Privacy Policy

INDEX

Introduction
Definitions
Background information on the processing of the user’s personal data
Cookies
Rights of the user concerned
How to exercise rights and/or request information on processing
Background Information

INTRODUCTION

Dear user,

This Privacy Policy is provided to you pursuant to Article 13 of EU Regulation 2016/679 – on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter also “the Regulation” or “GDPR”).

In this Privacy Policy you will find information on the processing of your personal data resulting from navigation within web spaces and the use of the services made available to you through the website.

You will be provided with specific and/or supplementary information on the processing of your personal data each time we collect it, during your interaction with the site, or under contractual relationships established with our Company. You can consult all of them at any time by clicking on the links in the “Information” section at the bottom of this page.

Please note that this Privacy Policy does not apply to web services provided by third parties that you may use or consult and access via hypertext links. For these, we invite you to consult the privacy notices and privacy policies provided by these third parties in the appropriate locations.

DEFINITIONS

Privacy Policy: The GDPR, the Privacy Code, the Provisions of the Guarantor, and in general, all legislation on the protection of individuals with regard to the processing of Personal Data.

GDPR or Regulation: European Union Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data (General Data Protection Regulation)

Personal data: Any information relating to an identified or identifiable natural person. In addition to the data provided by the user via any forms within the individual areas of the Web Services, this also includes data relating to the user’s navigation

Stakeholder or interested party: The identified or identifiable natural person to whom the Personal Data relates.

Navigation data: The computer systems and software procedures used to operate the Web Services acquire, in the course of their normal operation, certain data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified interested parties, but by its very nature could enable users to be identified through processing and association with data held by third parties. However, if the browsing session is carried out after accessing the Reserved Area (or log in), the data collected are associated with the user’s personal account.

Navigation data includes:

• IP addresses or domain names of computers used by users connecting to the site;
• the addresses in URI (Uniform Resource Identifier) notation of the requested resources;
• the time of the request;
• the method used to submit the request to the server;
• the size of the file obtained in response;
• the numerical code indicating the status of the response given by the server (successful, error, etc.);
• other parameters relating to the user’s operating system and computer environment.

Data provided by the user: These are the data that the user voluntarily and knowingly shared by sending communications (e.g. by e-mail, to the addresses present in the web domain) or by filling in specific forms, if present in the spaces provided by the Services.

The Data provided by the User are only those strictly necessary for the purposes occasionally required by the services (for precise indications regarding the categories of data occasionally collected, please refer to the individual privacy policies of reference). By way of example, such data may include:

• personal details;
• contact details (e.g. e-mail address);
• information related to the contractual position of the user/customer;
• geolocation (where the user has given consent to the collection of data relating to his/her location);
• information related to the use of the individual services made available to the user;
• relevant facts and events revealed by the user in his/her messages (in this regard, and for his/her greater protection, the user is invited not to provide information that is not strictly pertinent to the subject of the request and the nature of the services provided by the company)..

Data Controller or the Controller: The person who decides upon the purposes and means of processing Personal Data. With reference to Web Services, it is the Company of the Unipol Group to which this site refers, and the references of which you can find at the bottom of each page.

Services or Web Services: The services provided through the internet, used through the website and/or any apps.

User: The data subject (natural person) who browses, consults, accesses, or uses the Web Services.

DPO: The Data Protection Officer. The user concerned may request clarifications on the processing of Personal Data or exercise his/her rights by contacting the DPO, in the manner and form indicated in the section “How to exercise rights and/or request information on data processing”.

Privacy Guarantor: The Garante per la protezione dei dati personali [Data Protection Guarantor], i.e. the Italian national supervisory authority for the protection of personal data. See the website of the Privacy Guarantor.

Cookies: Cookies are pieces of information that are stored on your device (e.g. in the memory of your browser) when you visit a website or use a web application.

Each cookie may contain various data, such as the name of the server from which it comes, a numeric identifier, etc.

See Cookie Policy for more information.

BACKGROUND INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA

Below we provide you with useful information regarding the processing of Personal Data carried out through the Web Services.

In particular, we want to inform you about:

• the identification and contact details of the data controller;
• the contact details of the Data Protection Officer (DPO);
• the categories of Personal Data processed through the Web Services;
• the purposes for which such Personal Data are occasionally processed;
• the preconditions for processing such data (legal bases);
• the duration of their storage, always strictly necessary for the pursuit of the stated purposes;
• the categories of recipients of data communication.

Data controller	Registered office
ITAL H&R S.r.l.	– Via Stalingrado, 37 – 40128 Bologna (Italy)

Categories of Personal Data, purpose, and legal basis of processing and retention periods

The provision of your Personal Data is free and optional. We remind you, however, that for the pursuit of certain purposes (to provide you with the appropriate feedback requested, for registration in the Reserved Area or for the provision of individual Services) it is indispensable; if not provided, in such cases, it may not be possible to proceed with the pursuit of the aforementioned purposes.

However, we invite you to consult the individual data processing notices for more details.

 Processing methods and recipients of data communication

The above data will not be subject to dissemination and may be viewed the by employees of our company specifically authorised to process them. They may also be acquired and/or processed by other companies of the Unipol Group and/or by the companies. Processing operations may be carried out by external parties to whom we entrust the performance of activities on our behalf, and with whom we enter into appropriate agreements aimed at regulating the processing of data.

Finally, the data may be communicated to public authorities or law enforcement agencies at their express request.

The processing of Personal Data is always carried out following the adoption of appropriate security measures to ensure the confidentiality, availability and integrity of such data.

COOKIES

The Web Services may use technical, analytical, and profiling cookies, both first and third party ones.

Cookies are essential for improving the services and providing products that are always in line with users’ preferences.

Any use of profiling and/or third-party cookies will always be subject to your prior consent.

To find out more, click here.

RIGHTS OF THE USER (AS DATA SUBJECT)

The Privacy Law (Articles 15-22 of the Regulation) guarantees the user, as the Data Subject, the right to access his/her data, as well as the right to rectification and/or integration, cancellation or portability. The Privacy Policy also gives the user the right to request the restriction of data processing and to object to data processing, as well as the possibility to revoke any consent given (revocation does not affect the lawfulness of the processing carried out up to that moment).

HOW TO EXERCISE RIGHTS AND/OR REQUEST INFORMATION ON PROCESSING

The “Data Protection Officer” is available to clear any doubts, for clarifications, for the exercise of the rights of the Data Subjects, and to provide an updated list of the categories of data recipients.

This does not affect your right to approach the Privacy Guarantor, including by means of a complaint, where deemed necessary for the protection of your Personal Data and your rights in this respect.

BACKGROUND INFORMATION

The list of background information is given below:

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