PRIVACY POLICY STATEMENT

Dear User,

This Privacy Policy Statement isissued, in accordance with art. 13 of EuropeanRegulation 2016/679 on personal data protection and art. 13 of the Italian Data ProtectionLaw (Legislative Decree No 196/2003), bearing in mind Recommendation no. 2/2001 adopted on 17 May 2001, to users who access the website, and relates to all personal data which the Data Controller collects and conservesconcerningits users.

The information isprovidedsolely for the / website and not for anyother websites/and or apps the user mayvisit by means of links to external pages belonging to third parties.

DATA CONTROLLER:

The data controller is “Cangini Benne Srl”, with registered office at Via Savio, 29/31 47027 Sarsina (FC), VAT No.: IT02185060403 and the Internal Data Processor is Mr. Giorgio Cangini. The Company hasappointed a company Dpo.

Data will be stored in the databases of the Server Provider companies used by the Data Controller, at data centres locatedwithin the European Union.

Data are normallyprocessedat the Data Controller’sregistered office, by employees and/or externalassociatesdulydesignatedas data processors or persons in charge of processing.

DATA TRANSFER

If personal data are transferredoutside the European Union for technical operatingpurposes and to guarantee a high degree of continuity of service, the Data Controller ensuresthat the transfer isbased on an adequacydecision of the Commission, in order to ensurethat the level of protection of naturalpersonsguaranteed by the relevantlegislation, and especially by Regulation (EU) 2016/679, ismaintained.

You may contact the Data Controller, the Data Processor or the DPO at privacy@canginibenne.com.

DATA COLLECTED

The personal data collected and processed by the Data Controller via this website are of the following types.

The optional, intentional, voluntarysending of messages to the Data Controller’scontactaddressesimplies the acquisition of the sender’scontact data necessary to reply, and of all the personal data included in the communications. Moreover, specifically:

– by compiling the specificenquiryform in the Contactssection of the website, users maysend Cangini Benne an information request, directlysupplyingtheir data, including company name, website, town, province, contact’s name and surname, email address and telephone number. In the event of failure to contribute or incorrect or partialcontribution of the data, itmay be impossible for us to contactyou and/or for you to receive the information requested.

– moreover, via a special data collectionform on the /work for us/ page, users maysendtheirCVs in an unsolicited job application. The Data Controller will conserve the personal data received for 24 months, contacting the data subjectif a post compatible with the CV receivedbecomesavailable.

– by compiling the specific newsletter subscriptionform, users mayask to receivepromotional, informative and marketing communications from Cangini Benne, by supplyingtheir name, surname and email addressdirectly. These data are contributeddirectly by the data subject and in the event of failure to contribute or incorrect or partialcontribution of the data, itmay be impossible for the user to obtain commercial or informative news and communications from the Data Controller.

Throughyournavigation of the website / the Data Controller automaticallycollects data knownasnavigation data. Duringtheirnormaloperation, the IT systems and software procedureswhich operate this website acquire some personal data the transmission of whichisimplicit in the use of Internet communicationsprotocols. These data are notgathered for association with identifiedsubjects, but by theirvery nature, whenprocessed or associated with data held by third parties or the data controller, theymightallow users to be identified. Thiscategory of data includes the IP addresses or domain names of the computers used by users who log onto the website, the addresses in URI notation of the resourcesrequested, the time of the request, the methodusedwhensubmitting the request to the server, the numerical code indicating the server’sresponse status (concludedsuccessfully, error, etc.) and otherparametersrelating to the user’soperating system and IT environment. These data, necessary for the use of web services, are processed, also in aggregate form, in order to:

– obtainstatistical information concerning the use of the services (mostvisited pages, number of visitors by time band or per day, geographical area of origin, etc.);

– check that the services offered are operatingcorrectly.

Navigation data are notretained for more thanseven days and are erasedimmediately after theiraggregation (unlessrequired for the investigation of criminaloffences by the JudicialAuthorities).

RECIPIENTS

The personal data suppliedmay be disclosed to dulydesignatedrecipients, whowillprocess the data in the capacity of data processors and/or persons in charge of processing.

Specifically, personal data concerning the data subjectmay be disclosed to recipients in the following categories: competentauthorities for the fulfilment of legalobligations and/or the orders of public bodies, on request; Data Controller’semployees for dispatch of the communicationsrequested or for the assessment of CVssubmitted; companies whichrepair and/or maintain IT equipment; website management companies and, in general, to enable suppliers to perform technical, logistics and othertypes of activities on ourbehalf. Our suppliers onlyhave access to the personal data necessary for the performance of their tasks, and undertakenot to use the data for otherpurposes. They are alsoobliged to process the personal data in accordance with the relevantlegislation.

The Data Controller doesnotdiscloseany data concerning data subjects to third parties withouttheirconsent, unlessrequired by law. Under no circumstances are personal data disseminated.

The full list of the data processors, the joint data controllers and the persons in charge of the processing of personal data can be requested by sending an email to privacy@canginibenne.com

 PURPOSES OF THE PROCESSING

Data are onlyprocessed for the purposes for whichtheywerecollected, asdescribedbelow. The Data Controller processes the data contributed by data subjects for:

Fulfilment of obligations under laws, regulations and EU directives;

Management of the dispatching of information requestedusing the contactform. The legalbasis of the processing is the fulfilment of a contract to which the data subjectis a party, or the performance of pre-contractualmeasuresadopted on hisrequest. The contribution of your personal data for the abovepurposeis optional, butunlessthey are contributed management of the enquirywillnot be possible;

Statistical analyses/research on aggregated or anonymous data, meaningthat the user cannot be identified, intended to evaluate the Website’soperation, measuretraffic and assessusability and interest;

With the user’sspecificconsentonly, evenif he hascompiled the formspecificallyasking to subscribe to the newsletter, to enable the user to receiveadditionalspecific services, suchas the dispatch of future informative and promotionalcommunications via email or telephone. The legalbasis for the contribution of data for the purposes of sending newsletters for promotional, information or survey purposesistherefore the consentgiven by the data subject. Therefore, the data subjectisentitled to withdrawthisconsentatany moment, withoutprejudice to the lawfulness of the processing based on the consentprior to the withdrawal and withoutanyprejudicialconsequences of the withdrawal for the data subject.

DATA PROCESSING PROCEDURES

Personal data are processed by automated and manualmeans for the time strictlynecessary to achieve the purposes for whichtheywerecollected.

Assoonas the personal data are no longernecessary for the purposes for whichtheywerecollected, the Data Controller erasesthem, unlesstheirconservationiscompulsory by law, or the user hasconsented to their processing for a longerperiod of time.

In particular, the personal data collected are stored for a period of time established on the basis of criteriasuchas a) the creation of a subsequentcontractualrelationship; b) the user’s lasting interest in receivingpromotional and/or commercial offers, until the user asks to unsubscribe, c) CVssent to the Work for Ussectionwill be conserved for 24 months. In allothercases, the Data Controller stores the data for 12 months, unlesslegalobligationsrequiretheirconservation for longerperiods of time.

Specific security measures are implemented to prevent the loss of data, illegal or improper use, or unauthorised access.

RIGHTS OF THE DATA SUBJECT

Pursuant to articles 15 – 21 of Regulation (EU) 2016/679, every data subjectisgranted a series of rights.

Right to Access: pursuant to art. 15, the data subjecthas the right to confirmationthat personal data concerninghim are beingprocessed, and, wherethatis the case, to obtain a copy of the data. He isalsoentitled to obtain access to the personal data concerninghim and to additional information, suchas the purpose of the processing, the categories of recipients, the data storage period and the rights he isable to exercise.

Right to rectification: pursuant to art. 16, the data subjecthas the right to obtain the rectification of inaccurate personal data concerninghim or the completion of the data.

Right to erasure: the data subjecthas the right to obtain the erasure of personal data concerninghim, withoutundue delay, if one of the circumstanceslisted by art. 17 ismet.

Right to restriction of processing: pursuant to art. 18 of Regulation 2016/679, the data subjecthas the right to obtainrestriction of the processing.

Right to data portability: the data subjecthas the right to receive the personal data concerninghim in a structured, commonlyused and machine-readable format and has the right to transmitthose data to another controller withouthindrance, in accordance with the provisions of art. 20 of Regulation 2016/679;

Right to object to the processing: the data subjecthas the right to object to the processing of the personal data concerninghim in accordance with the provisionsif art. 21 of Regulation 2016/679.

The data subjectalsohas the right to lodge a complaint with the competent Supervisory Authority.

Requests to exercise the rights set out in the previous points must be addressed to the Data Controller in writing. The Data Controller willreply to requests to exercise the rights of data subjectswithoutundue delay, within the time limits set by the relevantlegislation.

Allrequests for explanations or clarificationsmay be addressed to the Data Controller in writing, alsousing the formprovidedat https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1089924

UPDATES AND AMENDMENTS

The Data Controller reserves the right to amend, supplement or update this Privacy Policy Statement at regular intervals in compliance with the relevantlegislation or with the measuresadopted by the Supervisory Authority for personal data protection.

Data subjectswill be informed of the saidamendments or supplements via email and via a link to the Privacy Policy page of this website.

In allcases, all data subjects are advised to view the Privacy Policy regularly, in order to examine the updated Statement.