This document is part of the information provided pursuant to Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“Regulation”), Legislative Decree No. 196 of 2003 as amended by Legislative Decree No. 101 of August 10, 2018 (“Privacy Code”) and additional applicable regulations on the protection of personal data.
The Privacy Officer, whom you can contact to exercise your rights under Art. 12, can be reached at firstname.lastname@example.org
Identity and contact details of the Data Controller
The Data Controller is Neodata Group s.p.a. (hereinafter, “Neodata”), with registered office in Viale XX Settembre, 21 – 95128 Catania. Neodata Group has provided Pursuant to art. 37, paragraph 1 letter a) of the Regulation, to appoint a DPO (Data Protection Officer) contactableat the email address: email@example.com whom you can contact for any clarifications regarding the protection of personal data.
Among the tasks that the DPO is called upon to perform are the following:
- Informing and advising the data controller or processor as well as the employees carrying out the processing about the obligations arising from the Regulation as well as from other Union or Member State provisions relating to data protection” (see Article 39(1)(a) of the Regulation)
- Oversee compliance with this Regulation, other Union or Member State data protection provisions, and the policies of the controller or processor regarding the protection of personal data, including the allocation of responsibilities, awareness-raising and training of personnel involved in processing and related supervisory activities” (see Article 39(1)(b) of the Regulation)
- Data subjects may contact the Data Protection Officer for all matters relating to the processing of their personal data and the exercise of their rights under this Regulation” (see Art. 38(4) of the Regulations).
Types of Data Processed
Neodata processes various types of Personal Data:
So-called “Identifying” Data.
This category of Personal Data includes information such as: your first name, last name, email address etc. For the collection of such Data, we ask you to fill out the appropriate online forms on our sites. The Data is collected by filling out forms, may vary from time to time depending on the form and are those corresponding to the boxes in the relevant completed online form.
Data collected automatically while you are browsing our Sites
This is information such as: the IP addresses (both static and dynamic) or domain names of the devices used by those who connect, the addresses in URI (“Uniform Resource Identifier”) notation, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used etc.
Purposes of Data Processing
The following explains the purposes of the Processing of Personal Data and on what legal basis such Processing is based:
- For the operational management of navigation on Neodata sites
The Personal Data automatically collected during your navigation allows the website to function, so that you can actually enjoy the content of the site.
- For security management of your Data and Neodata domains
To ensure the security of the information and data processed and to protect Neodata’s property.
- For the processing of statistical data
Neodata performs, also through the use of services provided by third parties, statistical analysis regarding the use of the content of its sites. These analyses, carried out at an aggregate and, therefore, anonymous level, allow us to understand fundamental aspects related to the use of the sites in order to improve the quality of their services.
- Protecting or defending rights in court
To protect or defend a right of ours before a judge, or other competent authorities.
- To fulfill obligations imposed by applicable laws or regulations, including accounting and tax matters
To fulfill obligations imposed by law that entail the Processing of the Data Subject’s Personal Data for the purposes provided for by law.
- Provision of requested services
Whenever the Data Subject wants to take advantage of the services offered by the sites such as, for example, applying for a job position) we will process Personal Data to provide what was requested and, therefore, to fulfill contractual obligations. For membership in the newsletter service, this service may be provided only if expressly requested. In particular, we point out the following with reference to the following services:
Membership in initiatives promoted by Neodata
It is possible to process Personal Data to enable participation in initiatives of a commercial or social nature promoted by Neodata. In this case, the Personal Data processed will be those indicated from time to time for participation in the specific initiative.
Following consent, Neodata may send newsletters, including those of a commercial or promotional nature, to the email address provided when subscribing to this service. You can unsubscribe from the newsletter at any time by clicking on the unsubscribe button that will be present at the bottom of each email.
The Data Subject’s Personal Data may be disclosed to specific Recipients, to whom the Data is disclosed to enable us to properly perform all Processing activities outlined in this document.
Such Recipients, may process Personal Data as:
- Data Processors
- Persons Authorized to Process.
If required by law or to prevent or suppress the commission of unlawful acts or crimes your Personal Data may be disclosed to public bodies or judicial authorities without them being considered Recipients (see art.4 number 9 of the Regulations) and, therefore, without them receiving instructions regarding the Processing they will have to perform. To obtain more information about the subjects to whom your Data may be disclosed, please contact us using the methods set out in the following document.
Data Retention Period and Security Measures
Without prejudice to any further specific information provided to you within this document with reference to each Processing, please note that, in accordance with this principle, we will process your Data only for as long as is necessary to pursue the Processing purposes listed in paragraph 5 of this document, subject to any period of time provided for by the relevant industry regulations. With respect to Processing activities that we perform on the basis of your consent, please note that you can always revoke such consent by requiring us, immediately, to cease the relevant Processing activities. For more information on revoking consent, please see the relevant section (Purposes of Processing) in this document.
Rights of the Data Subject
The subjects to whom the Personal Data refer have the right at any time to obtain confirmation of the existence or non-existence of the same at the Data Controller, to know their content and origin, to verify their accuracy or request their integration, cancellation, limitation, updating, rectification, transformation into anonymous form or blocking of Personal Data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, their Processing.The Request can be sent to firstname.lastname@example.org complete with a document identifying the requesting person.
Access to personal data
The data subject may request confirmation of the existence of data within Neodata’s systems with verification of the purposes for which he or she gave consent and also request whether such data has been shared with third parties if provided.
Modification of personal dataThe data subject may request the integration, modification of personal data.
The data subject may request his/her personal data, contained in Neodata’s systems, such as Personal Data as collected in Neodata’s own systems.
The data subject may request from Neodata that His or her data no longer be visible within its systems. This right may not be concurrent with deletion if there are constraints that oblige Neodata to retain the data. Neodata undertakes to process the User’s Request within 30 days of receipt of the Request.
Change of consent
Where the data is processed
Data subjects’ Personal Data will be processed by Neodata within the European Economic Area.
Last Updated: December 23, 2023