Privacy Policy
PRIVACY POLICY WEBSITE
The privacy policy is provided for the website “www.westpole.it” (hereinafter also referred to as the “Website”) and not also for other websites that may be visited by the User through links, pursuant to and for the purposes of article 13 of EU Regulation no. 2016/679 “General Data Protection Regulation” (hereinafter “Regulation”).
THE DATA CONTROLLER
The Data Controller is the company:
WESTPOLE S.P.A. – Via Francesco P. Da Cherso, 30 – 00143 Rome – Tel.: +39 06 519 931
email: [email protected] TO BE CHANGED; Certified email: [email protected]
Taxpayer’s number: 03705590580; VAT number: 01230291005
Share capital: € 500,000 fully paid-up – Chamber of Commerce: 448372 – Court Reg.: 4127/79 REA (Economic Register) Number: VE – 330005
TYPES OF DATA PROCESSED
Personal Data collected by this Website include: first name, surname, company name, email, telephone contact, company position, cookies.
Full details on each type of data collected are provided in the dedicated sections of this privacy policy or by means of specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected while browsing the pages of the Website. All Data requested and collected through the Website are mandatory and, in the absence of their provision, it may be impossible to provide the services requested or to proceed with the browsing of certain sections of the Website. In cases where certain Data are indicated as optional, Users are free to refrain from providing them, without this having any consequence on the availability of the service or on its operation. Users who have doubts about which Data are required are encouraged to contact the Data Controller. Any use of cookies – or other tracking tools – by the Website, or by the controllers of third-party services used by the Website, unless otherwise specified, is intended to provide the service requested by the User, as well as for the additional purposes described in this document and in the Cookie Policy. The User assumes responsibility for the Personal Data of third parties if provided through the Website, and guarantees having the right to communicate such data, releasing the Data Controller from any liability.
Browsing data
The computer systems and software procedures used to operate this Website acquire, during their normal operation, a number of Personal Data the transmission of which is implicit in the use of Internet communication protocols or is used to improve the quality of the provided service. This information is not collected to be associated with identified parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of computers used by Users who connect to the site, URI (Uniform Resource Identifier) of 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 from the server (successful, error, etc..) and other parameters relating to the operating system and computer environment. These data are used only to obtain anonymous statistical information on the use of the website and to check its proper functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the website: except in this case, the data on web contacts do not currently persist for more than 7 (seven) days.
Personal Data voluntarily provided by the User
The Personal Data provided by Users through the explicit and voluntary sending of requests through the use of the email addresses indicated on the website (forwarding of curriculum vitae, request for answers to questions, contact requests, etc.) involves the subsequent acquisition of the sender’s address as well as any other Personal Data included in the message. Such data are used only for the purpose of carrying out the requested service (e.g. information on products and services, application for employment, contacts, feedback on the website). Specific privacy information and relative requests for consent to the processing of Personal Data are also indicated or displayed on the pages of the website prepared by WESTPOLE S.p.A. to allow the User to request information on available services (e.g. demos and quotes on products and services, information or subscriptions to events, seminars, requests to send commercial communications, etc..) by filling out specific forms and registration forms. The privacy policies also indicate any data “processors”. In these cases, and only with the explicit and manifest consent of the User, the Personal Data acquired may also be used for:
• assessing the User’s interest in the Company, as a potential customer or supplier;
• carrying out communication and marketing activities;
• carrying out information activities on events and seminars.
We ensure that in all cases, data processing will always be based on principles of fairness, lawfulness and transparency and protection of confidentiality as indicated in the Regulation.
Cookies
Cookies are text files containing small amounts of information which are downloaded to your device or, more technically, to the browser you use on that device when you visit a Website. The person who sends the cookies on the browser can then read the information about the cookies which have been set. Cookies are normally divided into “session cookies”, which do not remain on the device after closing the browser, or “permanent cookies”, which normally remain on the device until deleted by the User or upon their expiration.
As stated in the privacy policy provided to the User at the time of access, this Website uses cookies, including third party cookies. For more details, please refer to the Extended Cookies Policy on the Website.
METHOD, STORAGE TIME, PLACE OF DATA PROCESSING AND RECIPIENTS
Methods of processing
The processing of Personal Data will be carried out through the use of computer systems in accordance with the requirements arising from the Regulation and according to the criteria of lawfulness, correctness and full protection of the rights and in particular the confidentiality of respondents. Specific security measures are adopted to prevent the loss of data, illicit or incorrect use and unauthorised access, and which guarantee their integrity, accuracy, availability and updating.
Time and place of storage
Personal Data are processed for the time necessary to perform the service requested by the User, or required by the purposes described in this document. Personal Data will also be stored for 24 (twenty-four) months (2 years) on WESTPOLE’s computer systems (back end site and CRM), after which they will be automatically deleted.
Data recipients
Personal Data will be communicated within the company to the functions concerned (marketing office, sales departments, sales, product BU). The Personal Data voluntarily provided by the User will not be disclosed but may be communicated to: natural persons or legal entities which, including by way of contracts with the Company, provide specific processing services or perform activities related to, instrumental to or in support of the processing of the request made, after a letter of Appointment imposing confidentiality and security; bodies or organisations authorised to fulfil their obligations within the limits of the provisions of the law. No Personal Data acquired through the Website will be communicated or disseminated, except as required by law or regulations. The term “disseminated” means making them known to indeterminate entities in any way, including by making them available or for reference. The Personal Data provided, with your consent, may be communicated to: a) third parties for whom knowledge of the Personal Data is necessary or in any case functional to the performance of WESTPOLE’s business activities; b) companies with which WESTPOLE has contractual relations relating to the production and marketing of products offered by the same. The communication of such data will be aimed at ensuring the continuity of the services offered and at monitoring the proper functioning as well as the implementation and provision of additional services.
Transfer of Personal Data to third countries
Personal Data collected automatically while browsing the pages of the Website or freely provided by the User will not be transferred by WESTPOLE to third countries or international organisations outside the EU.
PURPOSE OF PROCESSING
The User’s Personal Data are collected to allow the Data Controller to provide its services, as well as for the following purposes: to contact the User who requests: information Solutions and/or Services, to send the CV to Work with Us, information on specific Marketing Campaigns. This data is collected pursuant to and for the purposes of article 13 of EU Regulation no. 2016/679 “General Data Protection Regulation” (hereinafter “Regulation”). The types of Personal Data used for each purpose are indicated in the specific sections of this document and are summarised below. Apart from that specified for browsing data and cookies, the User is free to provide Personal Data to request information by forwarding emails or sending informative and commercial material by signing forms. Failure to provide such data may make it impossible to obtain what has been requested.
Details on the Processing of Collected Data
Contact us
The data acquired by WESTPOLE through the form fall within the category of “Personal Data” pursuant to article 4, paragraph 1 of the Regulation and will be used to be contacted and respond to the message issued by you in the form, to provide details and detect interest via email or telephone contact.
Collected personal data: first name, surname, telephone, company and email address.
Request of Information Solutions and/or Services
The data acquired by WESTPOLE through the form fall within the category of “Personal Data” pursuant to article 4, paragraph 1 of the Regulation and will be used to:
a) email Brochures relating to the Services and Solutions described in the WESTPOLE Website;
b) provide further information and detect interest by email or telephone contact.
Collected Personal Data: first name, surname, telephone number and email address.
Request Sending of Presentations/Sheets
The data acquired by WESTPOLE through the form (first name, surname, company, telephone and email address) fall within the category of “Personal Data” pursuant to article 4, paragraph 1 of the Regulation and will be used to:
c) email presentations/information sheets relating to the Company, Services and Solutions of Your Interest described on the WESTPOLE Website;
d) provide further information and determine interest by email or telephone contact.
Collected Personal Data: first name, surname, telephone number and email address.
Work with Us
The data acquired by WESTPOLE through CVs (first name, surname, place and date of birth, taxpayer’s code, telephone number, postal address, educational qualification and other elements of personal identification) sent in relation to any open positions or spontaneous application, fall within the category of “Personal Data” pursuant to article 4, paragraph 1 and paragraph 15 of the Regulation and will be processed solely for the purpose of carrying out an assessment of the professional aptitudes and skills of the candidates themselves, depending on the open position and for which a selection procedure is underway or for future needs to expand the company staff (recruitment or internship). Collected personal data: first name, surname, telephone number and email address.
Marketing Campaigns
The data acquired by WESTPOLE through the form fall within the category of “Personal Data” pursuant to article 4, paragraph 1 of the Regulation and will be used to:
e) email brochures on the Service advertised through the marketing campaign from time to time advertised on the site;
f) provide further information and determine interest in the service by email or telephone contact. Collected personal data: first name, surname, company, position, telephone number and email address.
Social Media
Users of the Website can participate in the WESTPOLE S.p.A. platform on LinkedIn, Twittere Youtube. The main objective is to facilitate and allow the sharing of content. However, WESTPOLE S.p.A. cannot be held responsible for the voluntary sharing, by Users on the Social Media, of Personal Data subsequently used, including in an improper way, by third parties.
MINORS
WESTPOLE S.p.A. does not knowingly use its website to request data from persons under the age of 16 as prescribed by article 8 of the Regulations.
P3P
This privacy policy can be viewed automatically by the most recent browsers which implement the P3P standard (“Platform for Privacy Preferences Project”) proposed by the World Wide Web Consortium (www.w3c.org).
Every effort will be made to make the functions of this site as interoperable as possible with the automatic privacy control mechanisms available in some products used by users.
Considering that the state of improvement of the automatic control mechanisms does not currently make them free from errors and malfunctions, it should be noted that this document constitutes the “Privacy Policy” of the website “www.westpole.it” of WESTPOLE S.p.A. which will be subject to updates (however, the various versions of the same will be made available).
RIGHTS OF DATA SUBJECTS
The entitlement of data subjects to exercise the rights referred to in articles 15, 16, 17, 18 and 20 of the Regulation (access, rectification, erasure of data, restriction of processing and data portability) during the aforementioned data retention period remains unaffected, as does the right to lodge a complaint with a supervisory authority.
The data subject has the right to obtain a copy of the Personal Data undergoing processing from the Data Controller. In the event of further copies being requested by the data subject, the Data Controller may charge a reasonable fee based on administrative costs.
If the data subject submits the request in electronic format, and unless otherwise indicated by the data subject, the information shall be provided in a commonly used electronic format. The right to obtain a copy shall not affect the rights and freedoms of others.
Requests must be made in writing and sent to the Data Controller:
– by means of certified email: [email protected]
– by registered mail with recorded delivery to: INSERT LEGAL OFFICE – WESTPOLE S.p.A, Via F.P. Da Cherso n.30 – 00143 Rome (RM)
Please indicate in the subject of the communication that this is a request for “Exercising of Rights under EU Regulation no. 2016/679”.
STATISTICS
WESTPOLE monitors and analyses data traffic on its Website in order to keep track of the User’s behaviour.
Google Analytics (Google)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of the WESTPOLE website, compiling reports and sharing them with other services developed by Google.
Google may use your Personal Data to contextualize and customize ads from its advertising network. Collected Personal Data: Cookies and Usage Data.
Place of processing: USA – https://www.google.com/analytics/learn/privacy.html
CHANGES TO THIS PRIVACY POLICY
The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving notice to Users on this page. Therefore, please visit this page often, taking as reference the date of the last amendment indicated at the bottom. If the User does not accept the amendments made to this Privacy Policy, he/she must cease using the WESTPOLE Site and may request the Data Controller to remove his/her Personal Data. Unless otherwise specified, the above Privacy Policy will continue to apply to the Personal Data collected up to that time.
WESTPOLE S.P.A.
Date of last amendment: 18/12/2018 DATE TO BE UPDATED