Pursuant to articles 13 and 14 of European Regulation 679/2016 on personal data protection, the so-called “General Data Protection Regulation” (“GDPR”) and art. 13 of Legislative Decree (D. Lgs.) No. 196/2003, we wish to inform you that this application collects some Personal Data of its Users.

Controller

DS Group, with registered office in Corso Venezia, No. 36, 20121 – Milan (MI), and represented by its acting legal representative is the Controller of your Personal Data.

The Controller can also be contacted at the following e-mail address: privacy@dsgroup.it, in addition to the postal address indicated above for all information and/or request regarding the processing of personal data performed by the Company.

Types of Data collected

The Personal Data collected by this Application, independently or via third parties, include: the name, surname, telephone number, e-mail address, Cookies, Usage Data and the Data disclosed during your use of the service.

Complete details on each type of data collected are provided in the sections dedicated to this Privacy Policy, or by means of specific information texts displayed before the data in question are collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, may be collected automatically during the use of this Application.

All the Data required by this Application are mandatory, unless otherwise specified. It may be impossible for this Application to provide the Service, if the User refuses to disclose the required Data. In the cases where this Application indicates some Data as optional, Users are free to refrain from disclosing such Data, without this having any consequence regarding the availability of the Service or the Service’s operation.

The possible use of Cookies, or other tracking tools by this Application or by the Owners of third-party services used by this Application, if not otherwise stated, has the purpose of providing the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy.

Any third-party cookies are collected independently by the third parties in question and who represent independent controllers of the data collected by means of the cookies used by them.

DS Group is not in a position to exercise any control regarding such cookies transmitted by the providers of the above-mentioned third-party services, and has no knowledge regarding their characteristics or their purposes. For this reason, you need to refer to the respective information notices, personal data processing policies and the consent forms (selection and deselection of the respective cookies), to which we invite you to refer, by means of links, in order to obtain further information. Such third parties are responsible for providing the information notice and collecting the users’ consent, for the processing activities performed by them. This responsibility not only refers to the cookies which the third parties transmit directly, but also to any additional cookies which are transmitted by means of our website as a result of using the services which the third parties in question utilise.

The User assumes responsibility for the third-party Personal Data obtained, published or shared by means of this Application and warrants that it has the right to communicate or disclose such third-party Personal Data, thereby releasing the Controller of any liability towards third parties.

Methods and place of processing the Data collected

Processing methods

The Controller adopts the appropriate security measures intended to prevent the unauthorised access, disclosure, modification, or destruction of Personal Data. The processing is carried out using computer/telematic tools, with organisational procedures and logics which are strictly related to the purposes indicated. In some cases, in addition to the Controller, the Data may be accessed by other subjects involved in the organisation of this Application (administrative, commercial, marketing, legal staff, system administrators), or external subjects (for example: providers of third-party technical services, postal couriers, hosting providers, computer companies, communication agencies) if necessary, also appointed as Processors by the Controller (pursuant to art. 28 of the “GDPR”). The Controller may always be requested to provide the up-to-date list of Processors.

Place

The Data are processed at the Controller’s operational centres and in every other place where the parties involved in the processing are located. The User’s Personal Data could be transferred to a country other than the country where the User is located, to a Member State of the European Economic Area (EEA) or outside the European Economic Area. In fact, if necessary, the Controller will have the right to move the data to servers in the European Union or located outside the European Union, in compliance with the applicable regulatory provisions. In case of need, the Data transfer will be performed on the basis of adequate safeguards, for example, adequacy decisions, Standard Contractual Clause forms duly approved by the European Commission or other safeguards considered adequate. The User can refer to the respective sections of this document or request information from the Controller in order to obtain additional information regarding the place of processing; the Controller may be contacted using the e-mail address or postal address indicated above.

Storage period

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

  • Personal Data collected for purposes related to performing a contract between the Controller and the User, or to implement pre-contractual measures adopted at your request and/or to fulfil a legal obligation to which the Controller is subject will be retained until the performance of such contract has been completed and/or until such obligation has been fulfilled;
  • Personal Data collected for purposes referable to the Controller’s legitimate interest will be retained until such interest has been satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the respective sections of this document or by contacting the Controller.

When the processing is based on the User’s consent, the Controller may store the Personal Data for a longer period until such consent is revoked. In addition, the Controller may be obliged to store the Personal Data for a longer period, in compliance with a legal obligation or by order of an authority.

The Personal Data will be deleted at the end of the storage period. Therefore, the right to access, delete, rectify and the right to Data portability can no longer be exercised after this period has expired.

Legal basis and purpose of Processing the Data collected

Legal basis for processing

The Controller processes the Personal Data relating to the User if one of the following conditions applies:

  • the processing is necessary to perform a contract entered into with the User and/or to implement pre-contractual measures;
  • the processing is necessary to fulfil a legal obligation to which the Controller is subject;
  • the processing is necessary to perform a public interest task or to exercise public powers of which the Controller is vested;
  • the processing is necessary to pursue the Controller’s legitimate interest or the legitimate interest of third parties;
  • the User has given his/her consent for one or more specific purposes;

Note: in some legal systems the Controller may be authorised to process Personal Data without requiring the User’s consent or another of the legal bases specified below, until the User objects to such treatment (“opt-out”). Nevertheless, this is not applicable if the processing of Personal Data is governed by European legislation on Personal Data protection. However, it is always possible to request the Controller to clarify the solid legal basis for each processing operation, and in particular, to specify whether the processing is: based on the law, envisaged by a contract or necessary to conclude a contract.

Purpose

The User’s Data are collected to enable the Controller to provide its Services, as well as for the purposes detailed below and where for some purposes you are required to give your consent, without which, for example, it would not be possible for us to contact you and to follow up your additional requests (for example: to inform you regarding any new services):

  • To contact the User;
  • Statistical analyses provided in an anonymous form;
  • Address management and sending e-mail messages;
  • Displaying content from external platforms;
  • Personnel search and selection.

The User may refer to the following respective sections of this document to obtain further detailed information regarding the purposes of the processing operations and the Personal Data actually relevant for each purpose.

Details on Personal Data processing

The Personal Data are collected for the following purposes and using the following services:

  • User Contact 

Contact form (This Application)
By compiling the contact form with his/her Data the User consents to the Data being used to reply to the requests for information, quotation requests, or a request of any other nature indicated in the form header.

Personal Data collected: surname, name, e-mail, telephone number.

Mailing List or Newsletter (This Application)
When registering with the mailing list or with the newsletter (for which your consent is required), the User’s e-mail address is automatically added to a list of contacts to which e-mail messages may be transmitted containing information, also commercial and promotional information relating to this Application. The User’s e-mail address could also be added to this list as a result of registering with this Application or after making a purchase.

Personal Data collected: surname, name, e-mail, telephone number.

Telephone contact (This Application)
Users who have provided their telephone number could be contacted for commercial or promotional purposes (for which consent must be given) linked to this Application, as well as to respond to support requests.

Personal Data collected: telephone number.

  • Statistics

The services included in this section enable the Controller to monitor and analyse the traffic data and serve to keep track of the User’s behaviour.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, to compile reports and share the reports with the other services developed by Google in complete autonomy.

Google could use the Personal Data to contextualise and customise the announcements of its advertising network.

Personal Data collected: Cookies and Usage Data.

Processing location: USA – Privacy Policy – Opt Out

  • Address management and transmitting mail messages (This Application)

This type of service enables a database of e-mail contacts, telephone contacts or contacts of any other type used to communicate with the User to be managed.

In addition, these services could enable the collection of data referring to the date and time the User views messages, as well as the User’s interaction with them, as well as information regarding the clicks on the links included in the messages.

Personal Data collected: e-mail, surname and name.

  • Viewing content from external platforms 

This type of service enables the content hosted on external platforms to be viewed directly from the pages of this Application and to interact with them.

If a service of this type is installed, and even if the Users do not utilise the service, the service in question may collect traffic data relating to the pages on which it is installed.

Widget Google Maps (Google Inc.)

Google Maps is a map display service managed by Google Inc. that enables this Application to integrate such contents on its pages.

Personal Data collected: Cookies and Usage Data.

Processing location: USA – Privacy Policy.

Widget Video YouTube (Google Inc.)

YouTube is a service to display video content managed by Google Inc. that enables this Application to integrate such contents on its pages.

Personal Data collected: Cookies and Usage Data.

Processing location: USA – Privacy Policy

User’s rights

Users may exercise certain rights with reference to the Data processed by the Controller. In particular, the User has the right:

  • to revoke his/her consent at any time: The User may revoke the consent given previously to the processing of his/her Personal Data;
  • to object to the processing of his/her Data: The User may object to the processing of his/her Data when the processing is performed on a legal basis other than consent. When the Personal Data are processed in the public interest, to exercise public powers of which the Controller is vested, or to pursue the Controller’s legitimate interest, Users have the right to object to the processing on grounds relating to their particular situation;
  • to access their Data: The User has the right to obtain information regarding the Data processed by the Controller, concerning certain aspects of the processing and to receive a copy of the Data processed;
  • to verify and request rectification: The User may verify the correctness of his/her Data and request their updating or correction;
  • to obtain a restriction of the processing: The User may request a restriction of the processing of his/her Data under certain conditions. In this case the Controller shall not process the Data for any other purpose except for their storage;
  • to obtain the erasure or removal of his/her Personal Data: The User may request the Controller to erase his/her Data under certain conditions;
  • to receive his/her Data or have the Data transferred to another controller: The User has the right to receive her/her Data in a format that is structured and commonly used and is legible by an automatic device and, where technically feasible, to obtain their transfer to another controller unimpeded. This provision is applicable when the Data are processed using automated tools and the processing is based on the User’s consent, on a contract to which the User is a party or on contractual measures related thereto;
  • to lodge a complaint: The User may lodge a complaint to the competent Personal Data Protection Supervisory Authority or may take legal action.

How to exercise the rights

Users may send a request to the Controller using the contact details indicated in this document in order to exercise their rights. The requests are filed free of charge and processed by the Controller in the shortest time possible, and in any case, within one month.

Further information on processing

Legal defence

The Controller may utilise the User’s Personal Data in legal proceedings or in the preparatory stages of initiating possible legal proceedings for defence from the User’s abuse in the use of this Application or the related Services. The User declares that he/she is aware that the Controller may be obliged to disclose the Data by order of public authorities.

System and maintenance log

This Application and possible third-party services used by the Application could collect system logs for needs associated with operating and maintenance aspects, namely, files which record the interactions and which may also contain Personal Data, for example, the User’s IP address.

Amendments to this privacy policy

The Controller reserves the right to amend this privacy policy at any time and to inform the Users on this page, and if possible, on this Application, as well as, by sending a notice to Users by means of one of the contact details available to the Controller, if technically and legally feasible. Therefore, you are invited to consult this page regularly and refer to the date of the last amendment indicated at the bottom of the page. If the amendments concern data processing for which the legal basis is consent, then the Controller will collect the User’s consent again, if necessary.

Service cancellation

Please enter your e-mail address in the form provided on this page in order to stop receiving the newsletter, and then click the “Cancel subscription” button. An e-mail notice may be sent to the following address in the case of technical problems (normally to the party that provides the service): privacy@dsgroup.it.

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