Privacy

PRIVACY POLICY

Euregio Plus SGR S.p.A. cares about your privacy.

Through www.euregioplus.com (the “Website”), Euregio Plus SGR S.p.A. (“Euregio Plus”, “we”, “us”, “our”) collects certain information about you (“Personal Data”).

In accordance with the General Data Protection Regulation (Regulation (EU) 2016/679, the “Regulation”) and applicable personal-data protection legislation, this privacy policy (the “Policy”) describes the Personal Data we collect when you visit the Website or choose to interact with us through it, as well as the purposes and methods by which we process such data.

Data Controller

For the purposes of this Policy and the processing activities covered by it, the Data Controller is Euregio Plus SGR S.p.A., with registered office at Passaggio Duomo 15, 39100 Bolzano (BZ), Italy.

What Personal Data we collect, the purposes for which we process them and the applicable legal basis

I. Data you provide when you choose to contact us

Data processed:

When you choose to contact us through the “Contact” section of the Website, we may collect and process the following Personal Data concerning you, which you choose to provide when submitting your request:

  • your name and surname, whether you are personally interested in the services offered by Euregio Plus or act as a contact person for an entity, company or professional firm interested in such services;

  • the identity of the persons or entities for which you work or that you represent;

  • the address of your residence or professional domicile, or that of the persons or entities for which you work or that you represent;

  • your telephone number, e-mail address and fax number, or those of the persons or entities for which you work or that you represent;

  • any other Personal Data that you provide by completing the information-request form.

You are free to provide all or only part of the Personal Data requested through the form in the “Contact” section. However, refusal to provide the relevant Personal Data may make it more difficult for us to respond promptly and accurately to your requests.

Purpose of processing:

If you contact us through the “Contact” section of the Website or send us a communication by e-mail or post, all data that you provide will be processed exclusively to provide you with a prompt response and to ensure the proper handling of your request.

Legal basis:

The processing of Personal Data provided through the contact form or through communications sent to the contact details indicated on the Website is necessary to respond to the requests made by the data subject and to take any pre-contractual measures requested by the data subject pursuant to Article 6(1)(b) of Regulation (EU) 2016/679.

Where the request is not connected with the establishment of a contractual or pre-contractual relationship, the processing will be based on the Data Controller’s legitimate interest in responding to the communications received pursuant to Article 6(1)(f) GDPR.

Retention period:

We will retain the Personal Data that you provide when contacting us through the “Contact” section of the Website for the period strictly necessary to respond to your requests, unless longer retention is necessary to comply with a legal obligation or to protect one of our rights.

II. Data you provide through the Complaints Desk

Data processed:

When you submit a complaint through the Complaints Desk or through the other channels indicated by the Company for complaint management, Euregio Plus may collect and process the Personal Data necessary to handle the case, including:

  • identification and personal data;

  • contact details;

  • data relating to the contractual relationship with Euregio Plus;

  • data contained in the complaint, in the attached documentation and in subsequent communications with the data subject;

  • any further Personal Data whose processing is necessary for the management, investigation and resolution of the complaint.

Purpose of processing:

Personal Data collected in connection with complaint management are processed to receive, examine, investigate and respond to reports and complaints submitted by data subjects, and to comply with the legal, regulatory and supervisory obligations applicable to the Company.

Legal basis:

Processing is necessary for the performance of the contractual relationship or for any pre-contractual measures requested by the data subject pursuant to Article 6(1)(b) of Regulation (EU) 2016/679.

Processing is also necessary to comply with the legal and regulatory obligations to which Euregio Plus is subject pursuant to Article 6(1)(c) of Regulation (EU) 2016/679, and for the pursuit of the Data Controller’s legitimate interest in managing and defending its rights in complaint procedures pursuant to Article 6(1)(f) GDPR.

Retention period:

Personal Data processed in connection with complaint management will be retained for the time necessary to manage the case and, subsequently, for the period required by applicable legislation, the provisions of the competent authorities and the retention obligations imposed on the Company, as well as to protect the Data Controller’s rights in the event of litigation.

III. Data you provide when contacting us about job opportunities at Euregio Plus

Data processed:

When you send your curriculum vitae in the manner indicated in the “Work with us” section of the Website, we may collect the following Personal Data:

  • personal details, such as name, surname, date of birth and residence;

  • contact details, such as telephone number and e-mail address;

  • photograph or personal portrait;

  • data relating to your qualifications, education and professional career;

  • any other information, including information belonging to special categories of Personal Data, which you may provide when applying, for example by submitting your curriculum vitae, or during any subsequent selection process.

Purpose of processing:

The Personal Data that you provide through the “Work with us” section will be processed to assess whether your profile is consistent with Euregio Plus’s professional requirements and to carry out selection activities among candidates.

Legal basis:

The legal basis for processing Personal Data provided through the “Work with us” section is the taking of pre-contractual measures aimed at establishing a possible employment relationship between you and Euregio Plus pursuant to Article 6(1)(b) of Regulation (EU) 2016/679.

Special categories of Personal Data:

With your specific consent, we may also process data capable of revealing your racial or ethnic origin, political opinions, religious beliefs, sexual orientation and data relating to your health that you choose to provide when applying in response to specific job advertisements or during the subsequent selection process. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal, pursuant to Article 7(3) GDPR.

Retention period:

Personal Data provided in response to job advertisements on the Website will be retained for the period necessary to carry out the selection activities for the specific position for which you applied and, in any event, for no more than two years after the end of the relevant selection process, unless longer retention is necessary to comply with a legal obligation or to protect one of our rights.

Personal Data provided through an unsolicited application will be deleted immediately after review, unless their retention is necessary to comply with a legal obligation or to protect one of our rights.

IV. Data we collect when you visit the Website

When you visit the Website, we collect the following browsing data in anonymised form:

  • technical information, including IP address and information about the devices used by Website visitors, the browser and operating systems;

  • information about navigation on the Website, including the URLs of pages visited, activities performed on the page, browsing dates and times, time spent on the Website and clickstream data.

This information is collected for the proper operation, management, maintenance and improvement of the Website, to ensure secure browsing and to establish liability in the event of cybersecurity breaches. It is also used to enable us to obtain statistical analyses concerning use of the Website, including in aggregate form, and to allow you to receive promotional advertisements consistent with your preferences and interests.

You are always free to decide whether to provide browsing data, for example by disabling cookies through your browser settings. However, refusal to provide information necessary for browsing may make it impossible to perform activities strictly connected with browsing and, therefore, to consult and interact with the Website.

We retain such data only for the time strictly necessary for the purposes for which they are collected.

Browsing data are collected through cookies. For further information on how cookies work and how to enable or disable them, please consult our Cookie Policy.

Summary table of processing activities

Processing activity Data processed Purpose Legal basis
General contact requests Identification and contact data Responding to requests received Article 6(1)(f) GDPR; Article 6(1)(b) GDPR
Management of complaints and reports Identification and contact data, data relating to the relationship with the Company and information contained in the complaint Receipt, investigation, management and response to complaints; compliance with regulatory and supervisory obligations Article 6(1)(b) GDPR; Article 6(1)(c) GDPR; Article 6(1)(f) GDPR
Applications for job positions (“Work with us” section) Personal and professional data and curriculum vitae content Application management Article 6(1)(b) GDPR
Browsing data Technical information and information concerning navigation on the Website Operation, security and maintenance of the Website, statistical analysis and possible personalisation of promotional advertisements Article 6(1)(f) GDPR; Article 6(1)(a) GDPR

Processing methods:

Your Personal Data are processed using IT, telematic and/or paper tools in accordance with the principles of fairness, lawfulness, transparency, accuracy, integrity, data minimisation, purpose limitation and storage limitation, and in accordance with the Regulation and applicable personal-data protection legislation, with the adoption of appropriate security measures.

How we protect your data:

Your Personal Data are collected, processed, transmitted and stored using appropriate physical, logical and organisational security measures to protect them against breaches, such as destruction, loss, alteration, unauthorised disclosure or accidental or unlawful access, and to ensure that processing is carried out only for the purposes described in this Policy.

To whom we disclose your Personal Data:

To ensure the most accurate possible processing of your Personal Data, Euregio Plus uses certain processors to whom your data may be disclosed. These parties have been selected from professionals that guarantee the implementation of appropriate technical and organisational measures, so that processing is always carried out in compliance with applicable legislation and with protection of your rights.

You may request the identity and contact details of the processor or processors by contacting us as indicated in the “How to contact us” section of this Policy.

Without prejudice to disclosures made in compliance with legal and contractual obligations, the data collected and processed may be disclosed for the purposes specified above to:

  • public administrations and authorities, where required by law and applicable legislation;

  • all public or private natural and/or legal persons, including, by way of example and without limitation, IT service providers, hosting providers, cloud service providers, parties entrusted with the maintenance and management of IT systems, legal, administrative and tax advisory firms, courts and Chambers of Commerce, where disclosure is necessary or instrumental to the performance of our activities and in the manner and for the purposes listed above.

Transfers outside the EEA:

For the purposes of the processing activities described in this Policy, your Personal Data may be transferred to countries outside the European Economic Area (“EEA”).

Euregio Plus guarantees that any transfer outside the EEA will be carried out in a manner that ensures full protection of your rights and freedoms.

Where the European Commission has not adopted an adequacy decision for the relevant third country, transfers will be governed by the standard contractual clauses issued by the European Commission. Transfers to the United States may be made to organisations that have joined the EU-US Data Privacy Framework, which ensures an adequate level of protection pursuant to Article 45 GDPR.

Your rights and how to exercise them:

In accordance with applicable legislation, and in particular the Regulation, you have the following rights in relation to your Personal Data:

  • Access: you may obtain information about the processing of your Personal Data and a copy of those data;

  • Rectification: where you consider your Personal Data inaccurate or incomplete, you may request that they be rectified or amended in accordance with your instructions;

  • Erasure: you may request the erasure of your Personal Data to the extent permitted by Article 17 of the Regulation;

  • Restriction: you may request restriction of the processing of your Personal Data;

  • Objection: on grounds relating to your particular situation, you may object to processing pursuant to Article 21 of the Regulation;

  • Withdrawal of consent: where processing is based on consent, you may withdraw consent at any time;

  • Data portability: where processing is based on consent, you may receive the Personal Data provided to us in a structured, commonly used and machine-readable format and, where technically feasible, have them securely transmitted to another controller.

Automated decision-making and profiling

Euregio Plus SGR S.p.A. does not carry out any decision-making process based on automated processing of Personal Data and does not carry out profiling activities.

How to contact us:

To exercise your rights and for any questions or clarification regarding how your Personal Data are processed and used under this Policy, you may contact Euregio Plus SGR S.p.A. by post at Passaggio Duomo 15, 39100 Bolzano (BZ), Italy, by e-mail at info@euregioplus.com or by telephone at +39 0471 068700.

To ensure the highest possible protection of your rights and freedoms, Euregio Plus has also appointed a Data Protection Officer (“DPO”), whom you may contact in relation to any matter concerning the processing of your Personal Data and the exercise of your rights. The Euregio Plus DPO may be contacted at DPO@euregioplus.com.

If you contact us, all data that you provide will be processed exclusively to provide you with a prompt response and ensure the proper handling of your request.

Protection of your rights:

To protect your rights and your Personal Data, you may at any time lodge a complaint with the competent supervisory authority, namely the Italian Data Protection Authority, tel. +39 06 696771, e-mail garante@gpdp.it or urp@gpdp.it, or bring proceedings before the competent national courts.

Nevertheless, Euregio Plus is always willing to listen to and carefully examine any observations or complaints. Without prejudice to your rights, we therefore invite you to contact us regarding the exercise of your rights.

Changes to this Policy:

This Policy may be updated in accordance with the legislation in force from time to time. Where data subjects have already provided their Personal Data, any change that substantially affects the processing of those data will be communicated through the appropriate channels, in order to ensure effective awareness of the processing methods and full protection of data-subject rights.

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