Privacy Policy
Art. 13 Reg. (EU) 2016/679
In compliance with Article 13 of Regulation (EU) 2016/679 (GDPR), the following information is provided to the users of the online portal that can be reached at www.ingeding.it ("Portal"), which refers exclusively to the processing performed through said Portal and not through other websites that may be visited through links that are present on the Portal, in relation to which it is suggested reading the relevant policies made available by the respective owners.
DATA CONTROLLER: INGEDING S.r.l., with registered office at Corso Rosmini No. 53-A, 38068, Rovereto (TN), VAT No. 02663180228. References for any inquiries: e-mail contact@ingeding.it.
CATEGORIES OF PROCESSED DATA, PURPOSE and LEGAL BASIS OF THE PROCESSING
Categories of processed data: first name, last name, e-mail address, and any personal data included in the message sent through the means of communication available on the Portal.
Purpose: to acknowledge the user's requests sent through the interaction methods available on the Portal, or to the e-mail addresses available on the Portal.
Legal basis: performance of a contract to which the data subject is a party/execution of pre-contractual measures taken at the data subject's request - art. 6.1.(b) GDPR.
Categories of processed data: navigation data (personal data whose transmission is implicit in the use of Internet communication protocols, for example IP addresses or domain names of computers used by users, the time of the request and other parameters related to the user's operating system and computer environment.
Purpose: to allow the user to browse the Portal.
Legal basis: performance of a contract to which the data subject is a party/execution of pre-contractual measures taken at the data subject's request - art. 6.1.(b) GDPR.
Categories of processed data: first name, last name, e-mail address, date of birth/age, username, professional registration number, VAT number, fiscal code and other billing data, images depicting the data subject.
Purpose: to enable the creation of a personal account for the user on the Portal and the publication of offers on the Portal and/or otherwise the use of its features.
Legal basis: execution of a contract to which the data subject is a party/execution of pre-contractual measures taken at the data subject's request - art. 6.1.(b) GDPR.
Categories of processed data: first name, last name, e-mail address, phone number, physical address, credit card or other payment method data.
Purpose: to enable the user to pay the annual fee for the creation of their account.
Legal basis: performance of a contract to which the data subject is a party/execution of pre-contractual measures taken at the data subject's request - art. 6.1.(b) GDPR.
Categories of processed data: first name, last name, e-mail address.
Purpose: direct marketing activities by sending communications or material (e.g., via e-mail, newsletter) with respect to products/services similar to those for which the user has requested information through the Portal.
Legal basis: legitimate interest of the Data Controller - art. 6.1.(f) GDPR. The legitimate interest of the Data Controller is identified as the promotion of its business through direct marketing - see Recital 47 of the GDPR.
Categories of processed data: first name, last name, residential address, contact details, history of the user's operations on the Portal.
Purpose: management of any disputes arising from the subscription for the Portal and/or otherwise in relation to the relationship between the user and the Data Controller within the Portal.
Legal basis: legitimate interest of the Data Controller - art. 6.1.(f) GDPR. The legitimate interest of the Data Controller is identified in the possibility of ascertaining, exercising, defending any of its rights and/or defending itself against any claims.
Categories of processed data: first name, last name, e-mail address, date of birth, residential address.
Purpose: marketing activities by sending newsletters to the user's e-mail address, possibly even targeted marketing.
Legal basis: consent given by the user - art. 6.1.(a) GDPR.
Categories of processed data: images depicting the data subject, name, general information about the performance of the profession of engineer/architect/engineer.
Purpose: marketing and other promotional activities, through the publication of data on the Portal, on social channels that refer to the Data Controller, trade magazines (both printed and digital), advertisements and other promotional channels.
Legal basis: consent given by the user - art. 6.1.(a) GDPR.
Categories of processed data: first name, last name, residential address, fiscal data.
Purpose: accounting management of payments for the annual fee required for the creation of the account.
Legal basis: legal obligation to which the Data Controller is subject - art. 6.1.(c) GDPR.
Sensitive data (i.e., those concerning religious beliefs, trade union membership, sexual preferences, and others specified in Article 9 of the GDPR) are not processed through the Portal, and we ask all users not to include them already in the contact submission phase through the Portal, or in other forms of interaction provided by the Portal.
MANDATORY NATURE OF THE DISCLOSURE
The disclosure of data for marketing purposes is optional, and failure to provide such data, as well as lack or revocation of consent, will not affect the ability to navigate the website, subscribe to the Portal, and use it. The provision of other data is necessary to navigate the website and/or to finalize subscriptions through the Portal. Failure to provide the data may result in the inability to navigate the website and/or subscribe to the Portal and/or use its features.
POSSIBLE RECIPIENTS OF THE PERSONAL DATA
The data may be disclosed to (i) third parties operating, on behalf of the Data Controller, for the performance of the services related to the purposes indicated in this Privacy Policy, and in particular the management and maintenance of the Portal, activities for its promotion etcetera; (ii) consultants of the Data Controller, for example tax consultants; (iii) authorities and public entities to whom communication is mandatory.
The data will not be transferred outside the European Economic Area.
PERIOD OF STORAGE
The data shall be stored for a maximum of 10 (ten) years from the date of the last interaction with the user, in consideration of the statute of limitations for any claims arising from the relationship between the Data Controller and the user, provided by the law. Browsing data shall be kept for the technical time necessary to perform the functions for which they were collected.
PROFILING
The user's date of birth, professional register, and residential address may be used to create a user profile and send targeted marketing possibly of greater interest to the user. Such profiling shall not bear legal effects for the user.
RIGHTS OF THE DATA SUBJECT
At any time each user may assert against the Data Controller the rights provided for in Articles 15 to 22 of the GDPR, i.e. the right to request:
- a. access to personal data, i.e. to know their personal data stored by the Data Controller, the purposes of their processing, their origin and other information provided for in Article 15 of the GDPR;
- b. the rectification of personal data in case of their inaccuracy;
- c. the deletion of personal data (so-called 'right to be forgotten');
- d. the limitation of the processing of personal data, i.e., the right to obtain the suspension of the processing of personal data for the period necessary to verify the request for the correction of personal data, or in the other cases provided for in Art. 18 of the GDPR;
- e. data portability, i.e. to receive in a structured, commonly used and machine-readable format, personal data – including by requesting their direct transfer to another Data Controller (with respect to those data whose processing is carried out by automated means);
- f. the right to ask the Data Controller to refrain from processing the data pursuant to Article 6(1)(e) or (f) of the GDPR (right to object);
- g. the right to file a complaint pursuant to Article 77 et seq. of the GDPR to a supervisory authority, which for the Italian State is identified in the Data Protection Authority (Garante per la protezione dei dati personali);
- h. the right to revoke consent at any time by written notice to the Data Controller, without affecting the legitimacy of the processing carried out before such revocation.
MODIFICATIONS TO THIS PRIVACY POLICY
This Privacy Policy may be subject to changes over time - including those related to the possible entry into force of new sector regulations, to the update or provision of new services or to intervening technological innovations. Changes to the Privacy Policy become applicable at the time of their publication on the Portal, it being understood that the Data Controller may not process the previously collected data for purposes other than those described herein, without informing the user.
Last update: March 23, 2022