Policy pursuant to art. 13 Reg. UE 27 April 2016 no. 679

The European Regulation no. 2016/679 (‘GDPR’) provides that the person processing personal data is required to inform the Interested party (i.e. the person to whom the data relate) of certain elements qualifying the processing, which must be carried out fairly, lawfully and transparently, protecting the confidentiality and rights of the Interested party.

GENERAL DATA PROCESSING PRINCIPLES

Data processing will be carried out by collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction and will be carried out by the data controller, the persons in charge and persons authorized to process such data. The data will be processed in a lawful, correct and transparent manner; they will be collected for specific, explicit and legitimate purposes and not processed in a way incompatible with those purposes; they will be adequate, relevant and limited to what is necessary with respect to the purposes for which they are processed, exact and up to date; they will be processed with the utmost confidentiality, mainly with electronic and IT tools and stored both on electronic supports and paper, and on any other suitable support, in compliance with the principles laid down in the European Regulation on the protection of personal data, the prescriptions issued by the Control Authority and in any case in such a way as to ensure adequate security, included protection, using suitable technical and organizational measures, against unauthorized, unlawful handling of data or loss, even accidental, of the same. The data will be kept in a form that allows for the identification of the person concerned for the time strictly necessary to achieve the purposes for which they were processed. ELVEM S.r.l. undertakes to comply with specific security measures to prevent the loss of data, unlawful or incorrect use and unauthorized access to the same, in full compliance with the rules of law and regulations. Personal data voluntarily provided by you (either by sending e-mail or by other means of communication, or by sending your curriculum vitae via the website at the time of your application request), will be kept in the database of ELVEM S.r.l. exclusively for the purposes indicated above and for the time provided for by the reference standard.

IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER

The data controller is Elvem S.r.l., currently based in Cartigliano (VI), Via delle Industrie, 42. In order to exercise your rights under the Regulations and for any request relating to your personal data, you may contact the Data Controller by sending a communication to the e-mail address info@elvem.it.

CONTACT DETAILS OF THE DATA PROTECTION OFFICER

ELVEM S.r.l. does not need to appoint a Data Protection Officer.

PURPOSE AND LEGAL BASIS OF DATA PROCESSING

We hereby inform you that the personal data voluntarily provided by you will be processed by ELVEM SRL, as data controller in order to respond to requests made by you as well as for advertising purposes. In particular, in relation to promotional activities, your personal data will be processed for:

▪ Marketing activities (direct sales, sending of advertising material, market research, commercial communication);

▪ profiling;

▪ communication of the same data to third parties for marketing purposes.

Processing for marketing purposes is lawful if previously agreed by the interested party under Article. 6, letter a) of the European Regulation no. 679 of 27 April 2016; the processing of data for the purpose of dealing with specific requests from the interested party is lawful and in accordance with art. 6, letter b) of the European Regulation (EEC) No 679/2011 of 27 April 2016, in so far as it is intended to implement pre-contractual measures at the request of the interested party.

ANY RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA

Please note that the third parties to whom the personal data are communicated for the purposes indicated above are E.B.L. Elettromeccanica Baron Luciano.
These companies – as data controllers – will process the data for the same purposes. The personal data that the undersigned Structure will come into possession of are not subject to disclosure. The same may be the subject of communication within the Company and come to the attention of those in charge and data processors appointed by ELVEM S.r.l.. For the purposes of maintenance of this website, ELVEM S.r.l. may use third parties who, in this way, may have access to your data. In any case, such parties will be designated as data processors or and will receive adequate operating instructions, with particular reference to the adoption of the minimum security measures.

TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

ELVEM S.r.l., for the purposes indicated, intends to transfer your personal data to the company MAILCHIMP, with registered office in 30308 Atlanta, GA (USA), The Rocket Science Group, LLC 675 Ponce de Leon Ave NE, Suite 5000. This company has adhered to the principles of Privacy Shield and therefore provides adequate guarantees of protection of personal data.

PERIOD OF STORAGE OF PERSONAL DATA

The personal data provided will be processed by the undersigned organization for the purposes set out above until the time when the interested party notifies the cancellation of consent to processing.

THE RIGHTS GRANTED TO THE INTERESTED PARTY

Interested parties have the right to obtain access to personal data from the data controller, free of charge and without prejudice to the rights and freedoms of third parties. In particular, they have the right to obtain confirmation that data concerning them are being processed or not and the following information: a) the origin of the personal data, if the data have not been collected from the interested party; b) the categories of personal data, c) the purpose and the processing mode; d) the existence of an automated process, including profiling and, in this case, the logic used, as well as the importance and the expected consequences of such processing for the interested party; e) update or change; f) the cancellation or limitation of the processing of data concerning them (anonymous transformation, blocking processed data under breach of law, including those data that do not need to be stored for the purposes for which they were collected or processed at a later time); g) the recipients or the categories of recipients to whom personal data have been or will be communicated, particularly if the recipients belong to international organizations or third countries (in this case, the interested party has the right to be informed on the existence of appropriate guarantees pursuant to article 46 concerning data transfer); h) when possible, the expected storage time of personal data or, if such data is not predicible, the criteria used to establish such period. The interested party also has the right to revoke his consent to the processing of personal data and to object to the processing thereof. In any case, the revocation of consent to processing shall not affect the lawfulness of processing based on the consent given prior to revocation. The interested parties also have the right to data portability.

RIGHT TO LODGE A COMPLAINT

Interested parties have the right to lodge a complaint with the Control Authority, represented in Italy by the Guarantor for the Protection of Personal Data, with registered office in Rome, Piazza Monte Citorio, 121.

MANDATORY OR OPTIONAL NATURE OF DATA PROVISION

The provision of your personal data is optional. Your refusal will prevent the Company from carrying out the purposes indicated in this policy.

EXISTENCE OF AN AUTOMATED DECISION-MAKING PROCESS

The undersigned Company does not use automated decision-making processes.

Consent in accordance with Art. 6 of European Regulation no. 2016/679:

read the above Policy:

a) the undersigned gives his/her specific consent to the processing of his/her personal data for marketing purposes (direct sales, sending of advertising material, carrying out market research and commercial communication). This consent is given for marketing carried out both with the use of traditional systems (regular mail, telephone call by operator), and with the use of automated call systems or communication without the intervention of an operator, e-mail, fax, messages, mms, or other means of automated communication. The right of the interested party to object to the processing of his/her personal data for direct marketing purposes through automated communication methods, extends to the traditional ones and remains subject to the possibility of exercising this right, even in part. The interested party may express his/her willingness to receive communications for the above purposes exclusively through traditional means of contact. Refusal to give consent will make it impossible for the Company to process your data for marketing purposes.

□ I agree □ I do not agree

Date, signature

b) The undersigned gives his/her specific consent to the processing of his/her personal data for profiling activities.

□ I agree □ I do not agree

Date, signature

c) The undersigned gives his/her specific consent to the processing of his/her personal data for communication of such data to third parties.

□ I agree □ I do not agree

Date, signature