Pursuant to art 13 of Italian Legislative Decree n° 196 of 30.6.2003 (hereinafter, the “Privacy Code”) and art 13 of Regulation (EU) 2016/679 (hereinafter, the “GDPR”), you are hereby informed that your data will be processed by the following means and for the following purposes:
1. Data controller
The data controller is RINA S.p.A., whose registered office is in Genoa (Italy), via Corsica 12, Tax code and VAT n° 03794120109 (hereinafter, the “Controller”).
The Controller may be contacted by writing to: firstname.lastname@example.org.
2. Scope of processing
The Controller processes personal data of a common type (name, employing company, town/city, telephone number, and e-mail address), provided by you by completing the form available in the “Contact Us” section of the website. In addition, normal operation of the website makes it necessary to obtain some personal data. This is information that is not collected to be associated with identified data subjects but that, by its very nature, could make it possible to identify the users by processing and associating the same with data collected by third parties. This category of data includes cookies, which are small text files that websites visited by the users send to their terminals, where they are stored to be sent back to the same sites at the time of subsequent visits. For further information on cookies used by the website go to: https://www.robins-project.eu/cookie-policy/.
3. Purpose of processing
a. Your personal data are processed for the following purposes:
- to receive and respond to any request for a contact, by sending the information you requested;
- to collect information necessary for the obligations connected with the pre-contractual phase.
b. In addition, with your explicit consent, your data will be processed to:
- send you e-mails, post, sms and/or telephone calls, newsletters, commercial communications, and/or advertising materials on products or services offered by the Controller, and measure the degree of satisfaction with the quality of such services;
- analyse your choices and surfing habits, in order to improve use of the website and choice of the Controller’s services.
4. Processing method
The Controller will process personal data in accordance with the principles of lawfulness, fairness and transparency.
Your personal data are processed by means of the following operations: collection, recording, organisation, structuring, storage, consultation, adaptation or alteration, use, dissemination, disclosure by transmission, retrieval, alignment, combination, restriction, erasure and destruction of the data. Your personal data are subjected to both hard-copy and electronic processing.
The Controller will process the personal data for the time necessary to carry out the purposes indicated above and, in any case, for not more than 2 years from collecting the data.
However, the Controller may store the data for longer than 2 years if erasure of the same may compromise its legitimate right to defence or, in general, to safeguard its company assets. Such storage will take place, limiting access to the same to heads of departments only, in order to guarantee the legitimate exercising of the right of defence of the Controller.
5. Access to data
Your data may be made accessible for the purposes indicated in art 3.a and 3.b to the following recipients:
- affiliate companies or subsidiaries of RINA Group, in Italy and abroad, to the extent to which this is necessary for processing;
- companies or other third parties (professional firms, consultants, insurance companies for providing insurance services, suppliers, entities that provide services for managing the computer system and the telecommunications network for the services, etc.), who act on an outsourcing basis for the Controller, and who have been formally nominated as the data processor;
- public entities, for fulfilling legal obligations.Without requiring your explicit consent, the Controller may communicate your data for the purposes indicated in art 3.a to supervisory bodies, judicial authorities, insurance companies for providing insurance services, as well as to entities to which communication is mandatory in terms of the law, for carrying out said purposes.
6. Transfers of data
Personal data are stored on servers located within the European Union. In any case, it is understood that, should this be necessary, the Controller will have the right to move the servers even outside the EU. In such a case, the Controller hereby guarantees that transfers of data outside the EU will be done in accordance with the applicable laws, also by means of including standard contractual clauses provided for by the European Commission, and adopting binding corporate rules for intra-group transfers.
The provision of data and related processing for the purposes indicated in point 3.a is necessary in order to guarantee the Controller’s services you have requested, and for executing the requests made. If refused, you cannot successfully submit requests and cannot receive a response from the Controller.
Providing data for the purposes indicated in point 3.b, on the other hand, is not mandatory. You may, therefore, decide not to provide any data or subsequently refuse processing of data already provided – the only consequence of any such refusal will be that receiving newsletters, commercial communications, and advertising materials related to the services offered by the Controller will not be possible. However, you will continue to have a right to the services indicated in point 3.a.
8. Rights of the data subject
In your capacity as the data subject in processing of the data in question, you have the rights provided for in the GDPR, including the right to ask the Data Controller, by contacting the Data Protection Officer for: access to the personal data, indication of the means, purposes and logics involved in the processing, the right to object, to request restriction of processing, data portability, rectification and erasure of the same, within the limits and in the ways provided for in the GDPR.
Where processing of data is based on consent, you have the right to withdraw the same at any time.
In addition, you always have the right to object to the sending of newsletters and processing of all or several data for marketing or commercial purposes.
Therefore, in your capacity as the data subject, you have the rights pursuant to art. 7 of the Privacy Code and art. 15 – 21 of GDPR, as well as the right to lodge a complaint with the competent Authority pursuant to art. 77 of GDPR.
9. Procedure for exercising rights and communications
The Controller has appointed a Data Protection Officer, who can be contacted for all matters related to processing of your personal data and the exercising of related rights.
Therefore, you may contact the Data Protection Officer at any time, using the following procedures:
- by sending a registered letter with notification of receipt to RINA S.p.A., via Corsica 12, 16128 Genova, Italy, for the attention of the Data Protection Officer, or by
- sending an e-mail message to email@example.com.
We wish to state that you have the right to withdraw the consent given at any time by writing to firstname.lastname@example.org.