Engineering Ingegneria Informatica S.p.a. with headquater in Piazzale dell’Agricoltura, 24 – 00144 (hereinafter“Engineering”) constantly undertakes to protect the online privacy of its users. This document was drafted pursuant to art. 13 of EU Regulation 2016/679 (hereafter: “Regulations”) in order to let you know our privacy policy, to understand how your personal information is handled when you are using our sites (www.dmcoach.eu, hereinafter collectively “Site” ) and, where appropriate, to give a expressed and aware consent to the processing of your personal data. The information and data you have provided or otherwise acquired in the context of using the services of Engineering, hereinafter “Services”, will be processed in compliance with the provisions of the Regulations and the confidentiality obligations that inspire the activity of Engineering.

According to the rules of the Regulations, the processing carried out by Engineering will be based on the principles of lawfulness, correctness, transparency, purpose and retention limits, data minimization, accuracy, integrity and confidentiality.

1. Data Controller

The Data Controller processed through the Website is Engineering as defined above. For any information regarding the processing of personal data by Engineering, including the list of data processors, you can write to the following address: dpo.privacy@eng.it.

2. Personal data processing

Following the navigation of this website, we inform you that Engineering will process personal data that may be made up of an identifier such as the name, an identification number, an online ID or one or more characteristic elements of your physical, physiological, psychic, economic identity, cultural or social suit to make the data subject identified or identifiable (hereinafter only “Personal Data“).

Personal data processed through the website are the following:

2.1. Navigation data

The computer systems and software procedures used to operate the Site, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This informations are not collected to be associated with identified subjects, but by their very nature could allow to identify users, through processing and association with data held by third parties. This category of data includes IP addresses or domain names of the computers used by users who connect to the website, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters related to the operating system and the user’s computer environment. These data are used for the only purpose to obtaining anonymous statistical information on the use of the website and to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes to the detriment of the site or third parties: except for this possibility, the data on web contacts do not persist for more than thirty days.

2.2. Data provided voluntarily by the data subject

Using some website services, personal Data may be processed by third parties sent by you to Engineering. With respect to these assumptions, you are the independent data controller, assuming all the legal obligations and responsibilities. In this sense, it confers on the point the widest indemnity with respect to any dispute, claim, request for compensation for damage from treatment, etc. that it should reach Engineering from third parties whose Personal Data have been processed through its use of the functions of the website in violation of the rules on the protection of applicable personal data. In any case, if it provides or otherwise processes Personal Data of third parties in the use of the website, it guarantees from now – assuming all related liability – that this particular hypothesis of treatment is based on an appropriate legal basis pursuant to art. . 6 of the Regulation that legitimizes the processing of the informations.

2.3. Cookie

Definitions, characteristics and application of the legislation

Cookies are small text files that the sites visited by the user send and record on his computer or mobile device, to be then re-transmitted to the same sites at the next visit. Thanks to cookies, a site remembers the user’s actions and preferences (such as login data, the chosen language, font size, other display settings, etc.) so that they do not have to be re-indicated when the user returns to visit that website or browse from one page to another. Cookies, therefore, are used to perform computer authentication, monitoring sessions and storing information regarding the activities of users accessing a site and may also contain a unique identification code that allows you to track the user’s navigation inside of the site itself for statistical or advertising purposes. During navigation on a website, the user can also receive on his computer cookies from websites or web servers other than the one he/she is visiting (c.d. “third party” cookies). Some operations could not be performed without the use of cookies, which in some cases are therefore technically necessary for the same functioning of the website.
There are various types of cookies, depending on their characteristics and functions, and these can remain on the user’s computer for different periods of time: c.d. session cookies, which are automatically deleted when the browser is closed; CD. persistent cookies, which remain on the user’s equipment until a pre-established expiry date.

According to the italian legislation, the user’s express consent is not always required for the use of cookies. In particular, “technical cookies”, ie those used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not require such consent. In other words, these are cookies that are essential for the operation of the website or necessary to perform activities requested by the user.

Among technical cookies, which do not require an express consent for their use, the Italian Data Protection Authority (see Determination of the simplified procedures for information and the acquisition of consent for the use of cookies May 8, 2014 and subsequent clarifications, hereinafter only “Determination“) also includes:

  • “analytics cookie ” when used directly by the website operator to collect information, in aggregate form, on the number of users and how they visit the website;
  • “cookies browsing or session” (to authenticate);
  • “cookies functionality”, which allow the user to navigate according to a series of selected criteria (for example, the language, the products selected to purchase) in order to improve the service provided.

“Profiling cookies”, instead, ie that create profiles related to the user and used to send advertising messages in line with the preferences expressed by the same in the context of web browsing, it’s required a prior consent by the user.

Types of cookies used by the Site and the possibility of (de-) selection

The Website uses the following cookies:

  • Technical cookies for navigation or session and strictly necessary for the operation of the website or to allow it to use the content and services requested.
  • Functional cookies, that is used to activate specific functions of the website and a series of selected criteria (for example, the language) in order to improve the service rendered.

Cookie settings

You can block or delete (in whole or in part) technical and functional cookies through the specific functions of your browser. We inform you, however, that if you don’t allow technical cookies it could be impossible to use the website, view the contents and take advantage of the related services. Inhibiting functional cookies could mean that some services or certain functions of the website are not available or do not work properly and you may be forced to change or manually enter certain information or preferences each time you visit the website.

The choices made in reference to cookies on the website will be registered in a special cookie. This cookie may not work properly, however, in some circumstances: in such cases, we advise you to delete unwanted cookies and to inhibit their use through the functionality of its browsers.

Your preferences regarding cookies will be reset if you use different devices or browsers to access the website.

How to view and modify cookies through the Browser

You can authorize, block or delete (in whole or in part) cookies through the specific functions of your browser. For more informations on how to set preferences on the use of cookies through the browser, you can consult the relevant instructions

3. Processing finality

The treatment we intend to carry out, with its specific consent where necessary, has the following purposes:
a. Allow the provision of the Services requested by you
b. respond to requests for assistance or information;
c. fulfill any legal, accounting and tax obligations.

4. Law basis and mandatory or optional processing

The legal basis of the Personal Data processing for the purposes set out in Section 3 (a-b-c) is art. 6 (1) (b) of the Regulations as the processing is necessary for the provision of the Services or for the response of requests by the interested party. The provision of Personal Data for these purposes is optional, but failure to provide it would make it impossible to activate the Services provided by the website, find requests or evaluate CVs. With specific reference to the objective 3.c and to the connected analysis of the professional social profiles freely available on the Internet as per section 2.b, the legal basis of the processing is art. 6 (1) (f) of the Regulations, ie the legitimate interest of Engineering to verify any risks on the suitability of the candidate to hold the specific position.

The purpose set out in section 3.d represents a legitimate processing of Personal Data pursuant to art. 6 (1) (c) of the Regulation. Once the Personal Data have been provided, the processing is indeed necessary to fulfill a legal obligation to which Engineering is subject.

The legal basis of the processing for the purposes referred to in section 3.e is the legitimate interest of the Data Controller pursuant to art. 6 (1) (f) of the Regulation.

5. Recipients of personal data

Your Personal Data may be shared, for the purposes referred to in Section 3 above, with:

a. subjects that typically act as data controllers, that is: i) persons, companies or professional firms that provide assistance and advice to Engineering in accounting, administrative, legal, tax, financial and debt collection with respect to the provision of the Services; ii) subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers) iii) or subjects delegated to perform technical maintenance activities (including maintenance of network equipment and electronic communications networks); (collectively “Recipients“);
b. subjects, bodies or authorities that are obliged to communicate their personal data in accordance with the provisions of law or orders of the authorities;
c. persons authorized by Engineering to the processing of Personal Data necessary to carry out activities strictly related to the provision of the Services, which are committed to confidentiality or have an appropriate legal obligation of confidentiality (eg employees of Engineering).

6. Personal data transfer

Some of your Personal Information are shared with Recipients that could be found outside the European Economic Area. Engineering ensures that the processing of their Personal Data by these Recipients takes place in compliance with the Regulation. Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another appropriate legal basis. Further informations are available at Engineering by writing to the following address dpo.privacy@eng.it

7. Data Retention

Personal Data processed for the purposes set out in section 3 (a-b) will be kept for the time strictly necessary to achieve those same purposes. In any case, since these are treatments performed for the provision of Services,Engineering will process Personal Data up to the time allowed by Italian law to protect its own interests (Art. 2946 c.c. and ss.).

Data processed for the purposes set out in section 3.c will be kept until the time required by the specific obligation or applicable law.

Further information on the data retention period and the criteria used to determine this period may be requested by writing to DPO to the following address dpo.privacy@eng.it.

8. Data subject rights

Pursuant to articles 15 and following of the Regulation, you have the right to ask Engineering, at any time, access to your Personal Data, to rectify or cancel them or to oppose their treatment, you have the right to request the limitation of the processing in the cases foreseen by the art. 18 of the Regulations, as well as obtaining, in a structured format, in common use and readable by automatic device, the data concerning it, in the cases provided by art. 20 of the Regulation.
Requests must be sent in writing to Engineering at the following address: dpo.privacy@eng.it.
In any case, you are always entitled to propose a complaint to the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulations, if you believe that the processing of your Personal Data is contrary to the law.

9. Change

This privacy policy is effective from 2018 25th May. Engineering reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. Engineering will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the website. Engineering therefore invites you to regularly visit this section to get to know the most recent and updated version of the privacy policy in order to be always updated on the data collected and its use Engineering.

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