PRIVACY STATEMENT ON PROCESSING THE PERSONAL DATA OF INTERNET WEB SITE USERS
Enerbrain S.r.l. with registered office in Strada alla Villa d’Agliè, 26 10132 Turin, Italy, VAT No. IT11249860013, the data controller (hereinafter referred to as the “Data Controller” or “Enerbrain”), informs you of the following concerning the processing of your personal data, in accordance with the laws in force on the processing of personal data and, in particular, Article 13 of EU Regulation 2016/679 (General Data Protection Regulation “GDPR”).
1. Data subject to processing
1.1. For the purposes specified in this statement, Enerbrain may process data the GDPR defines as “personal data”, in other words any information concerning an identified or identifiable natural person (the “subject”), such as the name, ID number, data on the location, an online ID, one or more the person’s identifying physical, physiological, genetic, psychic, economic, cultural or social characteristic features.
1.2. The computer systems and software procedures used on the Enerbrain web site and in the Enerbrain mobile application may acquire some personal data as part of their normal working function, and the transmission of said data is implicit in Internet communications’ protocols. This information is not gathered to be associated with identified subjects, but due to the very nature of the same could, by being processed and by association with third party data, make it possible to identify users. This category of data includes the IP addresses or domain names of computers used by users to browse the web site, the URI (Uniform Resource Identifier) addresses of the required 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 numeric code indicating the status of the server’s response (connected, error, etc.) and other parameters of the user’s operating system and computer. This data is used to gather anonymous statistical information on Enerbrain web site and mobile application usage and to check they function correctly, and is deleted immediately after it has been processed. The data may be used to ascertain any possible responsibility in the case of hypothetical cybercrimes against the web site; with the exception of the previous case, data on web contacts are not stored for more than seven days. With specific reference to the cookies used on the Enerbrain web site, please refer to the specific informative statement.
2. Purpose of the data processing
2.1. Your personal data, the transmission of which is implicit and related to browsing the Enerbrain web site, are used only in an anonymous form for statistical purposes related to the use of the same web site and its regular performance.
2.2. Personal data are provided voluntarily by the users, and are gathered and processed for the following purposes:
▪ to send newsletters and commercial communications on Enerbrain products and/or services or those of other Enerbrain associates (in the “Enerbrain Group”), when the user provides said data in order to subscribe to the newsletter;
▪ to do market research or determine the level of satisfaction in relation to the quality of the products and/or services provided and the activities performed by Enerbrain.
2.3. Your personal data is provided and processed by the Data Controller for the above purposes voluntarily on the basis of your consent. If you fail to provide your personal data the Data Controller will not be able to send you the newsletters and commercial communications and/or do market research.
2.4. Your personal data may also be gathered and processed so Enerbrain can:
▪ provide you with technical assistance;
▪ evaluate your candidacy, if you send your curriculum vitae to the company via the web site.
2.5. If you wish to receive technical support from Enerbrain or want the company to evaluate your candidacy, you must provide your personal data and the Data Controller must process the same for the above purposes. If you fail to provide your personal data the Data Controller will not be able to provide technical support or evaluate your candidacy.
3. Data processing procedure and data storage times
3.1. The processing of your personal data will involve gathering, registering, organising, storing, consulting, processing, editing, selecting, extracting, comparing, using, linking, blocking, communicating, cancelling and deleting said data. Your personal data will be processed both in printed and electronic form and/or automatically.
3.2. The Data Controller will process your personal data for the time required for the above purposes, and in any case until you revoke your consent or request your data be cancelled. Within the scope of the processing done by the Data Controller to meet contractual obligations (e.g. technical service) or legal obligations, the data will be processed for the duration of the contractual or legal obligations and, for the purpose of any challenges or disputes, within applicable time limits.
4. Categories of recipients
4.1. All the data gathered and processed can only be communicated for the purposes specified above to:
▪ the employees, collaborators and consultants of the Data Controller or other companies in the Enerbrain Group, in Italy and abroad;
▪ subjects managing and archiving documentation on relations with Enerbrain customers;
▪ subjects providing services for managing Enerbrain IT system;
▪ companies providing cloud services;
▪ subjects monitoring, auditing and certifying Enerbrain activities;
▪ the authorities and judicial bodies;
▪ third party companies or other subjects who perform outsourced activities for the Data Controller;
5. Transfer of the data to a foreign country
1.1. The Data Controller stores the personal data on servers located in the European Union.
1.2. The personal data being processed can only be transferred outside the EU in compliance with the rights and guarantees provided for by the laws in force. If the personal data being processed will not be transferred outside the EU on the basis of a European Commission’s decision on adequacy, other suitable guarantees will be adopted, such as so-called standard contractual clauses.
2. Subject’s rights
2.1. As the subject, you have the right to gain access to the data and specifically the right to have the Data Controller confirm whether or not your personal data is being processed and to have access to the personal data and the following information: purpose of the data processing, categories of receivers to whom the personal data has been or will be given, when possible, the storage period. You also have the right to obtain a copy of the personal data being processed from the Data Controller.
2.2. Furthermore, you have the right to request the following of the Data Controller: the correction of incorrect personal data that concerns you in good time and the completion of any incomplete personal data; the cancellation of personal data (for one of the reasons provided for by art. 17 of the GDPR); the limitation of processing; the data be transferred to another data controller. You also have the right to object to the processing of your personal data (at any time, if the purpose of the processing is direct marketing or profiling) and the right to file a complaint with the privacy watchdog.
3. How to exercise your rights
The above rights can be exercised by sending written notification to Enerbrain, in the form of an Email sent to firstname.lastname@example.org, or a registered letter with return receipt sent to Enerbrain at the following address: via della Consolata 4, Turin, Italy.
4. Data controller
4.1. The Data Controller is Enerbrain S.r.l. with registered office in Strada alla Villa d’Agliè 26, Turin, Italy, VAT No. IT11249860013, Email email@example.com.
4.2. Information on data processors and those appointed to process the data can be requested from the Data Controller.
For sending newsletters and commercial information concerning products and/or services of Enerbrain or of other entities related to Enerbrain
□ I give my consent
□ I do not give my consent
out market research or to measure the satisfaction on the quality of the products and/or services
□ I give my consent
□ I do not give my consent