Privacy Policy

Privacy Policy Statement in accordance with Articles 13 and 14 of Regulation EU No. 679/2016

Digitec S.r.l. will collect and use your personal data when you visit or use the services on the website https://www.digitecinnovation.com/

“Personal Data” refers to any information that can be used to identify you as an individual.

The purpose of this policy statement is to provide you with clear, detailed explanations about how, when, and why we collect and use your personal data. It has been designed to give you a simple, transparent understanding of our data protection policy, and to explain how you can exercise your rights as a data subject effectively.

This information only pertains to personal data processed by Digitec S.r.l. on this Website. It does not cover any other website, platform or social media page that may be accessible through links found on this Website. Please always refer to the policy statements available on third-party sites.

This policy statement may be amended or varied over time; we therefore ask you to check back to this page regularly, to receive updates on the processing of data.

CONTENTS:

1. Who is the Data Controller?

2. Who is the DPO (Data Protection Officer)?

3. When do you collect my personal data?

4. Which data do you process?

5. For which other reasons might you use my data?

6. With whom do you share my data?

7. How do you process my data?

8. Will my data be transferred outside Europe?

9. For how long will you store my data?

10. Links to third-party websites and social media

11. What are my rights as data subject and how can I protect my privacy?

12. Can I lodge a complaint?

13. Changes

1. Who is the Data Controller processing my data?
As Digitec S.r.l., VAT no. 01647550134 determines the purposes and methods of the processing of personal data involved in the use of this Website, it is the Data Controller.

You may contact the Data Controller by sending a communication to the following addresses:

Post: Digitec S.r.l., Via Caduti Lecchesi a Fossoli, n.17, 23900, Lecco (LC);

E-mail: privacy@digitecinnovation.com;

Certified e-mail (PEC): digiteclecco@pcert.it.

2. Who is the DPO (Data Protection Officer)?
Digitec S.r.l. has appointed a Data Protection Officer (DPO) whom you can contact for more information or clarification about the processing operations performed by the Data Controller, or to request assistance with the exercise of your rights as the data subject (also see paragraph 11 below).

To contact the DPO you can use the addresses given for the Data Controller, or send an e-mail to: fioriglio@fclex.it.

3. When do you collect my personal data?
Digitec S.r.l. will collect information given directly by you:

• when you access or browse the Website;
• when you send us requests or questions through the relevant contact forms or sections;
• when you request information or assistance related to our products and/or services;
• if you send us a job application;

if you subscribe to the newsletter.

4. Which data do you process?
When browsing on the Website of Digitec S.r.l., the following types of data may be processed:

a) Browsing data
Some of the personal data whose transmission is implicit in the browsing of websites, including but not limited to data traffic and data regarding localisation, weblogs and other communication data, or data pertaining to the resources you access through your device, may be acquired by our computer systems to allow their correct functioning. Although this information is not collected to be associated with any identified data subjects, it may be used to allow the identification of the users - by its nature or by elaboration and association with data held by third parties. This category of data includes the IP addresses or domain names of computers used by persons connecting to the Website, the unique addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server and other parameters about the operating system and browser used.

Purposes of the processing: to allow the safe, correct use of the Website;

Legal basis for the data processing: the legitimate interest of Digitec S.r.l. in the correct functioning of the Website and the security of browsing, duly balanced against the rights of the Data Subject (Art. 6 (1 f) GDPR).

b) Requests for information or assistance through the relevant sections

You may contact us using the contact forms or addresses given on the Website in order to request information or assistance, also in respect of individual products; this will entail the acquisition of the personal data you provided us with (name, surname, company, e-mail address and other information contained in the communication), and obviously, this will allow us to reply to you, using the contact details you gave at the time of the request.

Purpose of the data processing: to provide you with adequate assistance in relation to your requirements and to reply to your questions;

Legal basis for the data processing: the provision of the service you requested (Art. 6 (1 b) GDPR).

c) Work with us

You may contact us to apply for a job vacancy by completing the form in the “Work with us” section, thus authorising the Data Controller to use your personal data for this purpose. To this end you will be asked to give your identification details (name and surname), a phone number, contact e-mail address and a file containing your CV, as this information is required in order for Digitec S.r.l. to consider your application.

The provision of this personal data is only obligatory in order to submit a job application. It is left to the discretion of the individual candidate as to whether they wish to send a CV: failure to provide a CV will make it impossible to use the service but will have no further consequences.

Consent to the data processing is not necessary, pursuant to Article 111bis of Italian Legislative Decree 196/2003 (the Privacy Code, as amended by Legislative Decree 101/2018) and Article 9 paragraph 2 (b) GDPR, when the data processing relates to data contained in a CV sent spontaneously by candidates in order to establish a working/collaboration relationship, even if the data are included in the special categories provided for in Article 9 of the GDPR (for example where the data are required for reasons related to the new working relationship, with particular reference to the candidate’s membership of protected categories or the need for pre-employment medical examinations). If selected for interview, the data subject will be provided with full information about the processing of their personal data.

The data will be stored for the period necessary to consider your application and in any case, for up to 12 months after the last contact between Digitec and the candidate. Additionally, if the candidate sends a request to the Data Controller, all the information sent can be erased at any time.

Purpose of the data processing: to provide the service requested by the data subject and assess their CV with a view to possible employment;

Legal basis for the data processing: to execute the contract to which the data subject is a party (Art. 6 (1 b) GDPR).

d) Newsletter
The newsletter of Digitec S.r.l. will be sent by e-mail to those who explicitly request it, by filling out the newsletter form on the Website with an e-mail address, thereby authorising Digitec S.r.l. to process their personal data for this purpose. The newsletter service will only be provided with the express, unequivocal consent of the user (given by checking the relevant box on the Website). The provision of this personal data is only obligatory in order to receive the newsletter and any refusal to provide the data will make it impossible to use the service but will have no further consequences.

The newsletter service is delivered through the Sendinblue platform operated by Sendinblue SAS, headquartered at 7 rue de Madrid, 75008 Paris: for more information see the privacy policy at this link: https://www.brevo.com/legal/privacypolicy/

If you no longer wish to receive the newsletter, simply click on the "Unsubscribe” link at the bottom of each e-mail or send an Unsubscribe request to privacy@digitecinnovation.com. Cancellation from the newsletter service is partially automated and therefore newsletters scheduled for dispatch before your Unsubscribe request was sent, may be received after the time of the request, but in any case no longer than 72 hours thereafter.

Purpose of the data processing: to send the data subject e-mail communications about the products and services of Digitec S.r.l., as well as news and updates about related topics, offers and promotions for subscribers;

Legal basis for the data processing: the consent of the data subject (Art. 6 (1 a) GDPR).

e) Sending of marketing communications within the scope of legitimate interest; soft spamming

In some cases, we may use an e-mail address provided by a user browsing the Website (for example, in the case of requests about specific products) to send promotional communications even without requesting prior consent from the user. This type of data processing takes place in accordance with Art. 6 f) GDPR and Art. 130 paragraph 4 of Italian Legislative Decree 130/2003. In particular, users will be informed about the data processing through this policy. They have the right to object to such processing, simply and free of charge. Each communication sent by the Data Controller contains a reference to this information and details of how to opt-out, either by contacting the Data Controller or by selecting the link at the bottom of each communication.

• Purposes of the processing: to inform you about products you may be interested in;
• Legal basis for the data processing: compliance with Article 130 paragraph 4 of Italian Legislative Decree 196/2003 authorising the sending of communications about products or services similar to those already requested (Art. 6 (1 c and f) GDPR).

f) Cookies
What are cookies? Cookies are small text files that store brief information about the browsing of a certain website. They are installed on your device when you access the website. Each cookie contains different types of data (for example the name of the originating server, or a numerical identifier). It may remain on the system for the duration of a session (until the browser is closed), or for long periods, and it may contain a unique identifier.

When you visit the website again, the cookies will be redirected to the website that generated them (first-party cookies) or to those provided by third parties able to recognise them (third-party cookies).

Digitec S.r.l. would like to reassure you as to the security of the cookies found on its website. They will not damage your device in any way but they will give you a faster and better browsing experience.

What are they for? Cookies are used for different purposes depending on their type. Some of them are strictly necessary for the proper functioning of the website (technical cookies), while others optimise the website’s performance to offer a better user experience or to allow the acquisition of website statistics, such as analytics cookies. Other types, such as profiling cookies, allow you to view custom advertising.

The Website of Digitec S.r.l. may use cookies that do not require your consent for installation (such as technical cookies), as well as those that do require your prior consent, unless they are anonymised (such as analytics cookies). This information is contained in the banner which you will see on the Website landing page, and in the Cookies settings panel, which is always available on the Website.

In particular, the following cookies may be activated:

a. Technical cookies (which do NOT require your consent):
These cookies are necessary for the functioning of the Website and allow you to access its functions (browsing cookies) or to log in to the session.

This type of cookie includes functional cookies, which will store the user’s preferences and settings, thus giving them an improved browsing experience.

To guarantee their functionality, these cookies are not usually eliminated when the browser is closed. However, they do have a predefined duration (usually up to a maximum of 2 years), after which time they will automatically be deactivated. These cookies and the data they collect will never be used for any other purpose.

Technical cookies are installed automatically after accessing the Website, or to activate certain functions (such as the “Remember me” option).

The user can decide to disable these cookies at any time by changing the browser settings: however, this may cause certain issues with the display of the Website.

Purpose: to guarantee the proper functioning and safety of the Website;

Legal basis for the data processing: the legitimate interest of Digitec S.r.l. in the correct functioning of the Website and the security of browsing, duly balanced against the rights of the Data Subject (Art. 6 (1 f) GDPR).

b. Analytics cookies (which may NOT require your consent, if anonymised)

These cookies keep a record of the choices made on the Website and details of the users’ online browsing behaviours (pages viewed, time spent on a page etc.) in order to carry out statistical analysis, usually in anonymised, aggregate form. If the users can be traced and identified through this type of analysis, these tools can only be used with prior consent of the user.

However, in the following circumstances:

- when the IP address has been duly anonymised;

- when the information obtained with the analytics cookies will only refer to a single digital resource (website, app etc.) and will only be used in anonymised, aggregate form;

- when the cookie provider does not combine the information with other process data and does not send it to third parties,

there is a complete guarantee of data anonymity and the cookies in this category may be activated without the need for consent from the user, precisely because the process data cannot be linked to any identifiable user.

• Purpose: To obtain statistics about the behaviour of users of the Website, based on aggregate, anonymised data.
• Legal basis for the data processing: as the case may be:

- the legitimate interest of Digitec S.r.l. in optimising the performance of the Website and improving the services offered through it, duly balanced against the rights of the Data Subject (Art. 6 (1 f) GDPR);

- the user’s consent (Art. 6 (1 a) GDPR), freely given and revocable at any time, using the cookies banner or following the indications below and in the Cookie Policy on this Website.

c. Profiling and marketing cookies (which require your CONSENT):

In the case of profiling and third-party cookies, their installation is always subject to your prior consent, given through the banner or managed in another way through the Cookie Policy.

Profiling cookies may include various categories, such as advertising, retargeting, or social cookies.

Advertising cookies are used to create user profiles, to allow you to see advertising content based on the preferences shown when browsing the Website;

Retargeting cookies are created to send you advertising content relative to the products you have purchased or viewed on the Website, or products you have shown interest in;

Social cookies: this Website installs cookies relative to social network plug-ins. These cookies are managed directly by third parties and allow you to see advertising content in line with your preferences.

When you access the Website, a banner will inform you of the presence of profiling and retargeting cookies. You can use this banner to accept or refuse this type of cookies and select individually those cookies that you do wish to install.

You may withdraw your consent at any time, without affecting the possibility of visiting the Website or using the content.

The installation of profiling, retargeting, analytics, and social cookies, including all related activities, is managed through third-party services. For more information or to activate or deactivate these cookies, see the policy statements issued by the third-party companies: a list can be found in our Cookie Policy https://www.iubenda.com/privacy-policy/75758970/cookie-policy.

The user will be informed both through the banner displayed until consent is given or refused, and also in our Cookie Policy https://www.iubenda.com/privacy-policy/75758970/cookie-policy, which we ask you to read carefully to obtain all the other information about the cookies used on this Website, and for details of how to deactivate them.

• Purpose: to analyse the user’s browsing behaviour in order to display personalised advertising;
• Legal basis for the data processing: the user’s consent (Art. 6 (1 a) GDPR), freely given and revocable at any time, using the cookies banner or following the indications below and in the Cookie Policy -https://www.iubenda.com/privacy-policy/75758970/cookie-policy.

d. Social media buttons
The Website contains buttons referring users to the Data Controller’s social network pages. Certain marketing and third-party cookies may be activated when clicking on these buttons, for the purposes of marketing and profiling by the third parties that manage the social networks. The Website Data Controller does not directly manage these buttons but wishes to inform you that by using the functionalities on this Website, these buttons will be activated. For more information, including details of how to deactivate these cookies, please read the data protection statements of the social networks:

• LinkedIn: https://www.linkedin.com/legal/privacy-policy?
• YouTube: https://policies.google.com/privacy?hl=en-GB

Deactivation through the browser

From the website https://www.youronlinechoices.com/uk/ you cannot only obtain more information about cookies but you can also check whether many types of cookies have been installed on your browser/device and, if they are supported, you can also deactivate them.

The commonly used browsers (such as Chrome, Safari, Internet Explorer, Firefox, and Microsoft Edge) also accept cookies by pre-defined settings, but these can be changed by the user at any time. This applies both to desktop computers and mobile devices such as tablets and phones: this is a general and commonly-supported function.

Cookies can thus be deactivated or disabled by accessing the options or preferences on the browser you are using. Generally, it is also possible to block only the cookies of third parties. In general, these options will only take effect for the particular browser and device, unless you have activated options to synch these preferences to other devices. Specific instructions can be found on the Options or Help page of the browser. However, if you do decide to deactivate technical cookies, this may impair the full and/or proper functioning of various websites including this one.

Usually, modern browsers:

• offer a “Do not track” option, which is supported by certain websites (but not all of them). Choosing this option, certain websites may no longer collect certain browsing data;
• offer the option of anonymous or incognito browsing: by choosing this option, data will no longer be collected on the browser, and browsing history will not be saved, although browsing data may still be acquired by the operator of the website you visited;
• allow the elimination of all or some of the stored cookies, but on your next visit to a website, they will usually be installed, unless this possibility has been blocked.
• Below is a list of links to the support pages of the most popular browsers (with instructions on how to deactivate cookies on these browsers):
• Chrome (desktop: Clear, allow, & manage cookies in Chrome - Computer - Google Chrome Help; Android and iOS https://support.google.com/chrome/answer/2392971?hl=en);
• Safari (iOS) (Clear the history and cookies from Safari on your iPhone, iPad or iPod touch – Apple Support (UK));
• Internet Explorer ( Delete and manage cookies - Microsoft Support);
• Firefox (https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox);
• Microsoft Edge (Delete cookies in Microsoft Edge - Microsoft Support).

5. For which other reasons might you use my data?
Finally, your personal data may be used to:

a) comply with legal obligations and requests from public or government authorities;

b) manage disputes or litigation and defend the rights of Digitec S.r.l., in court or out of court.

In such cases, the legal basis for the data processing will be:

- for point a), the fulfilment of a legal obligation;

- for point b), the Data Controller’s legitimate interest in the protection of its rights, provided that they are adequately balanced in each case with the rights of the data subject.

6. With whom do we share your personal data?
In accordance with the purposes indicated in the previous section, the personnel of Digitec S.r.l. may be asked to process your data in order to provide you with the requested services, information, or support.

Therefore, access to your personal data will be expressly authorised by the Data Controller, who may, where necessary, appoint persons to be contacted for the provision of services and for their activities as Data Processors, pursuant to Articles 28 and 29 of the GDPR.

To this end, please note that:

- the newsletter service is provided by Sendinblue SAS, headquartered at 7 rue de Madrid, 75008 Paris, via the Brevo/Sendinblue platform;

- the hosting service is provided by Hosting Solutions, the provider of Genesys Informatica S.r.l., headquartered in Via dei Cattani 224/18, 50145- Florence;

- the list of cookies provided is available in the Website Cookie Policy.

Please also remember that a list of data processors can be obtained from the data controller, by contacting the addresses indicated above.

User data will under no circumstances be passed to any third party, except where required in relation to the nature of the services or in the event that the Data Controller has to provide the data to the courts or other competent authorities in order to fulfil a legal obligation or where it has a legitimate interest.

7.How do you process my personal data?
Your personal data will also be processed with electronic instruments for the time strictly necessary to achieve the purposes for which it was collected.

Digitec S.r.l. will take all the technical and organisational measures essential to prevent the loss, unauthorised or incorrect use of the data and to prevent any form of unauthorised access by a third party.

Therefore, Digitec S.r.l. will guarantee the security of your personal data by limiting the number of persons who may access the servers or databases and by putting in place protection systems in order to reduce the risk of cyber attacks.

8. Will my data be transferred outside Europe?
The data processed by Digitec S.r.l. are hosted on servers located in Italy, managed by Hosting Solutions, the provider of the company Genesys Informatica S.r.l.

However, certain service providers, particularly in the case of third-party cookies, are based in non-EC countries, specifically in the United States of America as indicated specifically in our Cookie Policy. In these cases, your personal data may also be transferred to servers in the USA, which is considered by the European Data Protection Authorities as a country that does not offer data protection guarantees equivalent to those provided for in the GDPR. In these cases, the Data Controller will use these providers in accordance with the provisions of Articles 45 et seq. of the GDPR. Full precautions will be taken in order to guarantee the best possible protection of your personal data, by basing such transfers on: a) the European Commission’s adequacy decisions regarding the recipient third countries; b) adequate guarantees given by the third-party recipients under Art. 46 of the Regulation; c) the adoption of Corporate binding rules and in particular, by providing the technical and information security measures designed to protect as far as possible the personal data and rights of the data subjects, as provided for in the GDPR and European legislation.

9. For how long will you store my data?
Digitec S.r.l. will process your personal data for the time reasonably necessary to pursue only the purposes listed above, which can be viewed in the Section “Which data do you process?” - for the conservation periods provided for in-sector regulations. In addition:

- personal data used for the sending of newsletters will be kept until you ask for them to be erased;

- data used for soft spamming will be kept until you ask for them to be erased or for two years from the last time you showed interest in Digitec S.r.l. (for example by contacting us through the Website);

- for details of the terms of erasure for data processed with cookies, see our Cookie Policy.

At the end of the conservation period, your personal data will be erased or rendered permanently anonymous.

10. Links to third-party websites and social media
The Website may contain links to and from the websites of our partners, including advertisers and social networks. Please note that the Data Controller declines all responsibility for any personal data collected by partner websites or from the use of their services. If the user follows a link to any of these websites, they are asked to read the privacy policy provided by each party external to this Website.

11. What are my rights as data subject and how can I protect my privacy?
In relation to your personal data and in accordance with the GDPR, Digitec S.r.l. informs you that can have the right to request:

• access to your personal data;
• the amendment or rectification of any error in our database, pertaining to your data;
• the erasure of your data, if they are kept without the necessary legal conditions;
• the limitation of the processing of your personal data;
• opposition of the processing of your data;
• data portability.

Data protection forms and more information can also be found at: https://www.garanteprivacy.it/web/garante-privacy-en/home_en

The table below illustrates in detail how you can exercise your rights:

Digitec S.r.l. guarantees that all requests regarding your rights will receive a reply within thirty days.

12. Can I lodge a complaint?
You can lodge a complaint to the Italian Data Protection Authority if you consider that the data processing by Digitec S.r.l. does not conform to the provisions of Regulation EU No. 679/2016 or of national legislation.

In Italy, the competent authority is the Data Protection Authority, whose contact details are available at https://www.garanteprivacy.it/web/garante-privacy-en/home_en.

More information, together with the model complaint form, can be found here: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524.

In addition, where the conditions of Articles 78 and 79 GDPR are met, you can also lodge a complaint with the competent court.

13. Changes
The information contained in this policy statement may be varied in future, where there are changes to the processing operations, the data collected, or where changes are made to laws or regulations, or technical developments. We recommend that you check back to this Privacy and Cookie Policy, which is regularly updated on this page.