PRIVACY POLICY

1. DATA CONTROLLER AND DATA PROTECTION OFFICER

The data controller is the company VEM Sistemi SpA, with registered office in Via Don Sebastiano Calderoni 12, Forlì (FC), contactable at the e-mail address privacy@vem.com.

The Data Controller has appointed a Data Protection Officer, who can be contacted at the email address dpoprivacy@vem.com.

Tipologie

2. TYPES OF DATA PROCESSED

While browsing the Site and within the scope of the services offered, VEM will process information about you and that may be collected automatically while you are browsing or provided directly by you, for example by filling in forms on the Site. The Personal Data processed through the Site belong to the types indicated below.

a) Name, contact details and other Personal Data

In some sections of the Site, for example on the Contact page, you will be asked to enter some Data such as name, surname and email address, telephone number and company / reference institute, including university, as well as any further information that you wish to communicate to us using the appropriate space where you can enter your message. The spontaneous sending of email communications to the email addresses indicated on our Site, involves the acquisition by VEM of the sender’s address necessary to respond to your requests, as well as any other Personal Data, including attachments, included in your communication.

In the sections that provide free entry fields, we invite you not to send Personal Data that could reveal your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, data relating to health or sexual orientation.

If you intend to communicate Personal Data of other people, you act as an Autonomous Data Controller and therefore assume all the obligations provided for by the current legislation. In such cases, you grant VEM the broadest indemnity and guarantee with respect to possible disputes or claims by third parties to whom the Personal Data you have communicated or transmitted refer.

b) Browsing data and cookies

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected by VEM in order to be associated with identified data subject, but by its very nature could, through processing and association with Data held by third parties, allow users to be identified.

This category of Data includes the IP addresses or domain names of the computers used by users who connect to the Site, the addresses in URI ( Uniform Resource Identifier ) notation of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment. This Data is used for the sole purpose of obtaining statistical information on the use of the Site, to check its correct functioning and to identify anomalies and/or abuses and does not persist for more than seven days (except in the event of the need to ascertain crimes by the Judicial Authority).

Information on the use of cookies is available in the Cookie Policy Section which we invite you to read in the following web page.

c) Data processed in interaction with Social Media platforms

Regarding the processing of personal data carried out by the managers of the Social Media platforms used by VEM, please refer to the information provided by them through their respective privacy policies.

d) Data acquired in the context of personnel research and selection

The Personal Data that you wish to communicate if you intend to submit your spontaneous application or with reference to one of the open positions indicated in the “Careers” section, will be processed as described in the specific Privacy Policy provided therein.

e) Data acquired as part of registration for events

The Personal Data that will be requested in the specific form for registration to events organized by VEM Sistemi S.p.A also in collaboration and partnership with third parties will be processed as described in the specific Privacy Policy provided therein.

Finalità

3. PURPOSE OF THE PROCESSING AND LEGAL BASIS

Within the limits established by current legislation, the Data will be processed by VEM for the following purposes:

• to carry out all the activities necessary for the use of the services you have requested, for example in order to manage the response to questions received through the contact forms present on the different pages of the Site. In particular, your Data will be processed in order to provide you with assistance, to verify your identity, to give you access to the service and, in general, to respond to your requests. The legal basis of the processing is the performance of a contract to which you are a party or the execution of pre-contractual measures taken at your request. The provision of Personal Data for this purpose is optional, but any failure to provide it or incorrect provision could make it impossible for VEM to fully process your requests (Provision of services);
• to allow VEM to fulfill the obligations set forth by laws, regulations and EU rules, or to provisions issued by Authorities. The provision of Personal Data and the related processing are necessary in order to comply with the relevant legal obligations (Legal Obligations);
• to obtain information necessary to identify anomalies, fraudulent activities and/or abuses in the use of the Site. The provision of Personal Data and the related processing for this purpose are based on VEM’s legitimate interest to identify and prevent illegal or fraudulent behavior. Consequently, failure to provide the Personal Data requested for this purpose could make it impossible for VEM to give you access to the Site and services (Security);
• to carry out information activities on VEM products and/or services as well as to carry out promotional and commercial activities, including communications and information regarding the planning and holding of events organized by VEM Sistemi also in collaboration and partnership with third parties, through the use of automated systems without operator intervention (for example, e-mail), but also through traditional contact methods, such as the postal service; to carry out customer satisfaction surveys activities by sending questionnaires, carrying out surveys or conducting polls. The provision of Personal Data and the its processing are based on your explicit consent, which can also be made positive mediation action of confirmation subscription to the newsletter through the appropriate form. You are never obliged to provide such consent and, should you provide it, you are free to revoke it at any time without suffering any consequence other than not receiving communications with commercial content from VEM. You can revoke your consent either through the appropriate unsubscribe link in the footer of the newsletters you receive, or by following the instructions contained in the “Rights of Data Subject” section of this Privacy Policy (Marketing);
• to carry out activities on users, by presenting personalized ads/posts/insertions online (for example within the social media you access, such as LinkedIn or Facebook) following a previous visit to our Site and subject to consent to the use of profiling cookies and similar tracking technologies through the appropriate banner; to analyze users’ use of the Site, examine the effectiveness of advertisements and promotions and, in aggregate form, statistics regarding browsing and activities on the Site, also in order to simplify its use and adapt it to the user’s interests and choices. The provision of Personal Data and the related processing are based on your explicit consent, collected through the appropriate flags on the cookie banner, or by accessing Site to the cookie preference center through the appropriate button located of the lower left part of the Site. You are never obliged to provide such consent and, if you do, you are free to modify or revoke it at any time without suffering any consequences. You can modify or revoke the consent given for this purpose by following the instructions in the “Rights of Data Subject” Section of this Privacy Policy, or by accessing the cookie preference center through the button located in the lower left part of the Site. From the cookie preference center you can revoke the consent given for the activation of all cookies that require it by pressing the “Use only technical cookies” button. With reference to the details of the activities of cookies and similar technologies that make this profiling activity effective, we invite you to refer to what is better specified in the Cookie Policy Section of this Privacy Policy and to the list of cookies, including third-party cookies, accessible from the cookie banner from the “Details” section (Profiling).

Destinatari

4.RECIPIENTS

The Personal Data will be disclosed to VEM personnel in charge of managing the Site, who are authorized to process it for the purposes previously indicated and who have undertaken to maintain confidentiality or have received an appropriate legal obligation of confidentiality.

The Personal Data will also be disclosed to and/or processed by third parties, duly designated as Data Processors, with whom VEM has ongoing contractual relationships concerning services functional to the performance of the purposes described above (for example, suppliers of platforms for sending e-mails, subjects delegated to carry out technical maintenance activities including ordinary and extraordinary maintenance of the Site, etc. ).

Finally, Personal Data will be communicated, where required, to the competent Authorities (for example in case of fraudulent activities and/or abuse in the use of the Site), to financial offices, or to other Public Administrations according to the provisions of the laws in force.

Some of your Personal Data may be shared with recipients in countries outside the European Union or the European Economic Area. The Data Controller ensures that in such cases the data transfer will take place in compliance with applicable laws, adopting appropriate transfer guarantees in compliance with the provisions of Chapter V of the Regulation.

The Data will not be disclosed.

Tempi

5. RETENTION TIME AND CRITERIA

The Personal Data processed for the purpose of Providing Services will be retained by VEM for the time strictly functional to the performance of the service you requested and the proper performance of the pre-contractual or contractual relationship with you. VEM reserves the right to retain such Data for a longer period, if this is necessary in order to protect its interests from possible liabilities. At the end of this period the Data will be deleted. Your requests and the Data contained therein and collected through the Site’s contact forms will be kept for as long as necessary to allow VEM to correctly manage your request. At the end of this period, Data allowing the identification, even indirectly, of a natural person (such as name, surname, e-mail) will be anonymized and possibly maintained, in the form of aggregate data, for statistical purposes.

Personal Data processed for the purpose of Legal Obligations will be retained for the period required by specific legal obligations or by applicable legislation.

Personal Data processed for Security purposes, except in cases where these are used to ascertain liability in case of hypothetical computer crimes against the Site or third parties, will not persist for more than 6 months.

Personal Data processed for Marketing and Profiling purposes will be retained until your consent is revoked. Once your consent is revoked, VEM will no longer use your Personal Data for such purposes, but may still retain them if this is necessary in order to protect its interests from possible liabilities based on such processing. In particular, as regards the retention time of Data processed through cookies and other related technologies, we invite you to read the Cookie Policy Section and the list of cookies, including third-party cookies, accessible from the cookie banner in the “Details” section.

Diritti

6. RIGHTS OF THE DATA SUBJECT

Data subjects have the right to obtain from VEM, in the cases provided for, access to their personal data and the correction or cancellation of the same or the limitation of processing concerning them or to object to processing (articles 15 et. seq. of the Regulation). The appropriate request can be submitted by contacting the Data Protection Officer at the email address dpoprivacy@vem.com or at the VEM’s contact details on the Site, preferably according to the instructions available on the site https://www.garanteprivacy.it/web/docweb/4535524.

RIGHT TO COMPLAIN

Data subjects who believe that the processing of their personal data carried out through this site is in violation of the provisions of the Regulation have the right to lodge a complaint with the Data Protection Authority, as provided for by art. 77 of the Regulation itself, or to take appropriate legal action (art. 79 of the Regulation).

Cookie

COOKIE POLICY

This cookie policy is to be considered an integral part of the Information provided pursuant to art. 13 of the Regulation.

Definitions, typologies and application of the legislation

Cookies are small text files that the sites visited by the user send and record on the user’s computer or mobile device, to be then retransmitted on the next visit: through cookies, a site remembers the user’s actions and preferences (such as, for example, login data, language chosen, products placed in the shopping cart, font size, other display settings, etc.) so that they do not have to be indicated again when the user returns to visit said site or navigates from one page to another of it.

Cookies can be used for different purposes such as, for example, to perform computer authentication, monitor sessions, store information about specific configurations regarding users accessing the server, preference storage, or to facilitate the enjoyment of online content, such as for example to keep track of items in a shopping cart or information for filling out an IT form. Cookies can also be used to profile the user, that is, to “observe” their behavior for example in order to send targeted advertising, measure the effectiveness of the advertising message and adopt consequent commercial strategies. In this case we speak of profiling cookies. The same result can also be achieved by means of other tracking tools or techniques, including fingerprinting .

For more information on cookies and their general functions, we invite you to visit the page dedicated to the cookie topic on the institutional website of the Privacy Authority, available at the link https://www.garanteprivacy.it/temi/cookie.

Cookies can be set directly by the site the user is visiting or by the website whose address was entered by the user and displayed in the URL window (so-called “first-party” cookies).

While browsing a site, the user may also receive on his or her device cookies from sites or web servers other than the one being visiting (so-called “third party” cookies). We talk about a third-party cookie in reference to cases when you visit a website and a third party other than the operator of the visited site releases a cookie through the same, owned by third parties.

Cookies and, to a large extent, other tracking tools can have different characteristics from a temporal point of view and thus be considered according to their duration (session or permanent), or from a subjective point of view (depending on whether the publisher acts independently or on behalf of the “third party”). However, the classification that responds to the rationale of the law and therefore also to the requirements of personal protection is the one that is based, ultimately, on the following categories:

• technical cookies , used for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the contracting party or user to provide such service (art. 122, paragraph 1 of the Privacy Code). These cookies are used to carry out navigation or to provide a service requested by the user; they are not used for any further purposes and are normally installed directly by the website owner. Without the use of these cookies, some operations could not be performed or would be more complex and/or less secure.
• analytical cookies , which can be used to collect information, in aggregate form, on the number of users and how they visit the web site. These cookies can be assimilated to technical cookies if they are used for site optimization purposes directly by the owner of the site, who can collect statistical information in aggregate form on the number of users and how they visit the site. If, however, the processing of such statistical analyses is entrusted to third parties, the user data must be previously minimised and cannot be combined with other processing or transmitted to other third parties.
• functionality cookies , which allow the user to navigate according to a set of selected criteria (for example, language and products selected for purchase) in order to improve the service provided to the user. By disabling navigation, session and/or functionality cookies, the site may not be accessible and some services or certain functions of the site may not be available or may not function properly.
• profiling cookies , used to trace back to specific, identified or identifiable subjects, specific actions or recurring behavioral patterns in the use of the offered features (patterns) in order to group the different profiles within homogeneous clusters of different width, so that the owner can, among other things, also modulate the provision of the service in an increasingly personalized way beyond what is strictly necessary for the provision of the service, as well as send targeted advertising messages, i.e. in line with the preferences expressed by the user in the context of web browsing. The activation of profiling cookies requires the user’s prior consent.

Types of cookies used by the Site

The Site uses the following types of cookies:

• technical cookies , navigation or session cookies, are used for the sole purpose of carrying out the transmission of a communication on an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the contractor or user to provide such service. These cookies are strictly necessary for the operation of the site or to allow you to take advantage of the content and services requested. Technical cookies include navigation or session cookies (used to authenticate and access the service);
• functional cookies , allow the user to navigate according to a set of selected criteria (for example, language) in order to improve the service.
• analytical cookies , used, among other things, to evaluate the effectiveness of an information society service or to help measure site traffic, i.e. the number of visitors, also possibly divided by geographic area, time slot of connection or other characteristics. For their activation, when tools that reduce the identifying power of cookies are not adopted and the third party cross-references the information collected with other information it already has, the user’s consent is required.
• profiling cookies , used to trace back to specific, identified or identifiable subjects, specific actions or recurring behavioral patterns in the use of the features offered (patterns) in order to group the different profiles within homogeneous clusters of different width, so that it is possible for the owner, among other things, also to modulate the provision of the service in an increasingly personalized way beyond what is strictly necessary for the provision of the service, as well as send targeted advertising messages, that is, in line with the preferences expressed by the user in the context of web browsing. Their activation requires the user’s consent.

The details of the cookies used by the Site can be viewed via the cookie banner in the “Details” section.

How to manage or delete cookies

Può autorizzare, bloccare o cancellare (in tutto o in parte) i cookie attraverso le specifiche impostazioni del suo browser. In caso si utilizzino dispositivi diversi tra loro per visualizzare e accedere al sito (per esempio, computer, smartphone, tablet, ecc.), è necessario assicurarsi che ciascun browser su ciascun dispositivo sia regolato per riflettere le preferenze espresse in merito ai cookie. Inoltre, al termine di ogni sessione di navigazione, è possibile cancellare dal proprio dispositivo i cookie raccolti facendo riferimento alle istruzioni specifiche del browser utilizzato.

Selezionando i collegamenti sottostanti è possibile accedere alle istruzioni specifiche per la gestione dei cookie tramite alcuni dei principali programmi per la navigazione.

You can authorize, block or delete (all or part of) cookies through your specific browser settings. If you use different devices to view and access the site (for example, computers, smartphones, tablets, etc.), you should ensure that each browser on each device is adjusted to reflect the preferences expressed regarding cookies. Furthermore, at the end of each browsing session, you can delete collected cookies from your device by referring to the specific instructions of the browser used.

By selecting the links below provides access specific instructions for managing cookies through some of the main browsing programs.

• Microsoft Windows Explorer
  http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
• Google Chrome
  https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies
  
• Mozilla Firefox
  https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Apple Safari
  http://www.apple.com/legal/privacy/it/cookies/

It is always possible to revoke or modify the consent you have given for cookies that require it , by accessing the cookie preference center by clicking the icon in the lower left corner found on the pages of the Site. From the aforementioned cookie preference center, you can always manage and differentiate your cookies preferences, as well as revoke the consent you have given.

The cookie banner on the Site will be shown to the user again when:

• significantly change one or more processing conditions, for example “third parties” linked to profiling cookies;
• it proves impossible to determine whether a technical cookie has already been placed on the device used to access the site (for example, in the event that the user has deleted cookies from the device);
• at least six months have passed since the previous presentation of the cookie banner.