Information on the processing of personal data

(General Data Protection Regulation - UE 2016/679)

 

  

1.       Introduction.

 

1.1 This Privacy Policy ("Policy") sets out how ILSA S.p.A., whose registered offices are at Via Roveggia n. 31 -37136 Verona (VR) (hereinafter ‘’company’’, "we", "us", "our") use your personal information.

  

1.2 The Company is primarily responsible to you for any questions, concerns or complaints you may have about this Policy or our handling of your information.

 

1.3 If you have questions, please contact the Data Controller, in the person of Vidhyadhar Belapure, at:

 

E-mail: infoilsa@huber.com 

Telephone:  +39 0444 452020

1.4 If you would like to access previous versions of this Policy please click here or, alternatively, you can contact us by email to infoilsa@huber.com.

 

2.       Information we collect.

 

2.1  Information you give us. You may give us information, including information that can identify you ("personal information"), when you use our Website, correspond with us, enquire about or purchase our goods or services. Where we request information from you, we will collect the information set out in the relevant forms or pages. You may choose to provide additional information to us when you contact us or otherwise interact with us.

 

2.2 We collect your personal information when you communicate with us whether in person, through our Website, email, over the phone, or via any other medium. For example, we collect your contact details and the details of our messages to you and from you (including when you sent it, when we received it and where you sent it from).

 

2.3 If you are a regular visitor of our Website or wish to access to specific services, you must create an Account ("Account") with us. The information that you provide when setting up your Account may include your name, email address, company name, company contact and telephone numbers. If you register to hold an Account with us, you will also have a unique password which enables you to access your Account.

 

2.4 If you subscribe to receive one of our newsletters, or receive other forms of direct communications from us, then you may have to provide us with your name, email address and company name, company contact and telephone numbers.

2.5 You may also provide us with personal data (such as the content and circumstances of your communication with us and your contact details) in order to receive additional information and/or services. The data will be processed by us exclusively for the purpose strictly related to your request. The refusal to provide that data may affect the possibility of you receiving the service or information requested.

2.6  Information we collect automatically. When you visit our Website, we may automatically collect the following information: your IP address, log-in information, browser type and version, browser plug-in types and versions, operating system and platform, information about your visit including the URL clickstream to, through and from our Website, products you viewed or searched for, download errors, timing and length of visits to certain pages and page interaction. We collect information automatically through the use of various technologies, including through "cookies" (please see section 8 of this Policy below).

2.7  We also collect information about you through our security systems when you visit our premises or attend our events.

2.8  Information we receive from other sources. We may receive information about you from other sources if you use any of the other services we provide on this Website, or from other members of the Group. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers) and may receive information about you from them (including information that is publicly available).

2.9  Special category data. We may receive information from you or other sources which falls within the meaning of 'special category data'.  

3.       How we use your information.

 

3.1 We use the information we collect in order to provide you with the best possible experience when you access our Website and engage with us, including by buying or using our services and products. This includes using your information for the following purposes:

(a)  providing and improving our products and services to you or your company: we use your information in order to provide you with, and improve, the products and services you or your company have requested, including when making purchases, sending you confirmation emails or contacting you regarding your Account. This also includes using your information to make payment to you or your company or take payment from you or your company. We use your information to improve our products and services to better suit the technical capabilities of our customers;

(b)  creating and managing your Account: we use your information in order to create your Account, create a profile of you on our systems and manage our relationship with you. We also use your information to communicate with you regarding your Account and our services;

(c)  administering the Website: we use your information in order to administer our Website for internal operations, including troubleshooting purposes and to understand any errors you may encounter when using our Website;

(d)  safety and security: we use information collected on our Website as part of our efforts to keep our Website safe and secure and to help manage and administer our IT systems;

(e)  marketing: we use your information in order to communicate with you and keep you up to date with our activities and those of the Group companies that you may be interested in and to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them. We will provide you with this information via email, telephone or smartphone. For more details on how we will market to you, please see section 6 of this Policy below;

(f)  online advertising: we use your information in order to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. For more details please see section 7 of this Policy below. We also use your information when communicating with you through social media in order to build and maintain our social media brand;

(g)  investigating any complaints and providing customer service: we may use your information in order to investigate any complaints on your behalf and to provide you with a more efficient customer care service. We may also use your information to ensure the quality and effectiveness of our handling of complaints or customer service requests;

(h)  recruitment: We accept online applications to work in our company through the 'Contact' page of the Website. We will receive the information provided in the application and supporting documentation (which may include a curriculum vitae and covering letter). We will use your personal information only for the purposes of progressing the possible recruitment process, assessing and making a decision about your suitability for a role, communicating with you and carrying out reference checks.  We will also use your information to comply with legal and regulatory requirements;

(i)  to make necessary disclosures: we may use your information in order to make necessary disclosures in response to requests which we are legally required to comply with, to law enforcement or regulatory authority, body or agency or in the defence of a legal claims.

4.       Why we use your information.

 

4.1 Our processing of your personal information will be based on a variety of legal grounds, including:

 

(a)  where the processing is necessary for the purposes of our legitimate interests: this includes, for example, to: (1) provide our products and services to you; (2) ensure your Account is adequately protected and to ensure that our Website, network and information technology are secure and are being used in an appropriate manner; (3) better understand how you use our products, services and Website and to make improvements; (4) research and analyse the products and services you want; [(5) tailor our content and offers to those more relevant to you]; (6) provide security over our business and who we partner with; and (7) develop and maintain relationships with vendors, partners and other companies and dealing with individuals who work for them;

(b)  where we need to comply with a legal obligation: for example, we may need to disclose your data to a law enforcement agency or to your or our representatives acting in a legal dispute;

(c)  where you have provided your consent: for example, we may require your consent when using technologies such as cookies.

4.2 If you would like to have more information about our legitimate interests to process your personal data, please contact us at infoilsa@huber.com.  

4.3 If you are unable or do not want to provide the personal information we need in order to perform a contract with you or comply with a legal obligation, this may result in us not being able to facilitate your request.

5.       How we share and disclose your information.

 

5.1 We may share your information with other companies belonging to the same Group for the purposes outlined at section 3 of this Policy and with the third parties identified in this Policy. We may also share your information with third parties when: (1) it is necessary to involve a third party service provider in order to facilitate or extend our services; (2) explicitly requested by you; (3) required by a court order or any legal or regulatory requirement; (4) in connection with the sale, transfer or reorganisation of a business; (5) to enforce our contracts and if we are defending a legal claim your information may be transferred as required in connection with defending such claim; (6) to ensure the safety and security of our users, customers, consumers and third parties; and (7) to protect our rights and property and the rights and property of our guests and third parties.

  

5.2 These third parties include organisations providing a service to us or acting as our agents, including, but not limited to, sub-contractors (including their agents), consultants and professional advisers, IT suppliers, database providers, backup and disaster recovery specialists, email providers and other service providers necessary for improving our products and services.

 

5.3 Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your personal information, will only be provided in connection with the performance of their function. They will not be permitted to use your personal data for any purposes other than those outlined in this Policy.

6.      How to opt in or opt out of direct marketing.

 

6.1 We, and other members of the Group, may use the information you give us for direct marketing purposes to provide updates, newsletters or other communications that we think may interest you.

  

6.2 Where required by law, your prior consent will be obtained before we send you direct marketing. In any event, we will offer you the option to unsubscribe in every communication sent.

 

6.3 You may object to receiving direct marketing from us at any time by contacting us by email at infoilsa@huber.com or selecting the unsubscribe option in our email communications.

7.       Cookies and other technologies.

 

7.1 We collect information automatically through the use of "cookies". A cookie is a text file containing small amounts of information that a website can send to your browser, which may then be stored on your computer as a tag that distinguishes your computer but does not name you. Some of our Website pages use cookies to better serve you when you return to the Website. You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies; however, if you do this, some of our Website may not work properly. This information is collected in order to obtain statistical information on our Website and emails, and also to identify the features and contents preferred by each user, in order to send personalized information.

  

7.2 For information about the specific cookies used on this Website, please refer to our Cookies Policy.

8.       Links to other websites and social media.

 

8.1 Where we provide links to other websites, we do so for information purposes only. The other websites are outside our control and are not covered by this Policy. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours.

9.       Data retention.

 

9.1 We will not retain your information for longer than is necessary for our business purposes or for legal or regulatory requirements.

9.2 We will retain your information for as long as you have an Account with us and for a period after you have closed your Account with us. For example, we do this if it is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

 

9.3 We will also retain a copy of your contact details if you object or opt-out of receiving direct marketing communications from us. We will add your details to our suppression list to ensure you do not receive any future marketing communications from us. Also, we will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

10.      Your rights.

10.1 Subject to applicable law, you may have the rights set out below, in certain circumstances, in relation to your personal information. Before responding to your request, we may ask you to verify your identity and to provide further details about your request.

(a)  Right to access your personal information. If you wish to obtain a copy of the personal information that we hold about you, please contact us by email at infoilsa@huber.com.

(b)  Right to rectify, erase or restrict the processing of your personal information.  If you wish to rectify, erase or restrict the processing of your personal information please contact us by email at infoilsa@huber.com.  It is your responsibility to ensure that you submit true, accurate and complete information to us and keep this information up to date.

(c)  Right to withdraw consent. Where you have provided your consent to processing, you may withdraw your consent at any time by contacting us at infoilsa@huber.com.

(d)  Right to data portability. You can ask us to help you move some of your information to other companies. To help with that you have a right to ask that we provide your information in a machine readable format to another company. You can email your request to infoilsa@huber.com.

(e)  Right to object.  You can object to the way we process your personal information by emailing your request to infoilsa@huber.com.

(f)  Right not to be subject to an automated decision.

(g)  Right to lodge a complaint with a supervisory authority. You can get in touch with the guarantor for the protection of personal data (Tel: 06/69677.3785 or at www.garanteprivacy.it) if you have a complaint in relation to how we handle your personal information.

10.2 If you have chosen to have an Account then you can access the personal information we hold about you via your Account to obtain a copy of it and to correct, amend, or delete information that is inaccurate. You can also close your Account at any time.

 

10.3 Right to object. You have a right to object to us processing your information in certain circumstances. For example, you have a right to object to our processing of your personal data where this is based on our legitimate interests (or those of a third party). You may challenge our reliance on legitimate interests. However we may be entitled to continue processing your personal data based on the our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.

11.      Information security.

11.1 We apply physical, technical and administrative measures to protect your personal information that is under our control from unauthorised access, collection, use, disclosure, copying, modification or disposal. All information you provide to us is stored on secure servers.

11.2  Where you have a password, which enables you to access our Website, you are responsible for keeping this password secure and confidential.

12.      International transfers.

 

12.1  Given that the Internet is a global environment, using the Internet to collect and process personal information necessarily involves the transmission of data on an international basis. While we generally store all of the personal information that we collect about you through our Website, it is possible that your personal information will be transmitted to parties outside your region (where data protection laws may be different e.g. in the United States).

12.2  If such transfer happens, we have implemented safeguards and data protection solutions to ensure your information is adequately protected in these third countries [e.g. by using standard contractual clauses]. If you would like to obtain the details of such safeguards, you can request these by contacting us by email at infoilsa@huber.com.

 

13.     Changes to the Policy.

 

13.1 This Policy was last updated on 24/05/2018.  A notice will be posted on our Website home page for 30 days whenever this Policy is changed in a material or a substantial way.

14.      Questions about this Policy .

 

14.1 This Website is maintained by ILSA S.p.A. If you have a question, concern or complaint about this Policy or our handling of your information, you can contact us by email to infoilsa@huber.com.