The declaration herein contains an indication of the regulations and directives which Indel B S.p.a. (hereinafter “Indel B” or “Data Controller”) abides by as regards the personal data processing of users (hereinafter “Users”) of the www.indelb.it website, of which Indel B is the legitimate owner (hereinafter the “Site”) and Data Controller.
This page describes the methods used to manage the site with reference to processing the personal data of the users who consult it. The processing is always based on the principles of correctness and lawfulness in compliance with all the applicable regulations in force and suitable security measures are implemented in order to protect the data. The data processing, which is explained in detail in the policy herein, observes the principles set out in article 5 of Regulation (EU) 2016/679. The site owner therefore confirms that (s)he abides by the principle of accountability.
The policy is also provided in accordance with the provisions of Recommendation no. 2/2001 adopted by the Work group set up by Art. 29 of directive no. 95/46/EC to those who interact with the web services of this site, for the purpose of personal data protection, accessible via the Internet at the address: www.indelb.it. By using any one of our services and/or by accepting the policy herein, for instance as part of a subscription to one of our services, you agree to the collection and use of your personal information as described in the policy herein.
The Site and the services offered by Indel B are reserved for people who are 16 years of age and over. The Controller does not collect data from people aged below 16 and therefore asks Users to refrain from performing subscription activities in the Contact us sections. The Controller undertakes, at the request of Users, to delete promptly all personal data referring to people below the age of 16, which are collected involuntarily.
Type of data processed
The types of data and information collected and processed by Indel B are:
- navigation data (collected automatically);
- data voluntarily submitted by the user;
Computer processing systems and all software procedures used to operate the Site - during normal operation - acquire some personal data whose transmission is implied in the use of Internet communication protocols.
This information is not collected for association with identified data subjects, but may by its nature, through processing and association with data held by third parties, permit the identification of users.
This category of data also includes IP addresses or the domain names of the computers used by users connecting to the website, and other parameters related to the operating system and to the user’s computer environment.
These data items are used only to get anonymous statistical information about the use of the Site and to check its correct operation and are retained for the amount of time strictly necessary for statistical analysis.
The data may be used to ascertain responsibility in the event that computer crimes are committed against the Site.
Data provided voluntarily by the user
Indel B collects the personal data provided voluntarily by users through the Contact us page in the event of:
1. the sending, on the part of users, of e-mail messages with the request for information about the company;
2. the spontaneous sending, on the part of users, of their CV.
Indel B also collects the personal data provided voluntarily by users, through the compilation of the dedicated form, to access the possibility of receiving newsletters.
The data controller is Indel B S.p.a., Via Sarsinate n. 27, S.Agata Feltria (RN), tax code 02037650419.
Purpose of processing
The Data Controller informs the Site Users that the data collected will be processed lawfully in accordance with Art. 6 of the Regulation solely for the following purposes:
a) to implement contracts for the sale or appointment for the provision of services (supply of goods or services) and in general the requests specifically originating from the User;
b) marketing activities, also through the sending of newsletters, MMS or SMS text messages or other types of messages and telephone contacts;
c) market research or other research useful for the improvement of their products or services;
d) collection of CVs for future recruitment;
e) to fulfil obligations set by the law, by competent authorities and by European regulations or standards;
f) the management of company quality certifications.
Legal basis of processing
With reference to the preceding points a) and e), the legal basis of the processing of your personal data is based on the contractual relationship in force with our company, and on the legal obligations inherent to the management of this relationship. Considering Art. 6 para. 1 of Regulation 679/2016, and the general Authorisation of the Italian Data Protection Authority no. 1/2016 of 15/12/2016 – currently still in force - the processing of your personal data, even if particularly sensitive, is not to be considered subject to consent. For the activities referred to in point d), in accordance with the provisions of Italian Legislative Decree no.196 of 30th June 2003 as amended by Italian Law Decree no.101 of 10th August 2018, Art. 111-bis, in the event of receipt of CVs spontaneously sent by the data subjects in order to establish a work relationship, the policy specified in Art. 13 can be provided at the time of the first useful contact, subsequent to the sending of the CV itself. Within the limits of the purposes specified in Article 6, paragraph 1, letter b), of the Regulation (contractual and pre-contractual relationships), consent to the processing of the personal data found in CVs is not due. For the processing referred to in points b), c) and f) a dedicated and separate informed consent is required.
Compulsory or optional nature of data provision and consequences of a possible refusal to provide your consent
The provision of personal data on the part of the User is optional, but it is indispensable, in relation to those data specified as compulsory and marked with a star (*) via the request forms or procedure, since lack of provision thereof would lead to the inability to send requests on the part of the User and to accommodate them on the part of Indel B.
Data processing methods and storage times
The data collected will be processed using manual, computerised or digital tools, observing the purposes for which they were collected and in a manner suitable to guarantee their security and confidentiality. The personal data will be stored for the amount of time required for the specific completion of the purposes specified above, also taking into account the observance of the time frames set by the law for the purposes of the legal protection of the interests of the User and of the Controller.
Scope of disclosure and dissemination of data
The personal data that are provided by the User might be known and used by employees and/or collaborators of Indel B, appointed to manage the Site and the requests of Users, for the sole purpose of providing the activities which make up the reason for which they were collected (for instance, to fulfil contracts for sale or provision of services or for the management of CVs). The data may be disclosed to other parent companies, subsidiaries and/or companies related to Indel B in Italy, in the European Union or to countries outside the EU, provided the legal system in the country of destination or transit of the data ensures a suitable level of personal protection. Suitability will be assessed by comparing the systems of the foreign country with the Italian one.
The personal data of Users may also be disclosed to third parties, appointed to the lawful processing on behalf of the Controller, in their capacity as External Data Processing Officers, for example, and only for example, providers of IT services and other types of services functional to the normal operation of the Site, outsourced service providers or cloud providers and consultants or freelance professionals who assist Indel B for the provision of the services requested or who organise on its behalf the management of commercial and marketing initiatives envisaged as part of the consent received from the User.
The Users, at the simple request addressed to the Controller in the ways disclosed herein above, may obtain a list of the possible External Data Processing Officers.
Existence of an automated decision-making process
There is no automated decision-making process. Your data will not be profiled.
Intention of the Personal Data Controller
The Data Controller will not transfer your personal data to third-party countries or to international organisations.
Rights of the data subject
The User, in his/her capacity as a Data Subject, may exercise the rights contemplated in the Regulation, vis-à-vis Indel B, in regard to the processing activities that concern his/her personal data.
In particular, the Data Subject is entitled to
a) The Right of Access (Art. 15 GDPR). The Data Subject may obtain confirmation as to whether or not personal data relating to him/her are being processed and also access the information about the purpose of processing, the categories of personal data processed, the recipients or categories of recipients to whom the personal data are being or will be disclosed, the envisaged storage period, the existence of a right to request rectification, erasure or restriction of the processing, the right to lodge a complaint with a supervisory authority, the existence of an automated decision-making process, including profiling;
b) The Right of rectification (Art. 16 GDPR) The data subject may obtain the rectification of personal data concerning him/her which are inaccurate and to obtain the integration of incomplete personal data;
c) The Right of Cancellation (right to be forgotten) (Art. 17 GDPR). The data subject may obtain the cancellation of the personal data concerning him/her, if:
i. The data subject revokes the consent provided for the processing of personal data;
ii. The personal data are no longer necessary with respect to the purposes for which they were collected;
iii. The personal data have been processed illegally;
iv. The personal data need to be cancelled to fulfil a legal obligation;
d) The Right to Processing Limitation (Art. 18 GDPR). The data subject may obtain the limitation to the processing of the personal data concerning him/her if:
i. The data subject questions the accuracy of the personal data, for the amount of time necessary for the data controller to check the accuracy of the said personal data;
ii. The processing is illegal and the data subject objects to the cancellation of the personal data and instead requests that their use be limited;
iii. Although Indel B no longer requires them for processing purposes, the personal data are necessary for the data subject to ascertain, exercise or defend a right in legal proceedings;
e) The Right to Data Portability (Art. 20 GDPR). The data subject has the right to receive in a structured, commonly used format that is legible from any automatic device the personal data concerning him/her provided by the Company, and has the right to transmit these data to another Data Controller without impediment on the part of Indel B, should the processing be done with automated means. If technically feasible, the data subject also has the right to obtain the direct transmission of his/her personal data from Indel B to another Data Controller;
f) Right of revocation of the consent provided for the processing of sensitive data. The aforesaid rights may be exercised by sending a request using the contacts provided in the foreword of this policy.
In addition to the rights mentioned above, the data subject may lodge a complaint for any issues concerning the processing of their personal data with the Italian Data Protection Supervisory Authority www.garanteprivacy.it.
Indel B pays particular attention to the right to Privacy and to the protection of the personal data of Users. For any information in reference to the contents of the document herein, the Users may contact the Controller, as follows:
- by registered letter with advice of receipt made out to the Data Controller at Indel B S.p.a., Via Sarsinate n. 27, 47866 S.Agata Feltria (RN)
- by sending an e-mail to email@example.com
- by sending a fax to +39 0541 848 741
The Controller will not be held liable for the update of the links specified in the policy herein. Should these prove not to function correctly, Users may refer to the site sections referred to in the link.