Privacy and cookie policy for the website: www.consulcesigroup.com
Consulcesi SA with registered offices in Via G. Motta 6, 6828 Balerna (CH) (hereinafter “Consulcesi” or the “Data Controller”) is constantly committed to protecting the online privacy of its users. This document was drawn up pursuant to art. 13 of Regulation (EU) 2016/679 (hereinafter: “Regulation“) in order to allow you to know our privacy policy, to understand how your personal information is managed when you use our website (hereinafter also the “Website“) and, where appropriate, to give specific and informed consent to the processing of your personal data. The information and data you provide, or that is otherwise obtained by way of the use of the Website’s services, will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that inspire Consulcesi’s activity.
According to the provisions of the Regulation, the processing carried out by the Data Controller will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitations, data minimisation, accuracy, integrity and confidentiality.
INDEX
1. Data Controller and Data Protection Officer “DPO”
The Data Controller for the processing carried out through the Website is Consulcesi SA, as defined above, which may be contacted at the address: Via G. Motta 6, 6828 Balerna (CH), or at the email address: privacy@consulcesi.ch.
The Data Controller’s Representative for the European territory is Consulcesi Homnya S.r.l., via G. Peroni 400, 00131 Roma; e-mail: privacy@consulcesihomnya.com.
The Data Protection Officer (hereinafter, “DPO”) may be contacted at: tel: +39.02.96515401; email: consulcesi.dpo@avvera.it.
2. Personal data being processed
Please be informed that following the browsing of the Website, the Data Controller will process your personal data which may consist of an identifier such as the name, an identification number, an online identifier or one or more factors specific to your physical, economic, cultural or social identity suitable to making the data subject identified or identifiable (hereinafter also just “personal data”).
The personal data processed through the Website are the following:
a. Navigation data
During their ordinary operation, the computer systems and software procedures used to run the Website, collect some Personal Data whose transmission is inherent in the use of Internet communication protocols. This is not information that is collected to be associated with identified data subjects, but information that may, by its very nature, allow users to be identified after processing and association with data held by third parties. This category of data includes IP addresses or the domain names of computers used by users connecting to the Website, the URI (Uniform Resource Identifier) address notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the response file, the numerical code indicating the status of the server’s response (successful, error, etc.) and other parameters regarding the operating system and the user’s IT environment. This data is only used to obtain anonymous statistical information on the Website’s use and for the purposes of monitoring its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to establish liability in case of IT crimes against this website or third parties.
b. Special categories of personal data
In using some sections of the Website, a provision of your personal data that falls within the category of special categories of Personal Data as referred to in art. 9 of the Regulation may take place, verbatim the “[…] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”. Please communicate such data only where necessary. In fact, we hereby remind you that in the face of transmissions of special categories of Personal Data, but in the absence of a specific indication of consent to process such data, Consulcesi cannot be held liable in any way, nor would any claim to that effect be receivable, as in such case processing will be permitted as it would relate to data manifestly made public by the data subject in accordance with the requirements of art. 9.2.e) of the Regulation.
In any event, should you wish to share the aforesaid data, we wish to specify, as already specified above, the importance of indicating your explicit consent to the processing of special categories of personal data.
Please also note that, for selection purposes, Consulcesi could analyse the social profiles of professional nature which you have made freely available on the Internet (by way of example, but not limited to, the portal called LinkedIn).
c. Data supplied voluntarily by the data subject
In using some Website Services, the processing of third parties’ personal data which you have sent to Consulcesi could take place. With respect to these instances, you are posing as an independent data controller, taking on all legal obligations and responsibilities. In this respect, you grant the most extensive indemnity with respect to any dispute, claim, request for damage compensation for processing, etc. that Consulcesi should receive from third parties whose personal data have been processed through your use of the Website’s features in breach of the applicable regulations on personal data protection. In any case, should you provide or otherwise process personal data of third parties in using the Website, you warrant, as of now – taking on all related responsibilities – that such specific processing case is grounded on an appropriate legal basis pursuant to art. 6 of the Regulation which legitimizes the processing of the information in question.
d. Cookies
The cookies that are on the Website are indicated at the following link: http://www.consulcesigroup.com/cookie-policy
Cookie settings
The user may disable (fully or partially) technical and functional cookies through its browser’s specific features. Nonetheless, please be informed that not authorizing technical cookies could make it impossible to use the Website, view its contents and use the related services. Inhibiting functional cookies could mean that some services or certain features of the Website may not be available or could not work properly, and you could be forced to manually modify, or enter, some information or preferences each time upon visiting the Website.
The choices made in relation to the Website’s cookies will in turn be recorded into a specific cookie. In some circumstances, however, said cookie may not work properly: in such instances, we suggest deleting unwanted cookies and also inhibiting their use through the browser’s features.
If you use different devices or browsers to access the Website, your cookie preferences will need to be reset.
How to view and modify cookies through your browser
You can authorize, block or disable (fully or partially) cookies through specific features on your browser. For more information on how to set preferences on the use of cookies through the Browser, please refer to the applicable instructions:
• Internet Explorer
• Firefox
• Chrome
• Safari
3. Purpose of the processing
The processing we intend to carry out, following your specific consent where necessary, is for the following purposes:
a. to allow the provision of the Services you have requested, namely: i) access to the restricted-access area of the Website; ii) the request to be contacted by Consulcesi; iii) to conclude a contract;
b. to respond to requests for support or information;
c. fulfil potential legal, accounting and tax obligations.
d. direct sales, marketing and profiling. Following a prior explicit and specific consent, the data provided may be processed for purposes of direct sales and/or to send promotional and marketing communications, there including sending newsletters and market research, by automated means (sms, mms, email, push notifications, fax) and non-automated means (ordinary mail, or via a telephone operator), as well as to analyse personal details, purchase choices and behavioural preferences on the Website in order to better structure communications and personalized commercial offers, to carry out general analyses and for profiling activities in general.
It is also possible that processing of personal data, sent by you, relating to third parties can take place and be carried out by the Data Controller. With respect to these instances, you are posing as an independent data controller, taking on all legal obligations and responsibilities. In this respect, you grant the most extensive indemnity with respect to any dispute, claim, request for damage compensation for processing, etc. that the Data Controller should receive from third parties whose personal data have been processed by way of your spontaneous submission in breach of the applicable regulations on personal data protection. In any case, should you provide or otherwise process personal data of third parties, you warrant, as of now, taking on all related responsibilities, that such specific processing case is grounded on an appropriate legal basis which legitimizes the processing of said information.
4. Legal basis and the mandatory or optional nature of the processing
The legal basis for the processing of personal data for the purposes referred to in section 3 (a-b) is art. 6.1.b) of the Regulation as the processing is necessary for the provision of the Services or in response to requests by the data subject. 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, to respond to requests and to assess the CVs.
The purpose referred to in section 3.c represents a legitimate processing of personal data pursuant to art. 6.1.c) of the Regulation. Once the personal data has been provided, the processing is indeed necessary for compliance with a legal obligation to which Consulcesi is subject.
Following a prior explicit and specific consent, the data provided for the purposes referred to in section 3.d may be processed to carry out direct sales and/or to send promotional and marketing communications, there including sending newsletters and market research, by automated means (sms, mms, email, push notifications, fax) and non-automated means (ordinary mail, or via a telephone operator), as well as to analyse personal details, purchase choices and behavioural preferences on the Website, in order to better structure communications and personalized commercial offers, to carry out general analyses and for profiling activities in general. The legal basis for the processing of your data for said purposes is art. 6, paragraph 1, letter a) of the Regulation. Commercial profiling processing and direct marketing processing are optional and they depend on the user’s free choice; therefore failure to provide consent for these purposes will not affect the use of the services provided. For the processing carried out for the purpose of sending its own advertising material directly or carrying out its own direct sales or to carrying out its own market research or commercial communications relating to the Data Contoller’s products or services similar to those purchased, Consulcesi may use, without the data subject’s consent, the e-mail and physical addresses pursuant to and within the limits allowed by art. 130, paragraph 4 of the Code and the Data Protection Authority’s provision for the protection of personal data dated 19 June 2008. The legal basis for the processing of your data for this purpose is art. 6, paragraph 1, letter f) of the Regulation. The data subject may object to this processing at any time, at first, or in subsequent communications, in a manner that is easy and free of charge, also by writing to the e-mail address: privacy@consulcesi.ch, and the data subject may also obtain an immediate response confirming the discontinuation of said processing (art. 15 of the Regulation).
Where necessary, specific summary information notices on the processing of personal data and requests for consent prepared for specific services will be gradually reported or displayed on the Website’s pages.
5. Recipients of the personal data
For the purposes referred to in section 3 above, your personal data may be shared with:
a. individuals or entities who typically act as data processors pursuant to art. 28 of the Regulation, namely: i) people, companies or professional firms that provide assistance and advice to the Data Controller in matters of accounting, administration, legal, tax, financial and credit recovery pertaining to the provision of the Services; ii) individuals or entities with whom an interaction is necessary for the provision of the Services (for example hosting providers); iii) or individuals or entities delegated to carry out technical maintenance activities (there including maintenance of network infrastructures and equipment as well as electronic communication networks); (collectively referred to as “recipients”); the list of data processors who process data may be requested from the Data Controller or the DPO by writing to the following addresses: privacy@consulcesi.ch; consulcesi.dpo@avvera.it.
b. independent subjects, body corporates or authorities, that are data controllers, to whom communicating your personal data is mandatory pursuant to legal provisions or requests by the authorities;
c. people, authorized by Consulcesi to process Personal Data pursuant to art. 29 of the Regulation, as doing so is necessary in order to carry out activities strictly related to the provision of the Services, which have undertaken to respect the confidentiality or that are adequately legally bound to confidentiality (e.g. Consulcesi employees);
d. subject to your specific consent, third parties with whom the Data Controller has entered into commercial agreements and/or affiliations, belonging to the following categories: communication and marketing professionals as well as companies; professionals and companies operating in fields such as legal, tax/fiscal, financial, accounting/administrative, insurance, education; professionals and companies in sectors such as healthcare and medical/pharmaceutical as well as providers of leisure services, for their marketing and promotional communication purposes.
6. Transfers of personal data
As for the potential transfer of Data to Third Countries, the Data Controller informs that the processing will take place in accordance with one of the methods permitted by the applicable law, such as the data subject’s consent, the adoption of Standard Clauses approved by the European Commission, and the selection of subjects, individuals or entities, adhering to international programs for the free circulation of data or operating in countries that the European Commission considers safe. More information is available, upon request, from the Data Controller at the above-indicated contact details.
7. Storage of personal data
Personal data processed for the purposes referred to in section 3 (a-b) will be stored for the time strictly necessary to accomplish the purposes for which they are processed in compliance with the principles of storage minimization and limitation pursuant to art. 5.1.e) of the Regulation. In any event, Consulcesi shall process personal data for as long as necessary to fulfil contractual and legal obligations.
More information on the duration of data storage, and the criteria used to determine this period of time, may be requested from the Data Controller, in writing, at the email address privacy@consulcesi.ch or from the DPO at the following addresses: Largo Boccioni 1, 21040 Origgio (VA) ; email: consulcesi.dpo@avvera.it.
8. Rights of the data subjects
Pursuant to articles 15 et seq. of the Regulation, you have the right, at any time, to request access to your Personal Data, to request the rectification or erasure of the same, and request the restriction of processing of personal data for those cases provided for by art. 18 of the Regulation, and you have the right to obtain the data concerning yourself in a structured format, in a commonly used form that is readable by an automatic device for those cases provided for by art. 20 of the Regulation. Pursuant to art. 7 of the Regulation, you may withdraw your consent at any time; and if you believe that the processing of your data is contrary to the applicable law, you may lodge a complaint with the competent supervisory authority pursuant to art. Article 77 of the GDPR (Data Protection Authority) of the Regulation.
You may lodge a request whereby you object to the processing of your data pursuant to article 21 of the GDPR, and where you substantiate the reasons and grounds for the objection: the Data Controller reserves the right to assess the application, which would not be accepted should there be compelling legitimate grounds for the processing which override your interests, rights and freedoms.
Requests should be sent in writing to the Data Controller at the email address privacy@consulcesi.ch, or to the representative for the territory: via G. Peroni 400, 00131 Rome; email: privacy@doctacomunicazione.it.
9. Changes
The Data Controller reserves the right to change, in whole or in part, or simply update the contents of the privacy policy, also pursuant to changes in the applicable law. You shall be informed of such changes as soon as they will be introduced, and the same shall be binding as soon as they will be published on the Website. Consulcesi therefore encourages you to visit this section on a regular basis so that you are informed of the most recent and updated version of the privacy policy in order to always be updated on the data collected and on the use of such data by the Data Controller.
Last updated: 03.08.2020