This privacy policy describes the processing of personal data concerning users and visitors (collectively, the “Users”) with the Crealis Group website (www.crealisgroup.com: the “Website”).
Crealis S.p.A. may modify this privacy statement in accordance with future improvements or modifications of the Website or the provided services. In case of substantial changes, Crealis S.p.A. will publish a notice on the Website to draw the Users’ attention to the changes and collect, if necessary, any request to exercise the rights recognized by the applicable laws on the protection of personal data.
1. DATA CONTROLLER
The data controller is Crealis S.p.A., with registered office in Bodio Lomnago (Varese), Via Galvani n.1 – 21020, C.F. and VAT number 13400560150 (hereinafter “Crealis” or the “Data Controller”).
2. COLLECTED DATA
2.1 Personal data provided by Users
Personal data collected through the Website are provided by the Users by filling-in the forms made available on the Website (the “Forms”), in particular:
“Contact Us” Section
In the section “Contact us” or by sending Crealis a request to the addressed indicated on the Website, the User will provide his personal identification and contact data (e.g. name and surname, e-mail address, the telephone number, the country and, optionally, the professional profile), the data included in the communications and requests sent to Crealis, as well as all the further data necessary to reply and follow up on Users’ requests.
“Join Us” Section
By submitting your application and filling in the data collection form in the “Join Us” section, you will provide your personal, identification and contact data (such as your name and surname, e-mail address, telephone number, the country and, optionally, the sector/specialization) and any additional information contained within the resume submitted.
“Newsletter” Section
By submitting the request to subscribe to the Crealis’s newsletter you will provide your email address.
Users are invited to provide Crealis with up to date and relevant data, limited to what is necessary in relation to the purposes for which they are processed.
At any time, it is possible to unsubscribe from the newsletter service by selecting the unsubscribe button available in each e-mail sent.
2.2 Web browsing information data
Each time the Users access the Website, the systems automatically register and analyze the usage data for the understanding and optimizing of the Website, such us:
- the cookies;
- the provider’s IP address;
- the User ID;
- the custom dimensions and variables;
- the Order ID;
- the location of the User; and
- other information on the used browser, such as the pages visited, date, time and duration of each visit, the URL of the page, the screen resolution, the time in local timezone, the files that were clicked and downloaded, the link clicks to an outside domain, the main language of the browser and the user agent of the browser
(hereinafter the “Navigation Data”).
These information are automatically collected by the Website in an anonymous and aggregated way, through the web analytics platform “Matomo” – provided by InnoCraft Ltd (more information available at the following link) – and does not require any action by Users.
3. PURPOSE OF THE PROCESSING
Users’ personal data (the “Data”) shall be processed for the following purposes.
3.1 Follow up Users’ requests
The Data shall be processed to respond and follow up on the requests that Users may send to Crealis through the different form in the various section of the Website such as the “Contact Us” and “Join us” Forms or through the contact details available on the Website.
The legal basis for this processing is the legitimate interest of the Data Controller in pursuing its business activities to follow up on the Users’ requests.
This legitimate interest has been duly balanced against the reasonable expectations of the data subjects and, as it does not affect the rights of the data subjects involved and since the processing of the Data is carried out following the User’s own request, it has been deemed to prevail.
The provision of the Data for the above-mentioned purposes is necessary for the correct management and execution of the User’s requests. Any partial or total refusal to provide the Data for such purposes will make it impossible for the Data Controller to fulfil such requests.
3.2 Sending the newsletter of Crealis
The Data will be processed in order to keep Users constantly updated on the activities, services, products and promotions of Crealis by sending the newsletter containing communications and information materials.
The provision of Data for such purposes is based on your explicit and prior consent: any refusal, or subsequent opposition, will make it impossible for the Data Controller to send you the newsletter and updates on its activities.
You may revoke your consent at any time by following the procedure indicated in each e-mail or by sending a specific request to be transmitted to the addresses indicated in the following article 7. Any withdrawal of consent shall not affect the lawfulness of the processing based on the consent given before the withdrawal.
3.3 Analysis of the Navigation Data and optimizing of the Website
The Navigation Data will be analyzed and processed for the purposes of understanding and optimizing the Website, improving the user experience and helping the Users to find the information they are looking for.
The legal basis for this processing is the legitimate interest of the Data Controller in pursuing its business activities to improve and optimizing the Website and the experience of the Users.
This legitimate interest has been duly balanced against the reasonable expectations of the data subjects and, as it does not affect the rights of the data subjects involved and since the processing of the Navigation Data is carried out in order to improve the Website and the User’s web experience, it has been deemed to prevail.
In any case you can opt-out of the processing of your Navigation Data through Matomo by clicking the following box “You are not opted out. Uncheck this box to opt-out”.There will be no consequences regarding the use of the Website.
3.4 Exercise the rights of Crealis (judicial protection)
The Data will be processed to exercise the rights of the Data Controller, such as the right to defence in court, on the basis of the legitimate interest of the Data Controller. This legitimate interest is to be considered prevailing since it corresponds to a constitutionally guaranteed right and, as such, is socially recognised as prevailing over the interests of the individual concerned.
The provision of the Data for this purpose is necessary to enable the Data Controller to defend itself in legal proceedings.
4. MODALITIES OF PROCESSING AND RECIPIENTS OF DATA
The Data shall be processed by means of manual and digital tools and will be communicated and may be known (i) by employees and collaborators of the Data Controller, duly instructed and designated to the processing to which Crealis has given detailed instructions, with specific regard to the implementation of appropriate technical and organizational security measures; (ii) by third parties who provide accessory or instrumental services to the activities of the Data Controller, in relation, for example, to the development, provision and operational maintenance of the Website; and (iii) external subjects operating as autonomous data controller such as, by way of example, Authorities and supervisory and control bodies and, in general, to subjects, including private subjects, entitled to request the data (such as, for example, accounting consultants, legal consultants), Public Authorities who make an express request for administrative or institutional purposes, in accordance with the provisions of current national and European legislation.
The complete list of the recipients of Data is available upon request, to be sent to the addresses set out in following point 7.
5. PERIOD OF STORAGE
The Data collected and processed by Crealis, for the purpose set out in point 3 above, may be stored and processed in a form that allows the identification of the User for the period necessary to achieve the purposes of processing and, in particular:
- in the case of filling in the Forms made available on the Website for a period of 13 months from the last contact made and, in any case, where applicable, for the entire duration of the contractual relationship with the Data Controller, as well as for the time necessary to (i) fulfil statutory and/or legal obligations and (ii) ensure the judicial protection of the Data Controller’s rights, in accordance with the relevant limitation periods;
- in the case of the analysis of the Navigation Data through Matomo, for a period of 12 months from the collection;
- in the case of your subscription to the newsletter service, on the basis of your optional and revocable at any time consent, will be stored for a maximum of 24 months after the provision of the relevant consent;
- for the judicial protection of the Data Controller, and specifically in the case of legal disputes, they will be kept for the duration of such disputes, until the deadlines for appeals will be reached.
6. PLACE OF PROCESSING AND TRANSFER OF DATA
The Data collected on the Website will not be transferred outside the European Union.
7. USER’S RIGHTS AND CONTACT DETAILS
Users, as data subjects (i.e., subjects to whom the Data refer), are holders of rights conferred by the GDPR. In particular, pursuant to Articles 15-22 of the GDPR, data subjects have the right to request and obtain, at any time, access to their personal data, information on the processing carried out, rectification and/or updating of personal data, erasure and restriction of processing. They also have the right to object to the processing and to request data portability (i.e. to receive their personal data in a structured, commonly used, machine-readable format). Finally, data subjects always have the right to withdraw their consent at any time (this, in any case, will not affect the lawfulness of the processing carried out on the basis of the consent given before the revocation) and to lodge a complaint with a supervisory authority (in Italy: the Garante per la Protezione dei Dati Personali).
The requests concerning the exercise of the above rights shall be sent to the following addresses:
- By mail, to: contact@crealisgroup.com
- By registered letter, to: Crealis S.p.A. Via Galvani n. 1 – 21020 Bodio Lomnago – Italy
To the same addresses above, the Users shall send also the requests concerning the recipients of Data, as well as the clarifications’ requests regarding this privacy policy.
8. LINKS TO OTHER WEBSITES
This privacy policy regarding the processing of personal data concerns only Data collected through the Website and with reference to purposes identified in paragraph 3., and it is not and shall not be deemed applicable to other websites consulted and/or that can be consulted through links and/or widgets (e.g. social networks): these further websites will process the Data as independent data controllers and according to their respective privacy information, whose consultation by the Users is expressly recommended.