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Privacy Policy

Privacy Policy

  1. INTRODUCTION – WHO ARE WE?

Gruppo Sirio S.r.l., with its registered office at Via V. Monti 108, 41123 Modena, VAT no. 02217510367 (hereinafter, the “Data Controller”)—owner of the website https://gruppo-sirio.it/ (hereinafter, the “Site”)—in its capacity as the data controller for the personal data of users who browse the Site (hereinafter, “Users”), provides the following privacy policy in accordance with Article 13 of EU Regulation 2016/679 of April 27, 2016 (hereinafter, the “Regulation” or “Applicable Legislation”).

  1. HOW TO CONTACT US?

The Data Controller attaches the utmost importance to the right to privacy and the protection of its Users’ personal data.

For any information regarding this privacy policy, Users may contact the Data Controller at any time using the following methods:

  • by sending a certified letter with return receipt to the Data Controller’s registered office at Via V. Monti No. 108, 41123 Modena;
  • by sending an email to the address: info@gruppo-sirio.it.

Data subjects may also contact the Data Controller’s Data Protection Officer (DPO), whose contact details are provided below: dpo@gruppo-sirio.it

  1. WHAT DO WE DO? – PURPOSES OF THE PROCESSING

In relation to the activities that can be carried out through the Site, the Data Controller collects personal data concerning the Users.

This Site and any services offered through the Site are reserved for individuals who have reached the age of eighteen. Consequently, the Data Controller does not collect personal data concerning individuals under the age of 18. Upon request by Users, the Data Controller will promptly delete any personal data that may have been inadvertently collected regarding individuals under the age of 18.

In particular, Users’ personal data will be lawfully processed for the following processing purposes:

  1. processing the User’s request regarding the possibility of establishing a collaborative relationship with the Data Controller: the Users’ personal data are collected and processed by the Data Controller solely for the purpose of handling their request concerning the possibility of establishing a collaborative relationship with the Data Controller. The User data collected by the Data Controller for this purpose include the User’s first and last name, the company they represent, their telephone number, and their email address; this also encompasses any data that the User may have voluntarily provided to the Data Controller by filling in the free-text field in the form, as well as any information contained in a curriculum vitae attached to the request.

No other processing of Users’ personal data will be carried out by the Data Controller. Without prejudice to the provisions elsewhere in this privacy policy, under no circumstances will the Data Controller make Users’ personal data accessible to other Users and/or third parties;

  1. fulfilling the User’s contact request: Users’ personal data are collected and processed by the Data Controller solely for the purpose of fulfilling their request. The User data collected by the Data Controller for this purpose include the User’s first and last name, the company they represent, their telephone number, their email address, and any other data that the User may choose to provide voluntarily. The Data Controller will not perform any other processing of the Users’ personal data. Without prejudice to any other provisions in this privacy policy, the Data Controller will under no circumstances make Users’ personal data accessible to other Users and/or third parties;
  2. provision of the Service, or to enable the User to browse the Site. The User data collected by the Data Controller for this purpose includes all personal data the transmission of which is implicit in the use of Internet communication protocols, which the IT systems and procedures software The cookies used to operate the Site acquire during their normal operation: the IP addresses or domain names of the computers used by the Users, the addresses in URI notation (Uniform Resource Identifier) of the resources requested, the time of the request, the method used in submitting the request to the server, la dimensione del file ottenuto in risposta, il codice numerico indicante lo stato della risposta data dal server (successful completion, error, etc.) and other parameters relating to the User’s operating system and IT environment. This data is used solely for the purpose of obtaining anonymous statistical information on the use of the Site and to ensure its proper functioning. Notwithstanding anything else stated elsewhere in this privacy policy, under no circumstances will the Data Controller make Users’ personal data accessible to other Users and/or third parties;
  3. administrative-accounting purposes—that is, to carry out activities of an organizational, administrative, financial, and accounting nature, such as internal organizational tasks and activities necessary for the fulfillment of contractual and pre-contractual obligations;
  4. legal obligations, that is, to comply with obligations set forth by law, an authority, a regulation, or European legislation.

Failure to provide the data will not in any way affect your ability to use the Site.

Providing personal data for the processing purposes indicated above is optional yet necessary; failure to provide such data will make it impossible to apply for a position within the Data Controller’s team.

The personal data required for the purposes of processing described in this section 3 are marked with an asterisk in the application form.

  1. LEGAL BASIS

Fulfillment of the User’s request regarding establishing contact or the possibility of entering into a collaborative relationship with the Data Controller; provision of the service (as described in the preceding paragraph 3, letters a, b, and c): the legal basis is Article 6, paragraph 1, letter b) of the Regulation, as the processing is necessary for the performance of a contract and/or for the implementation of pre-contractual measures taken at the User’s request.

Administrative and accounting purposes (as described in paragraph 3, letter d) above): the legal basis is Article 6, paragraph 1, letter b) of the Regulation, as the processing is necessary for the performance of a contract and/or for the implementation of pre-contractual measures taken at the User’s request.

Legal obligations (as described in the preceding paragraph 3, letter e)): the legal basis consists of Article 6, paragraph 1, letter d) of the Regulation, as the processing is necessary to comply with a legal obligation to which the Data Controller is subject.

  1. DATA PROCESSING METHODS AND RETENTION PERIODS

The Data Controller will process Users’ personal data using manual and electronic tools, in a manner strictly related to the stated purposes and, in any case, so as to ensure the security and confidentiality of the data itself.

The personal data of the Site’s Users will be retained for the time strictly necessary to fulfill the primary purposes outlined in the preceding paragraph 3, or otherwise as necessary to protect the interests of both the Users and the Data Controller in civil proceedings.

  1. SCOPE OF DATA COMMUNICATION AND DISSEMINATION

The User’s personal data may be transferred outside the European Union; in such cases, the Data Controller will ensure that the transfer takes place in compliance with the Applicable Law—specifically, in accordance with Articles 45 (Transfers on the basis of an adequacy decision) and 46 (Transfers subject to appropriate safeguards) of the Regulation.

The Data Controller’s employees and/or collaborators who are tasked with managing the Site and handling user requests may have access to users’ personal data. These individuals, having received instructions to this effect from the Data Controller in accordance with Article 29 of the Regulation, will process user data exclusively for the purposes specified in this privacy policy and in compliance with the provisions of the applicable legislation.

Furthermore, third parties may gain access to Users’ personal data; these parties may process such data on behalf of the Data Controller in the capacity of Data Processors—for example, providers of IT and logistics services essential to the operation of the Site, providers of outsourced or cloud computing services, as well as professionals and consultants.

Users have the right to obtain a list of any data processors appointed by the Data Controller, by submitting a request to the Data Controller in accordance with the procedures set out in paragraph 7 below.

  1. Rights of Data Subjects

Users may exercise the rights granted to them under the Applicable Law by contacting the Data Controller in the following ways:

  • by sending a certified letter with return receipt to the Data Controller’s registered office at Via V. Monti No. 108, 41123 Modena;
  • inviando un messaggio di posta elettronica all’indirizzo: info@gruppo-sirio.it.

Data subjects may also contact the Data Protection Officer (DPO) of the Data Controller, whose contact information is provided below: dpo@gruppo-sirio.it

Pursuant to the Applicable Legislation, the Data Controller informs Users that they have the right to obtain information regarding: (i) the origin of their personal data; (ii) the purposes and methods of processing; (iii) the logic applied in the event that processing is carried out with the aid of electronic tools; (iv) the identification details of the Data Controller and the Data Processors; and (v) the entities or categories of entities to whom the personal data may be disclosed or who may become aware of such data in their capacity as Data Processors or persons in charge of processing.

Furthermore, Users have the right to obtain:

  1. a) access to, updating, or rectification of the data, or—where there is an interest in doing so—the supplementation of the data;
  2. b) the erasure, anonymization, or restriction of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
  3. c) confirmation that the operations referred to in points (a) and (b) have been brought to the attention—including with regard to their content—of those to whom the data have been communicated or disseminated, unless this proves impossible or involves an effort that is manifestly disproportionate to the right being protected.

Furthermore, Users have:

  1. a) the right to withdraw consent at any time, where the processing is based on their consent;
  2. b) the right (where applicable) to data portability (the right to receive all personal data concerning them in a structured, commonly used, and machine-readable format);
  3. c) the right to object:
  4. i) in whole or in part, on legitimate grounds, to the processing of personal data concerning them, even if such data are relevant to the purpose for which they were collected.
  5. ii) in whole or in part, to the processing of personal data concerning him or her for the purpose of sending advertising or direct sales material, or for carrying out market research or commercial communication;

iii) where personal data are processed for direct marketing purposes, to object at any time to the processing of data for such purposes, including profiling to the extent that it is related to such direct marketing.

  1. d) if they believe that the processing concerning them violates the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State of their habitual residence, the place of work, or the place where the alleged infringement occurred). The Italian supervisory authority is the Italian Data Protection Authority (*Garante per la protezione dei dati personali*), located at Piazza Venezia 11, 00187 – Rome (http://www.garanteprivacy.it/).

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The Data Controller is not responsible for keeping all the links provided in this Privacy Policy up to date; therefore, should any link be non-functional and/or outdated, Users acknowledge and agree that they must always refer directly to the document and/or section of the websites to which such link points.