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Privacy Policy

PRIVACY POLICY PURSUANT ARTICLE 13 OF REGULATION (EU) 2016/679 - USERS OF THE WEBSITE

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1. Definitions

Anonymous Data, Customers, Cookies, Events, Personal Data, Policy, Products, Profiling, Regulation, Website, Processing, Users.

1.1       Anonymous Data: personal information that do not identify or make an individual identifiable.

1.2       Customers: companies operating in the same business field of Euroengel, which are current or potential customers of Euroengel and which are interested in Euroengel’s services and Products

1.3       Cookies: cookies are text files (letters and/or numbers) that contain packages of information that are stored on the User's computer or mobile device whenever they  visit a website through a browser. At each subsequent visit the browser sends cookies to the website they originated from or to another website. Cookies can be stored only for a temporary period for use by a particular website (i.e. session cookies), or for a longer period of time and independent of the session (i.e. persistent cookies).

1.4       Events: business exhibitions, events and promotional initiatives related to the business field in which Euroengel operates, organized by Euroengel  or by third parties , aimed at promoting Euroengel’s image, brand, services and Products.
Policy: this document, consisting of the policy regarding the processing of Personal Data and the Policy relating to Cookies.

1.5       Personal Data: any information relating to an individual, identified or identifiable, directly and indirectly, by reference to their name, identification number, location data, online identifier or elements characteristic of their physical, physiological, genetic, psychic, economic, cultural or social identity.

1.6       Processing: any operation or set of operations concerning Personal Data, such as, by way of example, the collection, organization, structuring, preservation, modification, extraction, consultation, use, communication, interconnection, limitation, cancellation and destruction.

1.7       Products: are the products manufactured and/or distributed by Euroengel.

1.8       Profiling: Personal Data Processing through the evaluation of personal aspects of Users with the use of fully or partially automated procedures.

1.9       Regulation: Regulation EU No 2016/679 of April 27 2016.

1.10     Website: this website.

1.11     Users: users of the Website.

2. Data Controller

Euroengel S.r.l.

The Data Controller referred to in this Policy is Euroengel S.r.l., with its registered office in Brescia, Via Ferrini, 14, Tax Code/VAT and Brescia House of Companies Register No 03231780176 ("Euroengel" or “Data Controller).
Any request of the User concerning the Processing of personal data performed by Euroengel regarding their Personal Data (including the exercise of the rights referred to in paragraph 8 below), will be addressed to Euroengel by post at the registered office, or by email to the following address backoffice@euroengel.it

3. Purposes and legal basis of Processing

 

a)   navigation on the Website: consent;

b)   managing of contact requests: consent;

c)   sending of commercial and promotional information, by Euroengel: consent;

d)   improvement of the Website: legitimate interest;

e)   Profiling: legitimate interest;

f)    sending of contact request to Customers by Euroengel: legitimate interest.

Euroengel processes Personal Data of Users for pursuing following purposes:

a)        Enabling navigation on the Website, primarily through the use of Cookies.

➢       the collection of Personal Data for the purposes referred to in letter a) is regulated in the Cookies Policy, available at the following paragraphs 8 and 9, of which Euroengel recommends reading.

b)       Managing of the contacts request submitted by the Users to the Website through the filling of a dedicated form.

➢       The collection of Personal Data for the purpose referred to in letter b) is mandatory by the User in order to allow Euroengel to manage the contact request, and any refusal prevents the User from receiving an answer from Euroengel. These Processing operations are based on the free, specific, informed and unequivocal consent of the User, expressed through a declaration or positive action (eg flag) on ​​the Website. The withdrawal of consent can be exercised at any time, following the instructions in point 8 letter a) of this Policy.

c)        Subject to prior optional consent, performing statistical analysis and market research, sending information and advertising material, to report on, and invite to promotional initiatives or Events;

➢       The collection of Personal Data for the purpose referred to in letter c) is optional and any refusal by the User prevents the latter from receiving newsletters and invitations to Events. These Processing operations are based on the free, specific, informed and unequivocal consent of the User, expressed through a declaration or positive action (eg flag) on ​​the Website. The withdrawal of consent can be exercised at any time, following the instructions in point 8 letter a) of this Policy.

d)       Performing Performing statistical analysis, market research, in an aggregate form, in order to improve the use of the Website by Users. Where possible, in order to achieve the present purpose, we will make use of Anonymous Data.

➢       The Data processing referred to in letter c) is based on the legitimate interest of Euroengel constituted by the benefit that the Euroengel can obtain from the setting up of a Website able to improve browsing and Users’ experience, which Euroengel believe to override Users' right to privacy. Opposition to this Processing (except when using Anonymous Data) can be exercised at any time by following the indications in paragraph 9 letter f) of this Privacy Policy.

e)       Carry out the Profiling according to paragraph 7 below.

➢       The Processing referred to in letter e) is based on the legitimate interest of Euroengel constituted by the benefit that the Euroengel can obtain identifying subjects potentially operating in the same business field and from sending customized contact request to Customers, which Euroengel believes to override Customers' right to privacy. Opposition to this Processing can be exercised at any time by following the indications in paragraph 9 letter of this Privacy Policy.

f)         Sending of contact request to Customers by Euroengel.

➢       The Data processing referred to in letter f) is based on the legitimate interest of Euroengel constituted by the benefit that the Euroengel can obtain from sending contact request, customized based on the Profiling, to Customers (current and/or potential) operating in Euroengel same business field, through the Customers’ contact address shown on their website, which Euroengel believes to override Customers' right to privacy. Opposition to this Processing can be exercised at any time by following the indications in paragraph 9 letter f) of this Privacy Policy.

4. Personal Data collection Procedures

 

a)   Personal Data entered on the Website by Users;

b)   Personal Data collected during Events;

c)   Personal Data expressly communicated by Users to Euroengel;

d)   Personal data automatically collected by the Website (through Cookies);

e)   Personal Data available on the Customers’ websites.

Euroengel collects Personal Data through the following ways:

a)        Personal Data entered on the Website by Users: these are the Personal Data provided, by way of example and not exhaustively, in order to fill the contact and/or newsletter forms;

b)       Personal Data collected during the Events: these are the Personal Data provided by the Users during their participation to Events, including the personal image of the User.

c)        Personal Data autonomously communicated by Users to Euroengel: these are the Personal Data communicated via email to Euroengel’ addresses available on the Website (e.g. info@euroengel.it) or through offline mode.

d)       Personal Data automatically collected by the Website: this is the Personal Data collected by the Website through, but not limited to, Cookies (for further information, Euroengel strongly recommends reading the Cookies Policy shown below).

e)       Personal Data available on the Customers’ websites: these are the Personal Data publicly available on the Customers’ websites.

5. Potential categories of recipients of Personal Data

 

Employees, third party IT service providers, technical and commercial third parties, companies of the “group of companies” of Euroengel.

Personal Data are processed by Euroengel and/or third parties, selected for reliability and competence, and to which such Personal Data may be disclosed as necessary or appropriate. In particular, Euroengel informs Users that Personal Data may be processed by, and/or communicated to:

a)        employees and/or collaborators of Euroengel;

b)        third parties suppliers of services necessary to guarantee the functioning of the Website (by way of example: a company that deals with hosting services);

c)         third parties, contractually linked to Euroengel, necessary for the provision of the Services (e.g. territorial partners of Euroengel);

d)        third parties that provide analysis services of the Website navigation data;

e)        subject to the User's optional consent, third parties providing automatic services for sending newsletters and/or any other type of commercial communication, marketing services, promotion, analysis of habits and consumption choices, also by means of Profiling;

f)         companies which, along with Euroengel, constitute the “group of companies” of Euroengel.

6. Retention period of Personal Data (or criteria for determination)

 

a)   Cookies: see Cookie policy

b)   Personal Data from the contact form: 6 months from receipt of the request;

c)   Personal Data for commercial purposes: 12 months from the last interaction of the User with the Company;

d)   Personal Data for Profiling: 12 months from the collection of Personal Data;

e)   Personal Data of the Customers available to the public on the Customers’ websites: 12 months from the last interaction of the Customer with the Company;

f)    Personal Data to comply with legal obligations and for judicial purposes

Personal Data are kept by Euroengel for the period of time strictly necessary to achieve the purposes for which they were collected, as indicated in point 3 above. In particular, except for the exercise of the right of withdrawal of the consent referred to in the following point 8 letter a) or the right of opposition referred to in point 8 letter f), Euroengel retains Personal Data for the following duration terms:

a)        Cookies: for the purpose referred to in point 3 letter a), Users are strongly advised to read the Cookies Policy, available at the following section no. 10 and 11;

b)        Personal Data for managing the contact request: for the purpose referred to in point 3 letter b), for a period of 6 months from receipt of the request of contact, sent by the User by filling in the appropriate forms on the Website and/or communicated spontaneously by the User to Euroengel through the email addresses available on the Website or offline mode. By way of derogation from this deadline, in case of a grievance or a complaint being sent via the "contact" form, the User's Personal Data will be kept for the period referred to in letter e) below;

c)         Personal Data for commercial and promotional communications: for the purpose referred to in point 3 letter c), for a period of 24 months (in absence of Profiling) or 12 months (in case of communications based on the Profiling) following the last interaction with Euroengel by the User, suitable to demonstrate an interest in receiving communications relating to Euroengel, such as gathering consent, opening newsletters, joining the Services and/or participating in the Events;

d)        Personal Data for carrying out the Profiling: for the purpose referred to in point 3 letter e), for a period of 12 months after the collection of the Personal Data;

e)        Personal Data of the Customers on the Customer’s website): for the purpose referred to in point 3 letter c), for a period of 12 months following the last interaction with Euroengel by the Customer suitable to demonstrate an interest in receiving promotional communications from Euroengel;

f)         in any case, Euroengel is authorized to keep, in whole or in part, Personal Data for a maximum period of 10 years from their collection, or for the longer duration of a legal dispute, limited to the information necessary to comply with legal obligations and enable Euroengel itself to investigate, exercise and defend, where applicable, its own right in court.

Once these terms have expired, Euroengel will automatically delete the Personal Data collected, or transform them into an irreversible anonymous form.

7. Profiling

Automated processing of Personal Data of Users for evaluative and/or predictive purposes.

 

Profiling performed by Euroengel has the following characteristics:

a)          object: Customers are companies which: a) have manifested their interest in Products by participating at the Events or which have spontaneously sent Personal Data to Euroengel by filling the contact and/or newsletter form on the Website; b) operating in Euroengel’s business field, potentially interested in Products and/or Events, which have a contact e-mail address publicly available on their websites;

b)          frequency: Euroengel’s commercial communications are aimed at promoting the Products and/or the Events where Euroengel participates, and have an approximately frequency of: i) 1 or 2 times a week, in case of newsletter related to Products, 2 or 3 times a year, in case of sending invitation to Events;

c)          Personal Data: Profiling is limited to “contact” Personal Data (i.e. name, surname, e-mail address, telephone number) and Customers’ business field;

d)          purpose: improving the promotion and advertising of the Products, by sending commercial communications regarding the Products and invitations to Events where Euroengel participates to subject operating in Euroengel same business field and potentially interested in receiving the aforementioned communications and invitations;

e)          effects for Users: receipt of contact requests related to the Products and invitations to Events related to the Costumers’ business field. In no case, does Profiling of Euroengel: i) constitute an automated decision-making process from which derive legal or similarly significant effects for Customers; ii) prejudice the behaviour and the purchase choices of the Customers; iii) have a prolonged and permanent impact on Customers; and iv) by reason of the type of Products offered by Euroengel and the category of Customers affected by such Processing, determine any discrimination of Customers.

8. Potential transfer of Personal Data outside EU

Yes.

Personal Data collected by Euroengel for the purposes referred to in point 3, letter c) and f), of this Privacy Policy might be transferred by Euroengel, pursuant to Article 44 and ss. of the Regulation, to The Rocket Science Group LLC (i.e. MailChimp), a company having its registered seat in 75 Ponce De Leon Ave NE Ste 5000 Atlanta,  GA , 30308-2172,  U.S.A. More information on the transfer and on the safety measures adopted by Euroengel may be requested to Euroengel.

9. Users’ Rights

Withdrawal of consent, access to Personal Data, correction or integration of Personal Data, deletion of Personal Data, limitation of Processing, opposition to Processing, portability of Personal Data, data breach, complaint to competent authorities

Ai sen   Pursuant to and for the purposes of the Regulation, for the period referred to in paragraph 6 of this Policy, each User has the right to:

a)        with reference to Data Processing referred to in point 3 letter d), withdraw the consent at any time, without prejudice to the lawfulness of the Processing based on consent before its withdrawal, by sending an email to Euroengel or by opting out from the commercial communications of Euroengel (see Article 7 of the Regulation);

b)       ask Euroengel for access to Personal Data and information regarding the related Processing and any copy in electronic format, unless otherwise specified by the User (see Article 15 of the Regulation);

c)        request the correction and/or integration of Personal Data, without undue delay (see Article 16 of the Regulation);

d)       for specific reasons (for example, unlawful processing, withdrawal of consent, non-existence of the purpose of the Processing), request cancellation of Personal Data, without unjustified delay (see Article 17 of the Regulation);

e)       with reference to specific cases (for example, inaccuracy of Personal Data, unlawful Processing, exercise of a right in court), request the limitation of Processing (Article 18 of the Regulation);

f)         with reference to the Processing referred to in point 3 letter d) (expect when Anonymous Data are used), to object at any time to the Processing of Personal Data by sending an email to Euroengel (see Article 21 of the Regulation);

g)        in case of automated Processing, to receive Personal Data in a readable format, in order to consent their communication to a third party, or, where technically feasible, to request the transmission of Personal Data by Euroengel directly to such third party (so-called portability of Personal Data - see Article 20 of the Regulation);

h)       be informed by Euroengel without undue delay of any violations or unauthorized access by third parties to their systems containing Personal Data (so-called data breach - see Article 34 of the Regulation);

i)         propose a complaint to the supervisory authority of the EU country in which the User resides, works or in which they believe the violation of their rights has occurred (see Article 77 of the Regulation).

For further information on the terms and conditions for the exercise of the rights granted to the User, the latter may consult the text of the EU Regulation published at the following link: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN, or contact Euroengel in the forms provided for in point 2 of this Policy.

 

Objection to the Profiling and to Euroengel’s promotional communications

Euroengel informs that each Customer has the right to object to the Processing of Personal data referred to in point 3 letters e) and f), any time and without any reason, by sending an e-mail to Euroengel or by exercising the opt-out within Euroengel’s promotional communications.

In case of exercise of this right, Euroengel will immediately interrupt any use of the Customer’s Personal Data for carrying out the Profiling and for sending communications related to the services, Products or Events.

10. Types of Cookies

Technical Cookies, necessary and functional to the browse on the Website.

Cookies necessary to browse:

a)      Purpose: Cookies essential to guarantee the correct functioning of the Website, for they allow the User to browse within the Website and use its basic features. Under no circumstances do these Cookies gather information likely to be used for commercial purposes. Said necessary Cookies are also needed to: (i) memorise the data given by the User during a session within the Browser; (ii) maintain active the User’s preferences and credentials during the navigation within the Website; (iii) display the content in the preferred language at each access, identifying from what nation the User is connected (and remembering such setting for future log ins). For the correct functioning of the Website, Users are requested to accept the Cookies necessary for the navigation, as their rejection could impede, or strongly compromise, the browsing possibilities on the Website.

b)      Collected Data: browsing-related Data.

c)      Duration: session Cookies.

            Cookies functional to browse:

a)      Purpose: Cookies allowing the Website to become more accessible. Such Cookies are able to memorise the User’s data for the log-in on the Website, avoiding that the same data should be entered again at each browsing session. Such Cookies are intended to facilitate and accelerate the Website’s use, they are not, however, essential for its browsing.

b)      Collected Data: browsing-related data and data regarding the preferences expressed during the navigation.

c)      Duration: both session and permanent Cookies

Third party Cookies

            Google Analytics cookies:

a)      Purpose: Cookies provided by Google Inc. to monitor, in anonymous and aggregate form, the statistical analysis of Users’ traffic on the Website in order to customise the Website in regard with the Users’ interest emerged from such analysis.

b)      Collected Data: Data related to the computer and the User’s visit on the Website. Such Data, under no circumstances, permit Euroengel to independently trace Users’ Personal Data: (i) the domain from which the User accesses to the internet; (ii) the web address, where available, from which the User accesses to the Website; (iii) the time and date of the access to the Website, for how long it lasted, and which pages have been visited; (iv) the internet protocol address (IP) of the User; (v) the computer’s operating system and the browser used by the User; (vi) the aggregated demographic details of the Users that access to the Website.

c)      Duration: session Cookies.

For further information regarding Google analytics, the User may refer to the following link: https://tools.google.com/dlpage/gaoptout.

11. Acceptance or waver of Cookies

Implicit consent, banner, access to the browsers’ control panels, Your Online Choices service

The User will be able to give their consent for the use of the Cookies described in the above section 10 through the following procedures:

1.      Proceeding with the navigation on the Website or accessing any area of the Website; or

2.      Clicking on the “Accept” option of the informative banner on Cookies, shown on the Website.

The expression of consent may be, at any time, modified by the User in accordance with the indications found in this Privacy Policy, which is available at the link within the banner and in each page of the Website (footer). For this purpose, the User may as well contact at any moment Euroengel to obtain information concerning the practical procedures though which they may exercise their selective consent or rejection, or delete the Cookies.

However, Euroengel specifies that, by deactivating the technical Cookies referred to in the above section 10, the correct navigation within the Website could be impeded and/or its usability limited.

Therefore, to better benefit from Euroengel’s services available through the Website, the User is strongly advised against proceeding with the deactivation of said technical Cookies.

That being said, the User may modify the settings concerning all Cookies of the Website, in accordance to the procedures provided for in the control panels of the browser used, such as, by way of example:

·            Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=fr&hlrm=en

·            Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

·            Internet Explorer: https://support.microsoft.com/en-us/products/windows?os=windows-7

·            Safari: https://support.apple.com

Moreover, with specific regard to profiling and advertising Cookies, in addition to using the means provided for by the browser to activate or deactivate single Cookies, Euroengel informs the User that the website www.youronlinechoices.com lists the main providers that work with the operators of websites to gather and employ information useful for the utilisation of behavioural advertising. The User may deactivate or activate all companies (included herein the Company) or, alternatively, individually adjust their preferences for each company. To do so, the User may use the tool found at the following link www.youronlinechoices.com/it/le-tue-scelte to control each preference on behavioural advertising provided during internet browsing.

 

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