The European Legislation No. 2016/679 concerning the protection of personal data (hereinafter “Privacy Regulation or EU Regulation”) and the Legislative Decree 30th June 2003 No. 196 “Code regarding the protection of personal data” (hereinafter the “Code”) provide for the right to the protection of personal data and ensure its processing in compliance with fundamental rights and freedoms, as well as the integrity of the person in question, with particular focus on confidentiality and security, personal identity and the right to protect personal data.
“Processing” of personal data is understood as, pursuant to article 4, paragraph 1, No. 2 of the Privacy Regulation, any operation or set of operations, performed with or without the aid of automated processes applied to Personal Data or sets of Personal Data, including collection, registration, organisation, structuring, storage, adaptation or the modification, extraction, consultation, use, communication by transmission, diffusion or any other form of provision, comparison or interconnection, limitation, cancellation or destruction.
The Elicapital Srl, located in Roma – Via Bellini 2, 00198, VAT Number 13673711001, in its capacity as Data Controller (hereinafter the “Data Controller”), in the person of the legal representative pro tempore, pursuant to and by effect of article 13 of Privacy Legislation No. 2016/679, we hereby
The user/visitor of the site, subsequently referred to as the interested party, in relation to using the website www.sanlorenzoyacht.com (the “Site”) and the potential communication of personal data and contact details through forms present on the same, that personal data provided shall be treated in accordance with what is outlined in the following report:
1. TYPE OF DATA PROCESSED
The Data Controller may gather information on the Interested party when they are browsing the Site, in the following ways:
a) Browsing data
During their normal operation, the computer systems and software procedures used to operate this website gather various personal data whose transmission is implicit in use of Internet communication protocols. This data category includes: the IP addresses, the browser type used, the operating system, the domain name and the website addresses it was accessed from, information on pages visited by users within the site, the access time, the period stayed on each single page, the internal path analysis and other parameters related to the operating system and the user’s computer environment. This also includes, where accepted by the visitor, the cookies (for see the specific section 5 of this report).
b) Data provided by the visitor/user
This is all the personal data provided by the user on the Website: (1) by filling out the contact form provided therein and/or by telephoning/sending e-mail to the addresses indicated by the Data Controller in the “contacts” and/or (2) filling out the form for job applications, available via the following link httpss://www.elicayachts.it//elica/recruitment-selection/ where the applicant can enter information in the appropriate spaces for personal data, along with their CV, photo and a short cover letter.
2 DATA PROCESSING AIMS AND METHODS
The processing of personal data, which is collected through the Site and provided voluntarily by the Data Subject and bound by this report, shall be managed on the principles of correctness, lawfulness and transparency, protecting your privacy and the rights of the data subjects in accordance with the procedures established by the company’s Data Controller to guarantee the safety of all processing.
a) Main purpose:
The processing of personal data gathered and/or communicated by the Interested parties shall be mainly for the following basic purposes, pursuant to and for the purposes of Article 6, paragraph 1, letter b), c) and f) of the Privacy Regulations:
- provide the interested parties with the functionalities and information present on the Website in a format suited to their needs and/or to the specifications of the respective internet browsers;
- provide the interested parties with support and information on the services of the Data Controller;
- keep information in the company files up-to-date, and available to the Company employees responsible for the processing;
- provide interested parties with the opportunity to apply for any “open positions” featured by the company.
b) Additional purposes – marketing:
The data collected may also be processed by the company, subject to the explicit and free consent of the interested party pursuant to Article 6, paragraph 1, letter a) of the Privacy Regulation, for the following additional aims:
- the sending of promotional communications and advertising material, the offer of products and/or services or those of third parties, the carrying out of surveys and market research, by any means including in particular use of telephone operators and/or automated systems (e.g. SMS, MMS, fax, autoresponder, push notifications, social media);
- for profiling purposes, to allow the processing and completion of studies and statistical and market research, to enable the creation/defining of the profile, as well as analyse: the preferences, habits, needs and/or consumption habits of the Interested party, to offer a more personal service tailored to their needs, as well as personalised promotions and discounts;
- the transfer of personal data to other companies, distinct from Elicapital Srl, holding commercial partnership contracts, with the aim sending promotional communications and advertising material, offering products and/or services or those of third parties, the completion of surveys and market research, by any means including in particular using telephone operators and/or automated systems (e.g. SMS, MMS, fax, autoresponder, push notifications, social media).
Personal data may be processed either in hardcopy or using IT tools in compliance with the provisions outlined on the protection of personal data. In particular regarding the security measures, pursuant to article 32 of the Privacy Regulation and by complying with all precautionary measures that can meet the required level of confidentiality and security.
All the data subject of this information shall be processed and stored by the Data Controller and by those appointed as Data Processors, and/or expressly authorised for processing by the Data Controller, in compliance with the principle of proportionality, for the time period strictly necessary for each purpose identified, which is deemed to be a maximum of 24 months from the last contact, always subject to the storage/archiving criteria for additional periods if foreseen by the current legislation regarding criminal, fiscal and financial matters (which envisage a maximum time of 10 years from their gathering and/or ending of the relative aim) and/or if requested by the relevant Authorities concerned. This specific processing is based on the meeting of legal obligations and on the legitimate interest of the Owner to exercise their rights (Article 6, paragraph 1, letter c) and f) of the EU Regulation).
3. COMPULSORY OR OPTIONAL NATURE OF DATA PROVISION AND CONSEQUENCE OF REFUSAL
The provision of data for the purposes referred to in Article 2, lett. a) of this information is mandatory for the proper functioning of the Site, as it required to meet the legal obligations in place, as well as by the Owner, in exercising their legitimate interests (Article 6, paragraph 1, lett. c) and f) of the EU Regulation). However, the Site user has the choice of denying consent to the installation of cookies in the manner outlined in the relevant article 5 of this report.
The provision of data for the purposes referred to in art. 2, lett. b) of this information is completely voluntary and not mandatory, and requires consent from the interested parties with explicit acceptance of this information for the processing. Failure to provide the data accompanied by the relative consent to the processing shall mean the Owner is unable to respond/manage any potential requests for support and/or contact.
The data collected shall also be processed by the Company so as to exercise its legitimate interests, pursuant to Article 6, paragraph 1, letter f) of the Privacy Regulation, to promote its services to users who have already used it, through the sending of periodic informative and/or commercial communications, without prejudice to the users’ right to oppose the processing at any time, pursuant to article 18 of the Privacy Regulation. It is understood that this processing is carried out in compliance with the provisions of article 130, paragraph 4 of the Privacy Code
If the Data Subject does not provide consent and/or provides only part of the data requested or provides inaccurate and/or incomplete data, it shall not be possible for the Data Controller to carry out any processing. Therefore, no responses can be provided and the interested party shall not be contacted by the owner.
4. AIM OF COMMUNICATION AND RELEASE OF PERSONAL DATA
Strictly in relation to the purposes indicated above and for the consents provided the personal data collected may be communicated to the following subjects or subject categories:
- to consultants (both natural and legal persons) or suppliers to whom the Data Controller may delegate tasks for the carrying out of various outsourced activities;
- to potential other users, to whom the current legal and/or contractual regulations outlines the duty to notify, in compliance with the provisions under the current legislation.
Personal data may be disclosed to company employees and/or collaborators specifically authorised for processing in accordance with Article 29 of the EU Regulation.
All the processing carried out by third parties with respect to the Owner who are employed by the organisation shall be duly authorised by the Owner itself, after delegating the third party as Data Processor, pursuant to article 28 of the EU Regulation. All processing shall be carried out in compliance with the regulations on security and privacy. Personal data collected will not be released, unless this is required by a legal provision or regulation or by EU legislation.