PRIVACY POLICY - REV 03

This Privacy Policy is produced by the Data Controller in compliance with Article 13 of EU Regulation 2016/679 (General Data Protection Regulation).

1. DATA CONTROLLER

ROTHO BLAAS SRL
Registered office: in I-39040 Cortaccia (BZ), Via Dell'Adige no. 2/1;
VAT NO. IT 01433490214.

If you wish to make a report, or if you have any requests or wish to exercise the rights referred to in Article 15 et seq. of EU Regulation 679/2016, please contact our Privacy Representative by e-mail at the following address: privacy@rothoblaas.com.

2. TRACKING: TYPE OF DATA PROCESSED, PURPOSE OF PROCESSING, LEGAL BASIS and METHODS OF PROCESSING

2.1. COOKIES

For tracking by means of cookies, refer to the reference policy.

2.2. WEBSITE BROWSING DATA

Access to the website involves the acquisition of browsing data, the transmission of which is implicit in the use of Internet communication protocols. For example, this category includes the IP addresses or domain names of the computers and/or other devices used by users who connect to the website, addresses of the requested resources in URI (Uniform Resource Identifier) format, the time of the request, the method used for submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response provided by the server (successful, error, etc.) and other parameters relating to the user’s operating system or IT environment.

The purposes of data processing are as follows:

• to enable the operation (and improvement) of the website and the performance of the services requested by the User;
• to obtain and use statistical information on the use of the website;
• to determine any responsibility in the event of cyber crimes.

The legal basis is the legitimate interest of the data controller for conducting and improving the services provided on the website.

2.3. DATA PROVIDED VOLUNTARILY TO REQUEST SERVICES OR INFORMATION

In order to access the services/information offered, the user voluntarily provides some of his or her personal identification and/or commercial data, collected through specific forms on the website; this action entails the acquisition of such data by the Data Controller in order to be able to provide the services requested in accordance with the methods described in this Privacy Policy. The purposes of the processing are different depending on the services requested by the user (website registration, newsletter subscription, application, marketing and commercial communications, course registration, downloading of documents and/or spreadsheets): performance of the service requested by the user; performance of the contractual relationship with the user and any related contractual obligations, including Customer Service management; performance of legal, administrative and accounting obligations related to the user's request for services or contractual obligations; communication with the customer in relation to the service requested marketing activities and the sending of related commercial communications, analysis of interests and personal information or habits or consumption choices and subject to the consent of the person concerned; in some cases it may be necessary for the prevention of fraud and/or abuse to the detriment of Rotho Blaas, or to protect against possible claims due to the use of the services provided. application management. The legal basis is the fulfilment of contractual obligations; otherwise, the consent of the data subject.

2.4. NEWSLETTER

Subscription to the newsletter can be completed by completing the appropriate form and, at the same time, giving consent to the processing of the personal identification and commercial data that you are providing: name, surname e-mail, residential address, occupation. This includes methods for monitoring interactions such as percentages of users who opened, undelivered emails, those who opened the link, etc., which we can use to determine the effectiveness of the newsletter and user preferences. Purposes of data processing:

• the periodic dispatch of a newsletter to promote products and services, including customised ones;
• the periodic dispatch of a newsletter to promote activities such as events, training courses, fairs and seminars organised by the company or in which the company participates, including customised ones;
• adaptation of the newsletter to the interests of the subscribers.

The consent of the data subject is the legal basis. By revoking consent to receive the newsletter, consent to tracking is also deemed revoked. The newsletter is dispatched with the help of a platform appointed as data processor, on whose server the e-mail address provided by the user is saved.

2.5. CONTACT FORMS

The following personal identification and commercial and through web and social platforms data can be provided voluntarily at trade fair events, sector conventions and/or events: name, surname e-mail, residential address, telephone number, occupation, company name. Purposes of data processing:

• to send special offers and promotions for services and products provided by Rotho Blaas to the data subject by electronic mail;
• to contact the data subject by telephone to communicate special offers and promotions for services and products provided by Rotho Blaas.

The consent of the data subject is the legal basis. In particular, for some events, data collection takes place with the help of a platform appointed as data processor, on whose server the data provided by the user are stored. The data will be kept for two years from the date of consent.

2.6. ROTHOSCHOOL TRAINING COURSES AND SEMINARS/DATA

You may register for a training course directly through this application by completing the registration form with the following personal data, the provision of which is optional:

A) identification and/or commercial information: name, surname, e-mail, address of residence, telephone number, profession, company name, tax and/or VAT code;
B) images and videos.

Failure to provide the data does not prevent enrolment in the chosen training course. Purposes of data processing are

• the data referred to in point A are used for: the management of training courses (by way of example but not limited to: sending confirmation of enrolment and the programme of the chosen training course, sending the certificate of attendance at the end of the course). the occasional sending of communications concerning news about products or services relevant to the service requested and/or useful for the professional updating of users.
• The data referred to in point B is gathered for documentation and advertising purposes. By giving your consent to take photos and videos, the course participant agrees that Rotho Blaas may take photos and videos immediately before, during and immediately after the course and use them subsequently for advertising purposes free of charge.

The legal basis for the processing is the fulfilment of contractual obligations if and inasmuch as requested by the data subject; otherwise the consent of the data subject. The data referred to in point A will be kept for two years from the date of consent. The data referred to in point B will be kept for ten years.

2.7. RECRUITING

The data of the people who apply for a position with the company by entering their personal data in the form shown below via the company’s home page or send their C.V. to the company by email. The purpose of the processing is recruitment in accordance with operational needs.The data is provided on a voluntary basis. Should you refuse to give consent to the subsequent processing of your personal data, the undersigned company will be unable to insert your data into its own archive and is prohibited from establishing a possible contractual relationship with you in future. The data shall be held for a maximum period of 24 months and then deleted, except if a communication to the contrary is received from the data subject. Your personal data may be communicated to the following categories of recipients, who are commissioned in writing as internal or external data processors and receive specific written instructions: HR personnel; company managers; Rotho Blaas Group companies; recruitment companies.

3. PLUG-INS AND TOOLS

3.1. YOUTUBE

This website uses YouTube integration features offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When a user interacts with a YouTube video, the system stores information about the video being viewed and links it to their YouTube user profile, if they are logged in. This information may be processed by Youtube for advertising purposes, market research and/or design of its website to meet users' needs.

3.2. GOOGLE MAPS

This website uses Google Maps integration features offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When a user interacts with a Google Maps map within our website, Google stores information about the user and links it to their Google user profile, if they are logged in. This information may be processed by Google for the purposes listed in Google's privacy policy.

3.3. MESSAGING SERVICES

When the user contact us via messaging services such as Whatsapp, the information made available to us (e.g. mobile phone number, name, status, message content, attachments etc.) will be accessible by both ROTHO BLAAS SRL and the companies providing the messaging service, namely WhatsApp Ireland Limited (4 Grand Canal Square, Grand Canal Harbour Dublin 2, Ireland).
The sharing of such data with service providers is necessary in order to allow proper management of the messaging service. The provision of data is optional. However, if this information is not provided, ROTHO BLAAS will not be able to communicate with you via Whatsapp. If the user does not wish to share this information with the service providers listed above, the user should contact ROTHO BLAAS directly via the contact forms on the website. ROTHO BLAAS shall process such data exclusively for the purpose of fulfilling the customer's request. The legal basis for the processing is the consent of the data subject. For more information on the processing of data by the service provider, refer to the privacy policy of the respective service provider:
Whatsapp: https://www.whatsapp.com/legal.

4. TRANSFER AND DISSEMINATION OF DATA TO THIRD PARTIES

Personal data provided by the User (e.g. for website registration, subscription to the newsletter, management of job applications) are managed by Data Controller internal resources (associates and colleagues) identified above according to their skills and the context of their relative responsibilities and/or any contractual obligations as described in this Privacy Policy. The data are uploaded into the company CRM. In order to fulfil the specified objectives, some data may be disclosed to Group companies; external parties/companies to whom the disclosure of the personal data proves to be necessary or, in any case, functional for the purpose of performing the requested service or for the management of the contractual relationship with the data subject (marketing, strategic and IT consulting companies, hosting companies or companies that manage services for third parties, sales network, recruitment companies to manage job applications) in the manner and for the objectives illustrated in this Privacy Policy, under the control of the Data Controller. The Data Controller shall not disclose any data deriving from the web services outside the Data Controller’s own organisation, including Group companies, not even any of the above-mentioned individual parties, unless consent has been expressly granted or as required for legal obligations.

5. FOREIGN TRANSFER

The personal data provided by the data subject may be processed or transferred to a country outside the EU for the above-mentioned purposes in accordance with the applicable legislation in relation to the transfer of data to Third Countries and the relative guarantees as indicated therein (Article 44 et seq. of EU Regulation No. 679/2016).

6. DATA PROCESSING METHODS AND RETENTION TIMES

Data processing of the gathered data is carried out through computerised procedures or, in any case, by digital means by internal or external parties specifically appointed and authorised for such purpose and committed to confidentiality terms. Data is processed and stored using tools suitable to ensure its safety, integrity and confidentiality through the adoption of adequate security measures, as established by law. For data obtained through forms filled in by the data subject:

• Failure to provide the data that is identified as mandatory, however, will prevent the service from being provided.
• Failure to provide data that is identified as optional, on the other hand, could lead to the provision of an incomplete service.

We reserve the right to change the applied security and data protection measures, if necessary, as required by law and/or in view of technical developments. In such cases, we will also adapt the data protection information accordingly. Personal data supplied by the User is kept for the time necessary to carry out the specified objectives and, to the extent necessary to fulfil contractual, tax, and legal obligations (e.g. course registration data) for the time as provided by applicable local legislation.

7. AMENDMENT OF THE PURPOSE FOR WHICH PERSONAL INFORMATION IS PROCESSED

If we intend to use personal information for purposes other than those intended during data collection, we will notify the user of this change before proceeding with further processing.

8. EXCLUSION OF LIABILITY

The data protection information of ROTHO BLAAS SRL does not apply to products, services, applications, websites or social media functions of third-party providers, which are accessible via the links offered for information purposes. By using these links the user leaves the website of ROTHO BLAAS SRL and it is therefore possible that personal information may be collected by or passed on to third parties. ROTHO BLAAS SRL has no influence on third-party websites and gives no guarantee regarding the data protection procedures used by these. We encourage you to read and review the privacy statements of all websites with which you may interact before authorising them to collect, process and use your personal data.

9. RIGHTS OF DATA SUBJECTS

For any comments, requests and/or for exercising the rights referred to in Article 15 et seq. of EU Regulation 679/2016, Data Subjects can refer to our privacy reference contact by sending a mail to the following address: privacy@rothoblaas.com. In particular, the data subject may at any time exercise the rights recognised by the privacy regulations. By way of example, without being exhaustive:

• Right to information and access: the right to obtain information about the processing of one's own data and access to it, and to obtain a copy of the processing.
• Right of rectification: the right to obtain amendment and supplementation of data in cases where they are inaccurate or incomplete.
• Right to be forgotten: right to data erasure and withdrawal of consent.
• Right to restriction of processing: which allows the temporary or permanent suspension of processing, with the retention of data by the Controller.
• Right to data portability: right to the transfer of personal data, i.e. that they are transferred to the data subject or transferred to another data controller/ processor for further processing.
• Right to object: it is possible to object to processing for reasons relating to the particular situation of the data subject, to be specified in the request.
• Automated decision-making processes concerning natural persons, including profiling: no automated decision-making processes are used.

10. COMPLAINTS LODGED WITH A COMPETENT SUPERVISORY AUTHORITY

The user has the right to lodge complaints, concerning the processing of personal information, with a supervisory authority. Data Protection Authority, based in Rome (Italy), Piazza di Monte Citorio no. 121, postal code: 00186.