PRIVACY POLICY

The Data Controller of the data collected through this site is IFP EUROPE S.R.L-SOCIETÀ BENEFIT (hereinafter also referred to as “IFP EUROPE”), with registered office in Via Po, 1, 35015, Galliera Veneta (PD), privacy@ifpsrl.com.
It decides independently on the purposes and methods of processing, as well as on the security procedures to be applied to ensure confidentiality, integrity, and availability of data. 

PURPOSES OF PROCESSING

The specific purposes for which the data are processed are:

1. Preparation of quotes;
2. execution of contracts and related commitments;
3. fulfillment of obligations provided for by laws connected to the contractual relationship;
4. organizational management of the contract, for example, relationships with employees, external collaborators;
5. any external professional collaborations for the fulfillment of legal obligations;
6. protection of contractual rights;
7. reception and management of Curricula vitae;
8. management of information requests in the “Contacts” section;
9. sending newsletters and marketing activities in general.

METHODS OF PROCESSING AND DATA RETENTION

Personal data are processed mainly using electronic and automated methods.

Processing operations are implemented in such a way as to guarantee the logical and physical security and confidentiality of your personal data.

The data provided will be kept for the time strictly necessary to achieve the purposes for which they were collected, namely:

• those collected for the purposes referred to in points 1 to 5: for the entire duration of the contractual relationship and for a period of 10 years following the conclusion of the contract;
• those collected for the purpose referred to in point 6: for the time necessary for the limitation period of the rights arising from the contractual relationship;
• data contained in Curricula vitae: for 12 months;
• data relating to the management of the data subject's requests: for the time necessary to satisfy the data subject's request;
• data collected for sending commercial communications as part of direct marketing (based on the legitimate interest of the Data Controller): until the exercise of the right to object expressed with the request to unsubscribe. In the case of data collected for sending commercial communications as part of direct marketing (based instead on the consent of the data subject): until the withdrawal of consent, expressed with the request to unsubscribe. It is specified that in any case, the data processing will not be indefinite, as after 5 years of an inactive profile, test e-mails will be sent to the user and if the profile remains inactive, the data will be permanently deleted.
  Regarding data related to any purchases, used to personalize commercial communications, these will be kept for a maximum period of 24 months.

MANDATORY OR OPTIONAL NATURE OF PROVIDING DATA AND LEGAL BASIS (LAWFULNESS CONDITION)

The provision of personal data to IFP EUROPE, which is requested on various collection occasions, may be mandatory or optional.

In the case of the purposes indicated in points 1 to 6 and point 8, the provision of data is mandatory and failure to provide it will make it impossible to execute what is requested.

For the purpose indicated in point 7, the provision is mandatory, otherwise, in its absence, the application cannot be considered.

For the purpose indicated in point 9, the provision is optional.

For the sake of completeness, it should be remembered that in some cases (not subject to the ordinary management of this site) the Authority may request news and information pursuant to art. 157 of Legislative Decree no. 196/2003, for the purpose of monitoring the processing of personal data. In these cases, the response is mandatory under penalty of an administrative sanction.

The legal basis and/or lawfulness condition of the processing is as follows:

• the contract for the purposes indicated in points 1, 2 and 4;
• fulfillment of a legal obligation for the purposes indicated in points 3 and 5;
• the legitimate interest for the purpose indicated in point 6;
• for the processing of data contained in curricula vitae (purpose indicated in point 7) it is the consent provided at the bottom of the C.V.. It is noted that pursuant to art. 111-bis of Legislative Decree 2003 n. 196, in case of spontaneously sent curricula vitae not containing special categories of data, no consent from the data subject is required.
• the consent of the user requesting information (purpose indicated in point 8), expressed by entering the data in the form of the “Contacts” section.
• for the purposes indicated in point 9 (sending newsletters and marketing activities in general) it is consent, in the absence of which it will not be possible to send newsletters, commercial communications or collect data to personalize the aforementioned commercial communications. For some commercial communications carried out as part of digital campaigns, data may be collected through tracking solutions, for which information on data processing is available in the cookie policy (link).
  With reference, instead, to cases where the data subjects have provided their contact details in the context of a previous commercial relationship (contract or request for quote/offer) with IFP EUROPE, the latter may use their data for sending communications about its own products and services, similar to what has already been purchased, even without having acquired specific consent, unless such use is refused (so-called “soft spam” - art. 130, paragraph 4, Legislative Decree 196/2003; art. 6, paragraph 1, letter f) of EU Reg. 2016/679). In this case, in fact, the legal basis justifying the processing is the legitimate interest of the Controller (Recital (47) of EU Reg. 2016/679).

SCOPE OF COMMUNICATION AND DISSEMINATION OF DATA

Data may be communicated to:

• all subjects to whom the right of access to such data is recognized by virtue of regulatory provisions;
• our collaborators and employees, within the scope of their respective duties, appointed to process the data provided by you;
• third parties, adequately selected and equipped with experience, capability, and reliability, who offer a suitable guarantee of full compliance with current provisions regarding processing, including the data security profile. These third parties have been appointed "data processors" and carry out their activities according to the instructions provided by IFP EUROPE.

Among these:

• companies and professionals used by the controller;
• companies and professionals used by the Customer, for specific services and always at the request of the Customer themselves;
• contracting companies, self-employed workers operating on behalf of IFP EUROPE S.R.L..

TYPES OF DATA PROCESSED

IFP EUROPE may collect users' personal data during navigation of this Site or on the occasion of the request for activation of some services through the appropriate data collection forms. It may also acquire information about users by deriving it from the interaction methods carried out on the Site through cookies.

In summary: consultation of the Site may involve the processing of data relating to identified or identifiable natural persons. Such data are divided into three general categories:

• navigation data and data acquired through cookie tracking;
• data voluntarily provided by the user.

Data acquired automatically (subject to consent if necessary)

Cookies

The use of cookies by IFP EUROPE is part of the Manager's privacy policy and complies with the new Guidelines on the use of cookies and other tracking tools issued on 10.06.2021 and entered into force on 9.01.2022.

Please refer to the Cookie Privacy (link).

Navigation data

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This category of data includes IP addresses or domain names of computers and terminals used by users, URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of the request, the method used in submitting 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 (success, error, etc.) and other parameters related to the user's operating system and computer environment.

These data, necessary for the use of web services, are also processed to:

• obtain statistical information on the use of services (most visited pages, number of visitors per time slot or daily, geographical areas of origin, etc.);
• ascertain responsibility in case of hypothetical computer crimes against the site. See Garante
• check the correct functioning of the services offered.

Navigation data do not persist for more than seven days (except for any need to ascertain crimes by the judicial authority).

Data voluntarily provided by the user

Personal data

MARKETING CAMPAIGNS AND PROFILING

IFP EUROPE may also carry out personal data processing activities in the context of digital marketing campaigns in the future. For such processing, the legal basis will be the consent provided by the user by accepting the cookies on the site. Such consent can always be withdrawn through the cookie settings, as indicated in the Cookie Policy.

IFP EUROPE may also collect some personal data on the occasion of the user's interaction with Social Pages. Some information, in fact, is communicated to IFP EUROPE directly by the user, when they decide to share, through their profile, images published on IFP EUROPE's social pages, comment on posts and/or products present therein.

Knowledge of personal information will depend on the settings of the individual social media used by the user and the content that the latter chooses to make public. To this end, users are invited to read the privacy policy of the various social media and check their privacy settings.

SECURITY MEASURES

IFP EUROPE has adopted appropriate security measures in order to minimize the risks of destruction or loss - even accidental - of data, unauthorized access or processing that is not permitted or does not comply with the collection purposes indicated.

RIGHTS OF DATA SUBJECTS pursuant to arts. 7, 15, 16, 17 18, 20, 21 and 22 of EU REG. 2016/679

We inform you that in your capacity as a data subject, you have, in addition to the right to lodge a complaint with a supervisory authority, the rights listed below, which you may exercise by sending a specific request to the Data Controller.

Art. 15 - Right of access

The data subject has the right to obtain from the data controller confirmation as to whether or not personal data concerning them are being processed, and where that is the case, access to the personal data and information regarding the processing.

Art. 16 - Right to rectification

The data subject has the right to obtain from the data controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Art. 17 - Right to erasure (right to be forgotten)

The data subject has the right to obtain from the data controller the erasure of personal data concerning them without undue delay and the data controller has the obligation to erase personal data without undue delay.

Art. 18 - Right to restriction of processing

The data subject has the right to obtain from the data controller restriction of processing where one of the following applies:

a) the accuracy of the personal data is contested by the data subject, for a period enabling the data controller to verify the accuracy of the personal data;

b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

c) the data controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims;

d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the data controller override those of the data subject.

Art. 20 - Right to data portability

The data subject has the right to receive the personal data concerning them, which they have provided to a data controller, in a structured, commonly used and machine-readable format and has the right to transmit those data to another data controller without hindrance from the data controller to which the personal data have been provided.

In exercising their right to data portability pursuant to paragraph 1, the data subject has the right to have the personal data transmitted directly from one data controller to another, where technically feasible.

Art. 21 - Right to object

The data subject has the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions.

Art. 22 - Right not to be subject to automated decision-making, including profiling

The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

Withdrawal of consent to processing

You are also recognized the right to withdraw consent to the processing of your personal data.

At the end of this operation, your personal data will be removed from the archives as soon as possible.

If you wish to have more information on the processing of your personal data, or exercise the rights referred to in the previous point, you can write to privacy@ifpsrl.com.

Before being able to provide or modify any information, it may be necessary to verify your identity and answer some questions. A response will be provided as soon as possible, within a maximum of 30 days from the request.

Requests may also be addressed to the Data Controller by writing to:

IFP EUROPE S.R.L. 
Via Po, 1
35015 - Galliera Veneta (PD) - Italy