data will also be processed to fulfil the obligations provided by law, a regulation or by Community legislation and for civil, administrative, accounting and tax purposes.

Legal basis: Pursuant to art. 6, par. 1 point c) GDPR processing for this purpose is lawful in so far as it is necessary to fulfil a legal obligation to which the data controller is subject.


c) Personal data will also be processed for sending promotional communications to advertise products and/or services similar to those previously purchased by the recipient (so called “Soft spam”).

On the basis of current legislation, the Company may use the e-mail address provided by you when purchasing our service and/or service and/or insurance product to offer you products and services similar to those purchased by you. However, if you do not wish to receive such communications, you may give notice at any time to the Company, using the following email address info@ienindustrie.com. The Company, in this case, will without delay interrupt the above mentioned activity.

Legal basis: Article 6, par. 1 point f): "Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child".


d) Finally, personal data may be processed to assert or defend in the competent courts (judicial, arbitration, administrative, etc.) rights of any nature, whether or not they are connected to a contractual relationship for the provision of the services listed above or to other legal terms and conditions of the Site.

Legal basis: Article 6, par. 1 point f): "Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child".



5. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Your personal information will be processed to the extent necessary for the fulfilment of our obligations and for the time necessary to achieve the purposes for which the information is collected, in accordance with our data retention policies and applicable data protection laws.

When we no longer need your personal information, we will take all reasonable steps to remove it from our systems and records or take steps to properly anonymize it, so that you can no longer be identified by it.



6. WHAT IS THE NATURE OF THE PROVISION OF DATA?

Apart from what is specified for navigation data, the user is free to provide personal data in order to be able to access the services offered by this site.

Failure to provide the data necessary to fill in the request forms makes it impossible to access the requested services including the sending of information material



7. HOW DO WE PROCESS YOUR PERSONAL DATA?

We will process your Personal Data by means of manual, computer or telematic tools, and in any case suitable to guarantee its security and confidentiality.

The processing will be carried out by personnel that we have duly instructed and trained as well as contracted.

The processing will take place in compliance with the principle of limitation of the purposes as well as all other principles present in Article 5 of Regulation 679/2016. In particular, in compliance with the principles of integrity and confidentiality, pursuant to which specific security measures are taken to prevent data loss, unlawful or incorrect use and unauthorized access.



8. TO WHOM ARE YOUR PERSONAL DATA COMMUNICATED? WHY? WHERE ARE THEY TREATED? DO WE SPREAD THEM?

For the pursuit of the purposes indicated in point 4, the Data Controller may communicate the User’s personal data to third parties, such as, for example, those belonging to the following subjects or categories of subjects:

  • our service providers, for example for the management or hosting of services and/or for the technology supporting the Services we provide;
  • other parties, for example based on external audit, compliance, risk management, business development and/or corporate governance needs; or
  • governmental and regulatory authorities, as required by applicable law.

In all the cases described above, IEN Industrie S.p.A. will not communicate personal data to external recipients, unless the communication is required by mandatory orders from public and/or judicial authorities. The data will not be disseminated.



9. ARE YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

The data will not be communicated or disseminated to third parties and will not be transferred or processed outside the European Union.

Transfers of personal data to countries outside the European Economic Area (EEA, i.e., EU + Norway, Liechtenstein, Iceland) or to an international organisation are permitted provided that the adequacy of the third country or organisation is recognised by decision of the European Commission (Art. 45 of EU Regulation 2016/679).

In the absence of such a decision, the transfer is allowed where the data controller or the data controller provides adequate guarantees that provide actionable rights and effective remedies for data subjects (Art. 46 of EU Regulation 2016/679). In this respect, appropriate safeguards may be provided:

  • without authorisation from the DPA:

• binding and enforceable legal instruments between public entities (Art. 46, par. 2, point a);

• binding corporate rules (Art. 46, par. 2, point b);

• standard clauses (Art. 46, para. 2, point c and point d);

• the codes of conduct (Art. 46, par. 2, point e);

• the certification mechanisms (Art. 46, par. 2, point f);

  • with the authorisation of the DPA:

• ad hoc contractual clauses (Art. 46, par. 3, point a);

• administrative agreements between public authorities or bodies (Art. 46, par. 3, point b);

In the absence of any other assumptions, it is possible to transfer personal data according to certain derogations that occur in specific situations (Art. 49 of EU Regulation 2016/679).



10. WHICH ARE YOUR RIGHTS?

Pursuant to Articles 13, paragraph 2, points (b) and (d), 15 to 22 of the Rules, we inform the data subject who has the right to ask:

- Right of access: You may obtain from IEN Industrie S.p.A. confirmation that your Personal Data are being processed or not and, in this case, obtain access to the Personal Data and the information provided by art. 15 of the Regulation, among which, by way of example: the purposes of the processing, the categories of Personal Data processed etc.

- If the Personal Data are transferred to a third country or an international organisation, you have the right to be informed of the existence of adequate guarantees relating to the transfer. If requested, IEN Industrie S.p.A. may provide you with a copy of the Personal Data processed. For any further copies, IEN Industrie S.p.A. may charge a reasonable fee based on administrative costs. If the request in question is submitted by electronic means, and unless otherwise indicated, the information will be provided by IEN Industrie S.p.A. in an electronic format in common use.

- Right of rectification: You may obtain from IEN Industrie S.p.A. the rectification of your Personal Data that are inaccurate as well as, taking into account the purposes of the processing, the integration of the same, if they are incomplete, by providing an additional declaration.

- Right to erasure: You may obtain from the Data Controller the erasure of your Personal Data, if there is one of the reasons provided for by art. 17 of the GDPR, including, by way of example, if the Personal Data are no longer necessary for the purposes for which they were collected or otherwise processed or if the consent on which the processing of your Personal Data is based has been revoked by you and there is no other legal basis for the processing. We inform you that IEN Industrie S.p.A. will not be able to erase your Personal Data: if their processing is necessary, for example, for the fulfilment of a legal obligation, for reasons of public interest, for the establishment, exercise or defense of legal claims.

- Right to restriction of processing: You may obtain the restriction of the processing of your Personal Data in one of the hypotheses provided for by art. 18 of the Regulation, among which, for example: in the event of a dispute about the accuracy of your Personal Data subject to processing or if your Personal Data are necessary for the establishment, exercise or defense of a right before a court, although IEN Industrie S.p.A. no longer needs it for processing purposes.

- Right to data portability: Article 20 of the GDPR introduces the new right to data portability. This right allows the data subject to receive the personal data provided to IEN Industrie S.p.A. in a structured, commonly used and machine-readable format, and - under certain conditions - to transmit them to another data controller without hindrance.

The only personal data that (a) concern the data subject are portable, and (b) have been provided by the data subject to IEN Industrie S.p.A.; (c) are processed electronically as part of the conclusion of a contract.

Data portability includes the right of the data subject to receive a subset of the personal data concerning him or her processed by the company and to keep them for further use for personal purposes. This storage can take place on a personal media or on a private cloud, without necessarily involving the transmission of data to another data controller. Portability is a kind of integration and strengthening of the different right of access to personal data, also provided for by art. 15 of the Regulation.

IEN Industrie S.p.A. undertakes to process requests for portability within 30 days of receiving the request, reserving, pursuant to art. 12, paragraph 3 of the Regulation, the power to find the request in the longer term of three months in cases of greater complexity. The request for portability should be addressed to the following specific email address: info@ienindustrie.com

- Right to object: You may object at any time to the processing of your Personal Data if the processing is carried out for the performance of an activity in the public interest or for the pursuit of a legitimate interest of the Data Controller (including profiling activity). If you decide to exercise the right of objection described here, IEN Industrie S.p.A. will refrain from further processing your personal data, unless there are legitimate grounds for processing (grounds overriding the interests, rights and freedoms of the data subject), or the processing is necessary for the establishment, exercise or defense of a right before a court.

- Right not to be subject to automated decisions, including profiling: the data subject has the right not to be subject to a decision based solely on automated processing, including profiling; producing legal effects which affect him/her or which have a similar significant impact on his or her person, unless the automated decision is necessary for the conclusion or performance of a contract between the data subject and a data controller, is provided for by law, in compliance with measures and precautions, is based on the explicit consent of the data subject.

Right to lodge a complaint with the Data Protection Authority: Without prejudice to your right to appeal in any other administrative or judicial venue, if you believe that the processing of your Personal Data by the Data Controller is in breach of the Regulation and/or applicable law, you may lodge a complaint with the competent Data Protection Authority following the procedures and indications published on the Authority’s official website on https://www.garanteprivacy.it/forms-e-services-online/complaint



11. HOW CAN I EXERCISE MY RIGHTS?

You may exercise the above rights by written request addressed to the Data Controller, available at the following e-mail address: info@ienindustrie.com

We will proceed as indicated by you without delay and, in any case, no later than one month after receipt of your request. The deadline can be extended by two months, if necessary, taking into account the complexity and the number of requests we will receive. In this case, we will send you, within one month of receiving your request, a communication to inform you and indicate the reasons for the extension.

We remind you that, where the response to your requests has not been satisfactory in your opinion, you can address and submit a complaint to the Authority for the Protection of Personal Data in the ways provided for by the Applicable Law and following the instructions available at www.garanteprivacy.it.



12. WHERE CAN I FIND THE FORM TO EXERCISE MY RIGHTS?

Click here: https://www.garanteprivacy.it/home/docweb/-/docweb-display/docweb/1089924



13. LINKS TO OTHER WEBSITES

The website contains links to other third-party sites, which have privacy policies other than ours. We are not responsible for the collection, processing or disclosure of personal information collected through other websites.

In addition, we are not responsible for any information or content on such websites.

Your use and browsing of such websites are subject to the specific policies of that website.



14. COOKIES

We use cookies to optimize our websites and analyze website traffic. Sometimes, if we have obtained your informed consent in advance, we may use third-party cookies, especially social media plugins, to allow you to share ideas and information relating to us instantly and for your marketing purposes.

Cookies or similar techniques (collectively referred to as "cookies") are small text or pixel files that may be stored on your computer or mobile device. Cookies may be necessary to facilitate the navigation of the website and make it more user-friendly. Third-party cookies may collect information to analyze personal browsing behavior.

It is possible that cookies belonging to one of the four categories listed below are used. The cookie banner on our website facilitates the management of preferences of non-compulsory cookie categories. The banner also provides an overview of all cookies used in the categories.

  • Technical (or necessary) cookies: these mandatory cookies are necessary for the proper functioning of our websites.
  • Analytical cookies (also called statistical or performance cookies): these cookies support analytical services that help us improve the functionality and experience of users of our website.
  • Profiling (or marketing) cookies: these cookies can be used to collect insights and publish personalized content and advertising on our and other websites.

Additional information about cookies can be found in the "Cookie Policy".



15. UPDATES

The Privacy Policy of the Site may be subject to periodic updates.

Any substantial changes will be published at this address and the user is responsible for periodically monitoring this website to inquire about the validity or modification of these conditions.