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Privacy

STATEMENT OF INFORMATION PURSUANT TO ARTICLE 13 OF LEG. DECREE 196/2003 ON PERSONAL DATA PROTECTION (PRIVACY)

Leg. Decree no. 196 dated 30th June 2003 (Code concerning personal data protection) provides for the safeguard of individuals and other subjects with regard to the treatment of personal data.
In compliance with the provisions set out in the abovementioned code on privacy, we provide all necessary information pertaining to the purposes and methods applied in the treatment of your personal data, with regard to their communication and disclosure as well as the nature of the data in our possession and their submission procedures.

The treatment of data will be carried out in conformity with all fundamental rights and freedoms and based upon principles of fairness, legitimacy, transparency and protection of the confidentiality of the subject’s data and rights.

INFORMATION ON THE TREATMENT OF COLLECTED DATA

The treatment of data comprises any operation or group of operations referred to in article 4, paragraph 1, letter a) of Leg. Decree 196/03, i.e. «the collection, recording, organization, preservation, consultation, processing, modification, selection, retrieval, comparison, use, interconnection, block, communication, cancellation and destruction of the data, even if not registered in a data base». After obtaining appropriate consent to it, in the cases permitted by law and pursuant to all existing legal provisions, the treatment of data may also include all personal data falling into the category of the «sensitive» data, meaning, according to the prescriptions set out in the abovementioned article 4, any data revealing the subject’s racial and ethnic origin, religious or philosophical convictions, political opinions, joining political parties, trade union organizations or any associations of a political, religious or philosophical nature, as well as any data revealing the subject’s health status and his/her sexual preferences.

1. Purposes of data processing

The data you have submitted to us will be processed, within the limitations prescribed by the existing legislation, for the following purposes:

  1. allow for a correct and comprehensive execution of the agreement and/or the professional assignment conferred;
  2. guarantee all communications with regard to the execution of the agreement and/or the professional assignment conferred;
  3. comply with all provisions set out in the applicable legislation and in the agreement;
  4. following a possible optional consent, organize the issue of commercial communications, via fax, e-mail or other means, in relation to any activities proposed or organized by the company;
  5. define the relationship between the subject’s professional attitudes and the role he will occupy;
  6. support all personalized training and motivational techniques in order to better interpret the subject’s personality with the aim to enhance productivity and efficiency in the execution of the business activities.

2. Methods of data processing

Data processing will be carried out pursuant to the provisions set out in article 11 of Leg. Decree 196/2003 and may be executed either manually or through the use of automated systems such as computers, telematic, audiovisual, cable and satellite devices and magnetic and paper means; in any case always by individuals specifically trained to do the task. Data processing will be carried at the Territorial Office of OTO Mills S.p.A. strictly according to the purposes specified in paragraph 1 contained herein, and with specific methods aimed at guaranteeing the data’s security and confidentiality through the adoption of suitable measures to avoid its alteration, cancellation, destruction, unauthorized access or treatment which may not be permitted or may not be in conformity with the pre-defined collection purposes.
In case of termination of a data treatment operation, for whatever reason, all data shall be destroyed or transferred pursuant to the provisions set out in article 16 of Leg. Decree 196/2003. The treatment of personal data shall last for a period of time not longer than what deemed necessary to fulfil the purposes for which it was collected in the first place. Should the data subject think, for whatever reason, that the company no longer needs to hold his data, he may notify, without formality, his intention to the latter pursuant to the instructions set out in paragraph 7.

3. Nature of data submission and possible consequences of a consent refusal

The submission of data by a candidate is optional but at the same time necessary to fulfil all relevant contractual, fiscal and accounting obligations. Refusing to submit personal data may result in the impossibility, full or partial, to provide for the requested service. The data processor also informs that, failure to communicate or the erroneous communication of said information, will entail the following consequences:

  • full or partial impossibility to carry out the requested service;
  • impossibility to guarantee the adequacy of the data processing procedure under the contractual covenants regulating its execution;
  • possible failure to meet the results of the processing operation under the obligations set out by the applicable legislation.

Failure to consent to the treatment of your personal data as referred to in paragraph 1 letter d) will not have any consequences whatsoever.

4. Communication and disclosure of personal data

Your personal data is not subject to diffusion but may be communicated to the other companies of the Group. Also, in case of research activities or personnel analysis duties it may be communicated, subject to due consent and pursuant to the applicable Code, to the entity that requested for said research or personnel analysis, in the person of the legal representative pro tem.

5. Data owner

The data owner here is OTO Mills SpA, having its registered office at Via Domenico Marchesi 4 in Boretto (Reggio Emilia).

6. Data Processor

Data processor shall be Claudio Sarzi Braga, domiciled for his office at OTO Mills SpA, also to respond to any possible queries from data subjects in case of their exercise of rights referred to in article 7.
There are also other officers responsible for the processing of data who are easily recognizable, without formality, according to the provisions specified in following paragraph no.8.

7. Rights of data subjects

Pursuant to article 7 of Leg. Decree 196/2003:

  1. The data subject has the right to obtain confirmation of the possible existence of personal data concerning him, even if not yet registered, and to be guaranteed that their communication will be in intelligible form.
  2. The data subject has the right to obtain an indication of:
    1. the source of the personal data;
    2. the purposes and methods of their processing;
    3. the logic applied in case of data processing carried out by means of electronic devices;
    4. the personal details of the data owner, data processors and the designated person in charge of the processing pursuant to article 5, paragraph 2;
    5. the subjects and categories of subjects to whom or which the personal data can be disclosed to or any entities that might know of said data in their capacity of designated representatives within the territory of the State, data processors or officers in charge.
  3. The data subject has the right to obtain:
    1. the updating, rectification or, where interested therein, integration of the data;
    2. erasure, anonymization and block of data that have been processed unlawfully, including the data whose retention is not necessary in relation to the purposes for which the data was collected or subsequently processed;
    3. certification to the effect that the operations referred to in letters a) and b) have been notified to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
  4. The data subject has the right to oppose, in whole or in part:
    1. for legitimate reasons, to the treatment of personal data concerning him, even if pertaining to the purpose of the collection of said data;
    2. to the treatment of personal data concerning him used for marketing, advertising or selling purposes or for carrying out market research or commercial communication operations.

8. How data subjects can exercise their rights

Data subjects may exercise their rights pursuant to article 8 of Leg. Decree 196/2003 by sending an e-mail to otoinfo@otomills.com or by submitting any other claim, without formality, to the data owner or data processor, even by means of a representative in charge.