POLICY PURSUANT TO ARTICLES 14 AND 15
Consorzio Agribologna Società Cooperativa Agricola,
OF THE 2016/679 EU REGULATION
as Data controller of the processing of your personal data, provides the following policy, pursuant to articles 14 and 15 of the 2016/679 (EU) European Regulation (hereafter the "Regulation
”), governing the protection of individuals as regards the processing of personal data - to explain how we treat your data, which is provided during access, browsing and use of the website, or through the access and use of the Agribologna Group websites or portals, or as part of the use of the services provided by Agribologna and collected through paper forms or electronic formats, so that you can knowingly and freely express your consent to treatment.
It should be noted that the following policy is not provided for any other websites consulted by the user through hypertext links (links), which lead from the Data controller's website to other websites. Therefore, the existence of a link to another website does not imply approval or acceptance of responsibility by the Data controller for the contents of the website to which the User is referred to, also in relation to the policy adopted for the processing of personal data as well as to its use.
Data Controller and Data processors
The Data Controller of the processing of your personal data is Consorzio Agribologna Società Cooperativa Agricola,
with legal and operational headquarters in via Paolo Canali n. 16, CAP 40127,Bologna (BO), Italy (hereinafter “Agribologna
” or the “Data controller
The updated list of the people responsible of the processing of the data (Data processors) can be requested from the Data controller by sending an email to the following address: email@example.com
, or with a written request to the Data controller at the address of the same, as indicated above, or finally by paying a call at the following number 051-9941111.
Method of collection of personal data and type of personal data collected
The personal data that may be collected by the Data controller depends on the use that the User makes of the Agribologna website and of other services provided by Agribologna.
- The browsing data are acquired by the IT systems and the software procedures that regulate the functioning of the present website. This is information that is not collected to allow the subsequent identification of the user, but which is used for the sole purpose of obtaining anonymous statistical information on the use of the website and to check its correct functioning; this category of data includes the IP addresses or domain names of the computers used by the Users who connect to the website, the time of the request, the method used to submit the request to the server, the numerical code indicating the status of the response provided by the server (successful, error, etc.) and other parameters related to the operating system and browser used by the user.
These data could be used by the competent authorities to ascertain responsibility in the event of computer crimes against the website.
- The Data controller may also acquire the User's personal data through the website if the User:
· Intends to submit his/her curriculum vitae to Agribologna;
· Wishes to receive the Agribologna newsletter;
· Participates in a loyalty programme, a survey, a prize draw or registers to be informed about commercial and marketing initiatives or events organised by Agribologna or by other companies belonging to the Group;
· Participates in events organised by Agribologna to promote its image, the range of services and corporate and commercial values.
which also provides indications to disable them.
- The Data controller can also acquire User data, collected through paper forms, for example when he/she physically accesses the Data controller's premises and is invited to provide, for security reasons, his/her own identification data or electronic formats, in the context of the use of the services offered by Agribologna.
- The Data controller acquires some User data following a registration procedure that is activated by the User to access a particular section of the website and take advantage of the service offered here (for example to forward his/her curriculum vitae
) to the Data controller). For reasons of confidentiality and security, the User must start a registration procedure by creating his/her own access code (password), which will be essential, together with the user-id, to access the protected services. The User can change his/her password at any time by following the instructions provided by the system. In this case, the User is solely responsible for maintaining the secrecy and confidentiality of his/her user-id and/or password.
- Video surveillance
: the Data controller acquires User data also through the video surveillance equipment installed at the Data controller's premises if the User physically accesses these premises. Suitable notice boards warn Users in transit of the presence of cameras. The personal data collected and processed, through the video surveillance system, are the images of people and things that find themselves passing through the range of action of these systems. The system collects both long-range and close-up images of the accesses, transits and rooms inside the area and operates 24 hours a day. The cameras are positioned outside and inside the perimeter where the Agribologna headquarters are located to take video footage of the accesses, adjacent areas, internal areas, which are all duly indicated by appropriate signs. The images are recorded and stored temporarily, i.e. for 24 hours, after which they are deleted by overwriting the data (except for special needs related to holidays or the closure of offices or buildings or on a specific order of the judicial Authority or judicial police).
The types of personal data that the Data controller may collect for the purposes indicated above are the following:
- User information, such as name and surname, residential address, telephone number, place and date of birth, e-mail address, company for which he/she works, professional role and area/company field;
- Photographs and video footage taken during events organised by Agribologna or by accessing the headquarters of the Data controller where a video surveillance system is operative;
- Credentials, such as password, id or other info used for authentication and access to specific reserved areas of the website;
- Data deriving from cookies, web beacons and other similar technologies.
Purpose of the processing of the User's personal data
The Data controller may process the User's personal data, with his/her explicit consent, for the following purposes:
- For the search and selection of personnel to be hired at Agribologna or at subsidiaries or associated companies.
- For marketing purposes in order to:
o keep the User informed of initiatives and events organised for the promotion of specific new products and services by sending the Agribologna newsletter or by other forms of communication;
o invite the User to events, to prize competitions, to participate in a survey;
o send promotional and advertising material and/or commercial proposals;
o carry out market research and/or opinion polls, satisfaction survey (also carried out by external companies on behalf of Agribologna).
- For commercial profiling purposes, that is:
The Data controller may process your personal data to analyse or predict, through the use of algorithms and other automated systems, your tastes and habits and consumption choices, to offer you services and communicate events and sector information specifically tailored to your real interests and to be able to develop promotions and personalised commercial communications. The same commercial profiling treatment may also be carried out by third-party companies appointed by Agribologna for this purpose if you issue a specific and optional consent to the Data controller.
- To promote Agribologna's image and values through events reserved for members or open to third-party participation.
In addition, the Data controller may process the data for the pursuit of the protection purposes of Agribologna's people and property with respect to possible aggressions, thefts, robberies, damage and vandalism in the premises used for the activity of the Data controller, limited to the images collected through the video surveillance system installed in the premises where Agribologna is based or to the personal data that are requested from Agribologna visitors who access the Data controller's premises.
Subjects to whom the User's personal data may be communicated. Disclosure cases.
The Data controller can communicate the User's personal data to:
- Subsidiaries, affiliates of or partially owned by Agribologna, subsidiaries or associates in Italy.
- Companies belonging to the Agribologna distribution network, direct and indirect in Italy.
- Companies that perform information acquisition services for market surveys or opinion polls in Italy on behalf of Agribologna.
- Companies that provide Agribologna with services for the management of the Data controller's IT system based in Italy.
- Studies and companies in the context of professional assistance and consultancy relationships based in Italy.
- Companies that perform control, revision and certification of the activities put in place by Agribologna with headquarters in the Italian territory.
- Law enforcement agencies responsible for possible investigations and judicial measures.
More in general, the collected data may also be communicated to subjects to whom the right and interest to access the User's personal data is recognised by law or secondary and/or community regulations.
With some of the categories of subjects indicated above, the Data controller has entered into a contract with the third party that provides a service to Agribologna and has appointed it "Data processor" in accordance with the Regulation. If said subject processes the Users' data, said treatment can take place only limited to the type of service that is carried out by the same and in any case by complying with the obligations imposed by the Data controller on the Data processor in relation to the processing of personal data.
With explicit and informed consent, the photographs and video footage of third parties who participate in events organised by Agribologna and other Agribologna Group companies may be disseminated through the Agribologna or other Group companies website or social networks (such as example: Facebook, Linkedin, Twitter, Instagram).
Processing methods and data retention time
The treatment is carried out with the aid of electronic tools and, in some cases, of paper supports, according to principles of correctness, lawfulness, transparency, with logic strictly related to the purposes indicated above and suitable to safeguard the confidentiality of the data to be protected and rights of the Subject in compliance with the provisions of the current legislation. To protect data from, even accidental, destruction or loss and against unauthorised access or disclosure, technical and organisational security measures have been adopted.
Consequently, in the absence of specific rules that provide for different storage times, the Data controller will take care to use the data for the purposes indicated in this policy for a reasonable time with respect to the same purposes. In any case, the Data controller will take every care to avoid an indefinite use of the data.
In particular, the following time-scales related to the purposes of the processing are noted:
- personal data collected for the purpose of search and selection of personnel to be hired at Agribologna or at subsidiaries or associated companies of Agribologna after the selection process, subject to the data collection, has ended: 12 months
- data collected for marketing and commercial profiling purposes: 36 months
- data collected through the video surveillance system: 24 hours, without prejudice to a longer retention period for particular needs related to holidays or the closure of offices or buildings, or on the specific order of the judicial Authority or judicial police.
- data collected following physical access to the Data controller's premises: 6 months
- photographic or video footage: 3 years (or until the end of the promotional activity or communication campaign).
It is made, in any case, without prejudice to the right of the Subject to withdraw consent to the processing eventually issued at any time, with the warning that, in the event that personal data are processed for the execution of a contract or for the management of the social relationship, the withdrawal of consent makes it impossible for the Data controller to fulfill the obligations assumed towards the Subject.
Nature of consent and possible consequences of refusal
All personal data provided by the User, both while browsing the Agribologna website and through paper forms or electronic formats, are strictly functional to the IT management of the website and to the relationship of the User with Agribologna.
The registration procedure to access certain specific areas of the website is mandatory in order to exclude unauthorised accesses to the services offered. The provision of personal data voluntarily provided for the purpose of registration and access to some areas of the website is optional, but failure to collect it determines the impossibility of forwarding information or requests to the website.
The Consent for the treatment of the images collected during the events and for the processing of your personal data for marketing and profiling purposes is absolutely free and optional. If you choose not to give consent to the processing of your data for these purposes, this will not entail any consequence with respect to your right to browse the Agribologna website and to access certain reserved areas that do not pursue these purposes to which you will decide to register.
The Data controller has designated, as external Data processors, companies or entities that provide services that involve the processing of personal data on behalf of the Data controller. The updated list of the Data processors is available from the Data controller and can be requested from the same at the numbers or contact addresses indicated above.
In relation to the aforementioned processing of personal data, pursuant to articles 13, paragraph 2, letters (b) and (d), 15, 18, 19 and 21 of the Regulation, the User of this website - the Subject - has the right to:
a) ask the Data controller for access to personal data, rectification or cancellation of the same or limitation of the processing that concerns him/her;
b) propose complaints either to the Guarantor for the protection of personal data in Italy, following the procedures and indications published on the official website of the Authority at www.garanteprivacy.it., or to the Guarantor of the country in which he/she usually works, or, finally, to the Control authority of the country where the violation occurred;
c) object, in whole or in part and at any time:
· for legitimate reasons, to the processing of personal data concerning him/her, even if pertinent to the purpose of the collection;
· to the processing of personal data concerning him/her for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication.
The Subject also has the right to withdraw consent to the processing of data, at any time, without prejudice to the lawfulness of the treatment based on the consent given before the revocation.
Any corrections or cancellations or limitations of the processing carried out upon request of the Subject, unless this proves impossible or involves a disproportionate effort, will be communicated by the Data controller to each of the recipients to whom the personal data has been transmitted. The Data controller may communicate these recipients to the Subject if he/she requests it.
The exercise of rights is not subject to any form constraint and is free of charge.
Each Subject can contact the Data Protection Officer for the exercise of his/her rights by sending a communication to the following address firstname.lastname@example.org or with a written request to the Data controller at the office of the same, indicated above, or by paying a call to the following number 051-9941111.
The present policy will be subject to updates. Agribologna, therefore, invites Users to consult this page regularly.