This privacy policy (hereinafter, “Privacy Policy”) refers to the site http://www.externasrl.it/ (hereinafter, the “Site”), including the areas dedicated and reserved for registered users, and describes the activities and the methods of processing personal data carried out by EXTERNA SRL (hereinafter, “EXTERNA”) through the Site, which is owned by EXTERNA SRL and registered in its name.
EXTERNA acknowledges the importance of its users’ privacy and is committed to respecting it. EXTERNA processes users’ personal data (“Personal Data”) when they visit the Site and use its services and features. The Privacy Policy has been written in accordance with the General Data Protection Regulation no. 679/2016 (“GDPR”). The Privacy Policy specifies: the data controller, who controls and manages the Personal Data collected and processed through the Site; the personal information collected; the purposes and methods on how Personal Data are processed; the scope of communication to third parties of personal Data and any potential transfer abroad; the security measures adopted in order to protect and safeguard such data; the methods by which the user can verify the processing of the data that concern him and exercise the rights the Privacy Regulation acknowledges.

This privacy notice, however, is provided only for the Site, the activities performed and the services offered by EXTERNA also through its own data processors, but not for other websites that the User may visit through links and/or activities performed by third parties. In case the User visits other websites, he is recommended to consult their respective privacy policies.

1. TYPES OF DATA PROCESSED

1.1 Navigation data

Visiting and consulting the Site do not generally involve collecting and processing the user’s Personal Data. The processing of Personal Data of users who visit and consult the Site is limited to the so-called navigation data, whose transmission is necessary for the operation of it systems and programs of the Site itself, but which, by their very nature, could allow the users’ identification in association with other data. This category of data includes, for example, IP (internet protocol) addresses or domain names of the computer used to visit the Site, as well as other parameters of the operating system used by the user to connect to the Site. The acquisition of navigation data takes place automatically and unavoidably and they shall be used for the sole purpose of obtaining statistical information on the use of the Site and to verify its correct functioning. Upon express request, Public Authorities can use such data in accordance with their procedures in force in order to ascertain responsibilities in the event of cybercrimes against the Site and/or third parties. Without prejudice to this eventuality, the navigation data described above are stored only temporarily in compliance with applicable laws.

1.2 Data provided voluntarily by individual Users

EXTERNA also collects and processes the Personal Data provided voluntarily by individual users, which consist of those data collected by sending e-mails, interacting with the Site’s functions, requesting services offered by the Site, sending curricula vitae, filling in specific forms to access the restricted areas of the Site. The Personal Data that EXTERNA collects and processes include name, sex, place and date of birth, nationality, contact information such as addresses, telephone numbers and e-mails, and the other information contained in the curriculum vitae.

2. METHODS AND PURPOSES

Data will be processed, both manually and with electronic tools, in order to respond and manage the Users’ requests for information and/or products, questions, communications or feedback; in order to provide the services requested through the Site, including registration and all subsequent updates given by sending price sensitive communication, presentations, interim reports, annual reports, and by managing the activities organized through the Site; in order to carry out recruiting and personnel selection; in order to collect and track information which is then used for User profiling, remarketing and behavioral targeting and other marketing purposes.
Personal Data will be kept as long as it is necessary for the purposes for which they were collected and, in any case, not beyond the limits established by the applicable legislation.

3. NATURE OF DATA PROVISION

The provision of Personal Data for the purposes referred to in point 2 above is necessary to allow EXTERNA to answer to information requests, to provide the services requested through the Site, including registration. In case of failure to provide Personal Data for the purposes referred to in point 2, EXTERNA will not be able to answer to information requests or to provide the services requested through the Site.

4. COMMUNICATION OF DATA

The Personal Data are accessible to the Data Processor indicated below, to the other subjects who will act as external data processors appointed by EXTERNA and, as data processors, to the EXTERNA staff involved in the provision of services and activities offered by EXTERNA according to criteria of necessity.

Personal Data may be disclosed to bodies, authorities, public institutions and legitimate recipients in compliance with laws and regulations; they may be made accessible to professionals and independent consultants, also organized in associated form, providers of professional and technical services, functional to the processing purposes indicated in point 2 above, and that assist EXTERNA in legal, tax, social security, accounting and/or organization matters, who will act as Data Processors or designated processors, as appropriate, provided they adopt those criteria of security and protection for Personal Data in line with the current legislation.

EXTERNA may also disclose Personal Data to third parties in the event of extraordinary transactions (e.g. mergers, acquisitions, company transfers, etc.), providing only the information necessary to perform their respective services. These third parties will commit to use the received information only for the processing purposes specified above, to keep it confidential and secure and to comply with applicable laws concerning Personal Data protection and with any instruction given by EXTERNA.

Personal Data may be transferred outside the national territory even to subjects established in countries outside the European Union (through the Dropbox server, for example) who may not guarantee an adequate level of protection pursuant to GDPR. In these cases, EXTERNA transfers Personal Data to such third countries only after adopting the measures established by art. 44 et seq of GDPR in order to legitimize the transfer and ensure adequate protection for the Personal Data transferred.
Personal Data will not be subject to disclosure in any case.

5. AUTOMATIC DATA COLLECTION MECHANISMS – COOKIES

The Site uses cookies and other technologies for reading and/or storing information on the user’s device. In order to provide a detailed description of these technologies, please consult the Cookie Policy fully referred to in http://externasrl.it/cookies

6. RIGHTS OF THE INTERESTED PARTY

At any time the User can exercise the rights recognized by Articles 15 – 22 of the GDPR, including, for example, the right to obtain confirmation of the existence or not of Personal Data concerning him, to verify their content, origin and accuracy, request their integration, update, rectification, cancellation, transformation into anonymous form, and transfer (portability). The user can object, in whole or in part, or request the limitation of data processing for legitimate reasons.

The User can contact EXTERNA at the following address: info@externasrl.it for any question or request the processing of his Personal Data and to exercise the rights recognized by the GDPR.

7. UPDATES AND CHANGES TO THE PRIVACY POLICY

The Privacy Policy is subject to changes and updates and the version currently in force is the one published on the Site. Changes to the Privacy Policy are published on the Site. Please regularly check the Privacy Policy in order to be updated on any change.

8. DATA PROCESSING CONTROLLER AND PROCESSOR

The data controller is EXTERNA SRL. based at Bicenter, in via Nona Strada 23/Q – 35129 Padova (PD), P.IVA and C.F. 0525790028, available at the following email address: info@externasrl.it

Internal data PROCESSOR is Silvia Salmistraro.