Privacy Policy

In the following privacy policy DUECI PROMOTION SRL with registered office in Bologna, via Farini, 28 CAP 40124, P.IVA 01796411203 (hereinafter the “Company” or the “Owner”) intends to describe the working of this website, with specific regard to the modalities whereby personal data pertaining to the users who visit it are gathered, registered and used, as well as the purposes of such processing: this notice has been issued for the website www.duecipromotion.com, (hereinafter “DueCi Promotion website”) only and is not meant to be applied to the other websites possibly visited by the user through the links on the pages of the aforementioned websites.

DueCi Promotion website is run and controlled by DueCi Promotion, the “Data Controller”, whose seat is in Bologna via Farini, n. 28.

This privacy policy, addressed to anyone who enjoys DueCi Promotion’ web services, intends to satisfy the requirements provided for by EU Regulation n. 679/2016 (the “Regulation”) and Legislative Decree no. 196/2003 (the “Privacy Code”) and it also draws inspiration from Recommendation no. 2/2001, adopted on May 17, 2001 by the EU authorities for the personal data protection, that are all part of the Group created pursuant to art. 29 of Directive no. 95/46/EC. This Recommendation identifies some basic requirements for the on-line collection of personal data; in particular, the nature of the information, as well as the timing and modalities of their provision, to be supplied by the holder of processing to the users whenever the latter visit some web pages, no matter what the reasons of their connection are.

PLACE OF DATA PROCESSING

The website is hosted on machines managed by the Company and located in its registered office.

TYPE OF DATA PROCESSED

Navigation data

The IT systems and the software procedures for the operation of this website, while being normally used, collect some personal data whose transmission is implicit while using the Internet communication protocols.

The above information is not collected to be associated to any identified persons; yet, its same nature could make it possible to identify users, by means of special processing and associations with other data.

The IP addresses or the domain names through which the users connect to the website, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of request, the procedures used to submit the request to server, the file size of the reply, the numeric code indicating the status of the server’s reply (successfully delivered, error and so on) and other parameters relating to the user’s operating system or IT environment, fall within this category of data.

Data voluntarily provided

The optional, explicit and voluntary sending of electronic mail messages to the addresses indicated on this website for the sending of contact requests or of the CVs implies the following collection of the sender’s address, necessary to reply to possible requests, as well as of the other personal data, if any, included in the message.

Specifically, the users that wish to send their CVs through DueCi Promotion’ website, or to enrol to any course or conference organised by DueCi Promotion, are invited to pay the due attention to this notice with regard to the processing of data related to them and inserted in the CVs sent or in the registration made. In this way only the processing can be carried out consciously and deliberately. In particular, DueCi Promotion acquaints that the Regulation and the Privacy Code prescribes that sensible and “particular” data (i.e. personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation) can be lawfully processed only by previous consent; it is difficult, thought, to obtain such a consent from each user. Thus, the Company’s intention being a legitimate and transparent processing, the same invites those being interested in the on-line sending of the CVs, or to enroll to any of the courses or conferences not to include any sensible and/or particular data in it.

The consent to the possible transfer abroad of the data contained in the CV will be requested upon the conoscitive and informative interview.

PURPOSES OF DATA PROCESSING AND COMMUNICATION

Navigation data are merely used to obtain anonymous statistical information on the use of website and to verify its proper operation, thus, it will be deleted immediately after processing. The data may be used to ascertain any liability in case of possible IT-related offences to the prejudice of the website: except this circumstance, the data about web contacts will not be currently held for more than seven days.

The personal data provided by users who request the sending of informative material on events or initiatives organized by DueCi Promotion and who participate in them, who wish to enroll in courses or conferences organized by DueCi Promotion, or who send requests for contact or forward Cv’s are used only to satisfy or respond to requests sent and are communicated to third parties only if this is necessary for that purpose. The “legal basis” pursuant to the Regulation that legitimates the collection and processing of these personal data is constituted by the execution of the service expressly requested by the users.

DueCi Promotion, finally, may process users’ personal data in the pursuit of its own or third parties’ “legitimate interests”, for example for the management of any disputes, claims, complaints, and protection of their information systems, as well as to comply with the applicable laws and regulations.

Processing connected to web services provided by this website are run by DueCi Promotion’ operators, who were appointed as “People in charge of processing” as well as by external subjects in their quality as “Data Processors” or as “Data Controllers” with regard to the specific activities carried out by them. The distinct role the Company’s partners take in relation to the data processing given to them is strictly connected to the specific activity performed.

Personal data can be transferred, as far as the above mentioned purposes are concerned, to other DueCi Promotion’ seats or to professional partners. In that case, the user will have the opportunity to express his/her preference in relation to such transfer of his/her data.

COOKIES

No personal data of users is intentionally acquired by the website.

Neither cookies nor the so-called persistent cookies of any kind or any users’ tracking systems will be used for the transmission of personal information.

The use of the so-called session cookies (that are only temporarily recorded on the user’s computer and that are deleted as soon as the browser is closed) is strictly limited to the transmission of session IDs (made up of random numbers generated by the server) necessary to perform a safe and efficient exploration of the site.

The so-called session cookies used in this site avoid any recourse to other IT techniques that are potentially prejudicial to the privacy of the users’ navigation and do not allow the collection of personal data which may identify users.

VOLUNTARY PROVISION OF DATA

Except as specified for navigation data, the user is free to provide his/her personal data by email to urge information, to submit an application to DueCi Promotion by sending his/her CV or to join DueCi Promotion’ initiatives as well as enroll to courses or conferences organised by DueCi Promotion.

However, any refusal by the user to provide the above data may impair, in such situations, the obtainment, by the user themselves, of the information requested.

PROCESSING METHODS AND CRITERIA FOR DATA STORAGE

Personal data is processed with IT tools exclusively for as long as is necessary for the purposes for which it has been collected, Personal data processed for informative purposes will be kept until user’s unsubscribe to the service required as well as for the periods of time provided for by specific provisions of law, if applicable

Specific security measures have been adopted to prevent any loss of data, any unlawful or non correct use of the same and unauthorised access.

No data deriving from the web service shall be disseminated.

RIGHTS OF THE DATA SUBJECTS

The data subjects are entitled at any time, when the conditions set forth by the law occur, to have confirmation of the existence of such data and to be acquainted with its contents, to verify its source and to require its rectification, integration, updating or limitation of the processing (artt. 15-22 of the Regulation).

Any subject also is entitled to request that his/her data processed are deleted, turned into anonymous or blocked, as well as to object, for lawful reasons, to its processing.

Requests can be sent to the e-mail address:

privacy@duecipromotion.com

Users may also, in relation to the processing of personal data described in this Privacy Policy, send complaints to the Italian Data Protection Authority (www.garanteprivacy.it)

DATA PROTECTION OFFICER

The contact details of the Data Protection Officer (“DPO”) of DueCi Promotion, domiciled in Bologna, via Farini, 28, are the following: phone 051 4841310 email

dpo@duecipromotion.com