Privacy Policy

INFORMATION AND CONSENT REQUEST FOR THE PROCESSING OF PERSONAL DATA FOR MARKETING PURPOSES

Information pursuant to Article 13 of the EU Regulation 2016/679 (GDPR) concerning the protection of personal data

Personal data is not necessarily required within the site. The users are free to leave their data or not at their own discretion, by sending an email, in case they wish to be contacted, by sending a form, by subscribing to the newsletter or otherwise.

Before communicating any personal data to us, we invite you to carefully read the following information provided pursuant to Article 13 of EU Regulation 2016/679 (GDPR) on the protection of personal data, in order to know what data we process, for what purposes, what failure to provide the required data entails and what your rights are in relation to such data, as well as the Cookie Policy.

BROWSING DATA

By accessing the web page and our website, during their normal operation the computer systems and software procedures used to operate this website acquire some personal data, the transmission of which is implicit in the use of Internet communication protocols.

This data category includes IP addresses or the domain names of computers and terminals used by users, URI/URL (Uniform Resource Identifier/Locator) addresses of requested resources, request time, method used to submit the request to the server and other parameters relating to the user’s operating system and IT environment.

This data, necessary for the use of web services, is not kept for more than one year.

Data Controller

Fabo S.p.A., with registered office in Via Cecinese 84-84/A, 51036 Larciano (PT), District of Castelmartini, VAT no. 00126020478, is the Data Controller for processing personal data concerning you (hereinafter referred to as FABO)

FABO’s Privacy Office contact details

privacy@fabosolutions.com

Tel. +39 0573 84851, Fax +39 0573 84109,

Processed Data

A) Data collected for the execution and performance of specific contractual or pre-contractual relationships with FABO or which may be maintained in the future or which have been voluntarily provided to us by you by contacting FABO directly, filling in appropriate forms online or leaving your business card or similar in order to obtain our business information in view of a possible contractual relationship (see processing detail in Table A)

B) Data collected in online forms or unsolicited data that you voluntarily provided us when you gave your express consent to the processing of data for marketing purposes (see processing details in Table B).

C) Data that you send us when you apply for possible employment or collaboration with FABO (“CV”) (see processing details in Table B)

TABLE A:

PROCESSING OF SUPPLIER, CUSTOMER AND POTENTIAL CUSTOMER DATA

Purposes of processing	The personal data collected by Fabo S.p.A. in the execution and performance of specific contractual or pre-contractual relations regarding the supply by third parties, or the sale and/or supply of our products and services, may be processed in particular for the following distinct purposes: To respond to a direct request that can be satisfied by an electronic reply or by sending paper material as appropriate. For purposes strictly connected and instrumental to the execution of the contractual or pre-contractual relationship in place. In order to comply with the legal obligations imposed by current administrative, tax and accounting regulations
Legal basis	Contract or pre-contractual contacts and negotiations also when we provide answers to questions we receive from the site’s online forms Compliance with legal obligations
Consequences of withholding data	Required data is mandatory. Failure to communicate the data makes it impossible to execute the contract or respond to your requests in a pre-contractual context so there will be no contract with Fabo S.p.A. and/or we cannot meet your demands.
Retention period	The data provided will be processed only for the time necessary for the performance of the requested service or to provide you with the information requested and stored for 24 months (letter a) In the event that you are (or have become after the pre-contractual relations) a customer or supplier of FABO, your data will be stored for a period of 10 years from the conclusion of the last provision for tax purposes or according to the maximum duration provided for by law. (b) and (c).
Disclosure to third parties	Personal data is processed by the Controller and by the authorised persons in charge, with a guarantee of security and confidentiality and a commitment not to disclose or communicate data to third parties. Your data may be communicated for needs related to the purposes, only to professionals who the Data Controller uses, expressly appointed as external data processors, and in particular: Board of Statutory Auditors Chartered Accountants financial advisor law firm Customs Assistance Centre for Intrastat Practices banks post offices or couriers for the shipment of parcels and letters To the email manager To the agents You may, at any time, request an updated list of Processors and their contact details from the Data Controller. The data may be transferred to third parties having their registered office in a country (in particular Switzerland) for which an adequacy decision exists or that offers adequate guarantees pursuant to articles 45 and 46 of EU regulation 2016/679.

TABLE B:

MARKETING DATA PROCESSING

Purposes of processing	The personal data collected by Fabo S.p.A., with consent, may be processed for the following distinct purposes: To send commercial or promotional communications electronically or on paper; to subscribe to our mailing list to receive the Newsletter with information on updates on new products and/or services offered by our Company or any promotions and Company participation in trade fairs or industry events. Your data may also be processed for the forwarding of commercial and promotional communications, for the sending of advertising material, for purposes of direct sales and for carrying out market research (all jointly referred to as “Marketing Purposes”). The processing of data for marketing purposes may take place through automated contact tools, such as email, SMS or instant messaging. In addition, you may also be contacted for marketing purposes by traditional means, such as sending letter post or phone calls via a telephone operator.
Legal basis	Consent
Consequences of withholding data	The processing of personal data for the further purposes set out in this table may only take place with your express consent, which constitutes the legal basis of the processing. This consent is free, optional and always revocable and any refusal does not in any way preclude the performance of obligations arising from the existing contractual relationship, but will only make it impossible to be subscribed to the Fabo S.p.A. Newsletter to receive updates on new products and/or services, or to receive other commercial or promotional advertising.
Retention period	24 months. Before the end of the 24 months you will be asked if you wish to continue receiving our commercial information, otherwise your data will be deleted.
Disclosure to third parties	Your data may be communicated to the following categories of recipients, appointed as external data processors: To the email manager To the Marketing and Communication Agency To the Agency that maintains the website and web hosting To the company that manages Newsletter forwarding You may, at any time, request an updated list of Processors and their contact details from the Data Controller.

TABLE C:

PROCESSING OF APPLICATION DATA

Purposes of processing	If, spontaneously or following a staff search, you send us an application form, a curriculum vitae or submit a proposal for collaboration, the data you provide will be processed by Fabo S.p.A. for the following distinct purposes: For the assessment of the candidate and his/her professional experience, for any interviews with the candidate, to propose other job offers or collaboration related to the candidate’s profile.
Legal basis	Consent. By sending us your application, you have given your consent to the processing of your personal data by means of this form. Pre-contractual reports (assessment of the applicant) adopted following the application
Consequences of withholding data	The processing of personal data for the further purposes set out in this table may be carried out with your consent or, if you have not provided such consent, on the legal basis of the implementation of the pre-contractual measures. This consent is free, optional and always revocable and any refusal does not allow FABO to further consider your proposal.
Retention period	Until the “open position” is closed or if the “open position” closing date is not indicated, 24 MONTHS
Disclosure to third parties	Your data will not be disclosed to third parties

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RIGHTS OF THE DATA SUBJECT

With regards to the data provided, you may at any time exercise the following rights, for all or part of the data and/or processing.

Right of access (Article 15): you may ask the owner to confirm whether your data is being processed, access the data and/or obtain a copy of the data concerning you that we process.
Right of rectification (Article 16): you may ask for your personal data to be updated, corrected or integrated.
Right of oblivion (Article 17): if any of the following apply, you may request erasure of your personal data which will be permanently deleted by us.
Right of limitation (Article 18): if one of the conditions provided for by this rule is met, you can request the limitation of the processing of your data. In such case, the data will be stored but no longer processed for other purposes.
Right of portability (Article 20): under the conditions of this standard, you can request to receive your personal data in an interoperable format and/or transfer them to another Data Controller.
Right of opposition (Article 21): you may oppose to all or part of the processing specifying the reason, provided there are sufficient grounds for doing so. You may also object to processing for marketing purposes at any time and without any justification. In this case, processing for marketing purposes will cease immediately.

If the legal basis for processing is consent, you may revoke your consent at any time. In this case, processing will cease for all processed data for which you have revoked your consent, unless there is a different legal basis for the processing (Right to withdraw consent: Article 7, paragraph 3).

These rights may be exercised with a request addressed without formalities to the data controller at the above addresses of the Privacy Office, to which a suitable response will be given without delay, and in any case no later than one month from the request.

If you believe that your rights have been violated, you can also lodge a complaint with the Guarantor for the protection of personal data pursuant to Article 77 EU regulation 2016/679.

This policy may be modified at any time due to changes in our practices. We therefore invite you to consult it regularly. In the event of a change, the “Date of last change” at the end of this notice will be updated.

Last modification date 25.05.2018