Your privacy is very important to us, so we want to inform you of the ways in which we collect and use information about you.
Windows on Europe SpA, the Data Controller, with an office in Milan, Piazza IV Novembre 7, a company belonging to the Windows on Europe Group, has always given special attention to processing and protection of personal data of its Clients, Users, Suppliers, Collaborators and all other entities it has a relationship with. For this reason, in order to assure the closest adherence to the regulation in Legislative Decree 30 June 2003 n. 196, our Company created a specific organization by adopting a suitable Model of Organizational Privacy.
Windows on Europe SpA, in thanking you for having provided your personal data to us, informs you of the processing goals and methods intended for them, distinguishing among:
- Website users
- Clients and Suppliers
- Job applicants
Your rights and Responsibilities regarding your data
First, we remind you that, according to section 7 of Legislative Decree 196/2003, provided below, it is your right, among others, to know which of your personal data we process as well as requesting its integration, correction or deletion.
To exercise these rights, contact the Person in Charge of processing at the following email address: firstname.lastname@example.org, or at the postal address of our organization’s office.
The complete list of all those responsible for processing personal data, appointed by us, is available by contacting our Person in Charge of processing.
Section 7 (Right to access personal data and other rights)
1. The subject has the right to confirm the existence or lack thereof of personal data regarding him, even if not yet recorded, and their communication to him in a readable format.
2. The subject has the right to obtain an index of a) the origin of the personal data; b) the purposes and types of processing; c) the logic applied if processing is performed electronically; d) the identification of the owner, the Persons in Charge, and the representative designated in accordance with section 5, paragraph 2; e) the subjects or categories of subjects to whom personal data may be communicated or who may become aware of them in their role as designated representatives in the territory of the State, the Persons in Charge, or the Appointees.
3. The subject has the right to obtain: a) updates, corrections, or, when necessary, supplementation of data; b) deletion, rendering anonymous, or blockages of data handled in violation of the law, including those data not required to be stored relevant to the purposes for which the data were obtained or later handled; c) notification that the operations referred to in a) and b) were made known, including regarding their content, to the subjects to whom the data were provided or distributed, excepting cases in which accomplishing this is revealed to be impossible or involves taking measures manifestly disproportionate to the protected right.
4. A data subject has the right to object, in whole or in part: a) for legitimate reasons to the handling of personal data regarding them, even if pertinent to the goal of the collection; b) to the handling of personal data regarding him in order to send advertising material or direct sales material, or for the performance of market research or commercial communications.
DISCLOSURE TO WEBSITE USERS
In this page we describe the site’s management methods with reference to processing personal data of the users who consult it. The processing is always based on principles of lawfulness and accurate compliance with all regulations in force.
This privacy police is also provided as a disclosure in compliance with section 13 of Legislative Decree 196/03 (Italian regulation on processing personal data in compliance with directive 95-46–CE) to those who interact with the web services on this site, for the purposes of protecting personal data, available online from www.Windows on Italy.com corresponding to the initial page of the official Windows on Italy site. The disclosure is provided only for the Windows on Italy site and not for other websites possibly consulted by the user through links. They are independent Owners of processing and therefore we refer you back to the site in question.
This disclosure is prompted as well by Recommendation n. 2/2001 that the European authorities for personal data protection, convened in the Group required by section 29 of directive n. 95/46/CE, adopted 17 May 2001 to identify minimum requirements for the collection of personal data online and, in particular, the methods, the time and the nature of the information that the Owners of the processing must provide to users when they link to web pages, regardless of the purpose of the link.
Processing the data freely given by you will be performed in accordance with the regulations in force. In particular, the processing will be done in accordance with principles of accuracy, lawfulness and transparency, relevance, completeness and avoidance of excess; the data will be collected and recorded for the purposes in the following point and kept for a period of time strictly necessary for those purposes.
Types of data processed, methods of processing, goals of processing, whether optional or not.
Net browsing data
The information systems and software procedures that govern the functioning of the website acquire, in the course of their operations, some personal data, the transmission of which is implicit in the use of Internet communication protocols.
Such information is not collected with the intention of matching it to the interested parties, although by its very nature, and through the processing and linking of data held by third parties, it might enable the identification of users. This category of data includes IP addresses or domain names of the computers used by visitors to the website, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request made, the method used to submit the request to the server, the size of files received by way of response, the numerical code which indicates the status of the response given by the server (successful, error, etc.) as well as other parameters associated with the operating system and the IT environment of the user.
This data is used with the sole aim of extracting anonymous, statistical information regarding the use of the website and to ensure that the latter is operating correctly. The data is eliminated immediately after being analyzed. Should the website be subject to cyber crime, such data could be used for investigation purposes and might enable the identification of the responsible party.
Data voluntarily supplied by the user
The optional, explicit and voluntary sending of emails to addresses indicated on this website will lead to the acquisition of the e-mail address of the sender as well as any other personal information needed in order to respond to the sender’s request and/or supply requested services. In addition, the website will acquire other personal information included in the correspondence (and attached documents) or in the relevant forms. The e-mails received are archived indefinitely in a server and protected by appropriate security measures. Interested parties can fully exercise their rights under Article 7 of the Legislative Decree 196/2003. In particular they can obtain information with regards to their personal data present in the archive and request its cancellation (for further information see “Rights of interested parties”). When replying to enquiries and/or supplying services requested the data supplied will be handled using informational and network procedures. The supply of personal data is always voluntary. Failure to provide such data will lead only to the inability of Windows on Italy to satisfy any given request. We may disclose the data of users to one or more qualified subjects who have the right to access such information as sanctioned by legal provisions, regulations and/or EU directives regarding data handling. In addition, personal data of users may be communicated to third parties if considered strictly necessary in order for such parties to execute activities connected to the relationship between such users and our company.
Location of data processing and scope of communication or broadcast.
The data related to the web services of this site are processed by the Provider, within limits strictly necessary for providing the hosting service, at our organization’s office only by technical staff charged with processing and at the Servers of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 - USA, or by possible persons charged with occasional maintenance operations. Your data may be communicated to parent, subsidiary or affiliate companies in accordance with section 2359 of the Italian Civil Code or to businesses under common control, for administrative accounting purposes as defined in section 34, paragraph 1-b of Legislative Decree 196/2003, or those involved in the performance of activities of an organizational, administrative, financial or accounting nature, regardless of the nature of the data processed.
DISCLOSURE TO CLIENTS AND SUPPLIERS
The nature of the data processed
Windows on Europe SpA processes Your personal and financial data, as well as other personal data of a nature normally necessary for the performance of contractual relationships, current or future, with our company.
Goals of processing
Your data will be processed in connection with contractual obligations, and the consequent fulfilment of legal and financial obligations, as well as to permit effective management of financial and business relationships.
Your data will be processed for the entire duration of the contractual relationship and thereafter, for the fulfilment of legal obligations and for administrative and business purposes.
Objections to processing for business purposes: opt-out.
The details you provided in email or paper correspondence may be used by Windows on Europe SpA in order to send direct advertising or sales materials or for the accomplishment of market or advertising research. This promotional activity may be related only to goods and services similar to the subject of the contractual relationship. We remind you that, upon our collection of Your data and in every communication sent regarding the mentioned purposes, you may object to processing by simply contacting our Person in Charge of replying, available at the email address email@example.com, or the postal address of our organization’s office, or by clicking on the “unsubscribe me” links provided at the bottom of electronic communications sent to you. You will receive an immediate reply to your request to stop processing.
Methods of processing
Data processing is done through the use of tools and processes suited to assure their safety and discretion and may be done either through paper backup or through the use of electronic means.
Obligation or right to provide data
As regards the data that we are required to know in order to fulfil our legal obligations, rules and public regulations or provisions issued by Authorities legally allowed to do so, or by units performing surveillance and inspection, Your withdrawal of permission constitutes the impossibility of establishing or continuing the relationship, as such data are necessary in the execution of the same. As regards the data we are not required to know, withdrawal of permission will be evaluated each time and will determine the consequent decisions, related to the importance to our organization of data requested and not provided.
Scope of knowledge and communication of Your data
Only executives, managers, accountants, administrators, operations management, or external consultants may access Your data in their roles as Persons in Charge or Trustees of processing appointed by this Organization. We may communicate your data (meaning by this term providing access to one or more defined subjects) to subjects who can access the data as provided by law, regulation or legislation, within the limits set forth in such regulations, as well as to subjects who need to access Your data for purposes auxiliary to the relationship between You and us, within limits strictly necessary to perform those auxiliary tasks.
We may, moreover, communicate the data to parent, subsidiary or affiliate companies in accordance with section 2359 of the Italian Civil Code or to companies under common control, for administrative accounting purposes as defined in section 34, paragraph 1-b of Legislative Decree 196/2003, or those connected to the performance of organizational, administrative, financial and accounting activities, regardless of the nature of the data being processed. In particular, internal organizational activities, those needed for the fulfilment of contractual and pre-contractual obligations, to the management of the work relationship in all phases, to bookkeeping and the application of regulations of a financial, trade, social security and welfare, health, hygiene and work safety nature, may pursue these goals.
The transfer of information about you, even temporary, to a Country not belonging to the European Union, may take place only if needed for the performance of obligations derived from a contract that You are party to, or to fulfil, before the end of the contract, Your specific requests, or for the conclusion or execution of a contract stipulated in Your favour.
DISCLOSURE TO JOB APPLICANTS
Windows on Europe SpA performs the activity of selecting personnel in pursuit of parity between workers and not discriminating against candidates of either sex, in accordance with Laws 903/77 and 125/91.
Your data will, moreover, be processed and stored with the greatest circumspection, care and diligence in compliance with Legislative Decree 196/2003 and according to the methods reported below.
Collection and nature of data
Data collection is done through transmitting, from the subjects, their own Curriculum Vitae. Collection may be done either online (emails or attachments to related forms) or on paper.
Purposes of processing
Processing of personal data is performed exclusively in the scope of performing activities of research, selection and evaluation of personnel.
Obligatory or optional nature of collection
Collection of personal data on the part of the subject, and the transmittal of one’s Curriculum Vitae, are optional: in its absence, however, we will not be able to perform the activities of research, selection and evaluation of personnel.
Scope of communication or broadcast of data
Persons in Charge or Appointees of targeted processing in our company may have access to Your data. Your data may, moreover, be communicated to third parties who supply specific services or perform related activities instrumental to or in support of the methods and purposes for which You provided Your data. Furthermore, we may communicate this data to parent, subsidiary or affiliate companies per section 2359 of the Italian Civil Code or to companies under common control, for administrative accounting purposes as defined in section 34, paragraph 1-b of Legislative Decree 196/2003, or those connected to the performance of activities of an organizational, administrative, financial and accounting nature, regardless of the nature of the data processed. In particular, internal organizational activities, those instrumental to the fulfilment of contractual and pre-contractual obligations, to the management of the work relationship in all phases, to bookkeeping and the application of financial, trade, social security and welfare, health, hygiene and work safety processes, may pursue those goals.
Processing methods and data storage
Data processing will be performed in accordance with the provisions of section 11 of Legislative Decree n. 196/2003. Data processing will also be performed with logic strictly correlated to the purposes indicated and with methods that assure safety and discretion of the data themselves, through the adoption of suitable measures to impede the alteration, deletion, destruction, unauthorized access or processing that is not allowed or does not conform to the purposes of the collection.
Data will be kept at our database for a period of time not more than two years and, therefore, no longer than the period of time necessary to manage and monitor the process of research and selection.