PRIVACY POLICY CONCERNING THE PROCESSING OF PERSONAL DATA OF WEBSITE USERS

Enerbrain S.r.l. with registered office in via della Consolata 4, Torino, VAT number IT11249860013, in his capacity of data controller (“Controller” or “Enerbrain”), provides you with the following information concerning the processing of your personal data, pursuant to the applicable law concerning data protection and, in particular, to Article 13 of EU Regulation 2016/679 (General Data Protection Regulation “GDPR”).

1. Data processed

  1. 1.1.  For the purposes indicated in the present privacy policy, Enerbrain will process your personal data, which means any information relating to an identified or identifiable natural person (so called “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  2. 1.2.  Computer systems and software procedures used to operate Enerbrain website and Enerbrain mobile application may acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified data subject, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users connected to the site, 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 relating to the operating system and the user’s computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Enerbrain site and the Enerbrain mobile application and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain possible liabilities in case of any computer crimes committed against the site; in any other case, data on web contacts do not persist for more than seven days. With specific reference to the cookies used by Enerbrain website, we invite you to read the specific policy.

2. Purposes of the processing

  1. 2.1.  Your personal data whose transmission is implicit and related to browsing the Enerbrain website is used exclusively in anonymous form for statistical purposes related to the use of the site and its correct and regular operation.
  2. 2.2.  Personal data that is voluntarily provided by users is collected and processed:
    • ▪  to send newsletters and commercial information concerning products and/or services of Enerbrain or of other entitiesrelated to Enerbrain (“Enerbrain Group”), where the user provides the aforementioned data for the purposes of

      registering to the newsletter;

    • ▪  to carry out market research or to measure the satisfaction on the quality of the products and/or services.
  3. 2.3.  You do not have any obligation to provide your personal data for the above said purposes, therefore data will be processed by the Controller exclusively on the basis of your consent. In the event you will not provide your personal data, the consequence will be that the Controller will not be able to send you newsletters and commercial information or to carry out market research or measure your satisfaction on the quality of the products and/or services.
  4. 2.4.  Your personal data could also be collected and processed:
    • ▪  to provide you with technical support;
    • ▪  to evaluate your job application, in the event that you spontaneously send your resumé through the site.
    • 2.5. If you need to receive technical support from Enerbrain or to have your job application evaluated by the company, collection of your personal data and processing from the Controller for such purposes is necessary. In the event that you will not provide your personal data, the Controller will not be able to provide you with technical support or to proceed with the recruitment procedure.

      3. Processing methods and duration of data storage

      1. 3.1.  Your personal data are processed through collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Your personal data are processed both with paper and with electronic and/or automated methods.
      2. 3.2.  Your personal data will be stored by the Controller for the time that will be necessary to complete the purposes indicated above and, in any event, until you will not withdraw your consent or ask for the deletion of your personal data. As regards personal data processed by the Controller to comply with contractual obligations (e.g. providing technical assistance) or legal obligations, personal data will be processed for the duration of the contractual or legal obligation and, to manage any claim or possible disputes, within the limits of the applicable periods of prescription.

      4. Categories of recipients of the data

      4.1. Personal data collected and processed could be communicated, for the purposes above indicated, to the following categories of recipients:

      • ▪  Employees, staff and consultants of the Controller or of other entities of the Enerbrain Group, in Italy and abroad;
      • ▪  people carrying out activity of storage and management of the documents relating to the relationships with Enerbrain’clients;
      • ▪  people providing IT services to Enerbrain;
      • ▪  companies providing cloud services;
      • ▪  people carrying out activities of control, audit and certification of Enerbrain activities;
      • ▪  public authorities and judicial bodies;
      • ▪  third parties or other subjects carrying out activities in outsourcing on behalf of the Controller;

      5. Transfer of personal data to third countries

      1. 1.1.  Personal data are stored on server located in the European Union.
      2. 1.2.  Personal data could be transferred outside the EU, always respecting rights and safeguards requested by applicable law. Should personal data be transferred outside the EU in absence of an adequacy decision by the European Commission, suitable safeguards will be adopted (e.g. standard data protection clauses).

      2. Rights of the data subject

      1. 2.1.  You have the right to request the Controller the access to personal data and, precisely, the right to obtain from the Controller confirmation as to whether or not personal data concerning you are being processed and to have access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the categories of recipients to whom the personal data have been or will be disclosed; where possible, the envisaged period for which the personal data will be stored. If requested, the Controller will provide you with a copy of the personal data processed.
      2. 2.2.  Moreover, you have right to obtain from the Controller the rectification of inaccurate personal data concerning you. You have also the right: to have incomplete personal data completed and to obtain the erasure of personal data concerning you without undue delay (should one of the reasons provided by Art. 17 of the GDPR occur); to obtain restriction of processing; the portability of personal data to another data controller. You have also the right to object to processing of personal data concerning you (in any moment, if the purpose of the processing is direct marketing or profiling) and the right to lodge a complaint with a supervisory authority.

        3. Modalities for the exercise of the data subject’s rights

        The above said rights can be exercised sending a written request to Enerbrain, by email using the email address info@enerbrain.com, or sending a letter with acknowledgment of receipt addressed to Enerbrain at the following address via della Consolata 4, Torino.

        4. Data Controller

        1. 4.1.  ThedatacontrollerisEnerbrainS.r.l.withregisteredofficeinviadellaConsolata4,Torino,VATnumber IT11249860013, email address info@enerbrain.com.
        2. 4.2.  The data subject could require to the Controller information concerning data processors and people acting under the authority of the Controller.

        I declare to have read the privacy policy, to be more than 16 years old and, for the following purposes, I do/do not give my consent to Enerbrain to process my personal data:

        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