Personal Data Policy

PRIVACY POLICY

Subject to EU Reg. 2016/679 (European Regulation for personal data protection – GDPR), this privacy policy provides information on the processing of the personal data submitted by the data subjects.

The notice does not apply to any other WEBSITES which can be accessed through links found on the websites belonging to the domain of the Controller, that cannot be held responsible for third-party websites.

It is a notice provided pursuant to article 13 of EU Reg. 2016/679, as well as to the provisions contained in the Directive 2002/58/EC, as updated by the Directive 2009/136/EC on Cookies and to the Provision of the Italian Data Protection Authority (Garante)on personal data protection and cookies

personal data: any information that directly or indirectly identifies a natural person, or causes them to be identifiable, and that can provide information about their characteristics, habits, lifestyle, personal relations, health, financial standing, etc.. (article 4. para. 1, no. 1 GDPR).

Data subject: the natural person the personal data refer to (article 4. para. 1, no. 1 GDPR). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data” (article 4. para. 1, no. 7 GDPR).

Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller (article 4. para. 1, no. 8 GDPR).

Data Controller

The Data Controller, pursuant to articles 4 and 24 of EU Reg. 2016/679, is FRIEM S.p.A., headquartered in via Edison 1, 20090 Segrate, Tax Number and VAT Code 00770590156. The Controller can be contacted as follows:

by ordinary mail addressed to: via Edison 1, 20090 Segrate;
at the email address: privacy@friem.com.

Processed data types

Navigation data

The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data, whose transmission is implicit in the use of Internet communication protocols.

This category of data includes the IP addresses or the domain names of the computers or terminals used by the users, the addresses in URI (Uniform Resource Identifier/Locator) format of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the operating system and the computer environment of the user.

Data provided by the data subject

The optional, explicit and voluntary sending of messages to the Friem contact addresses, as well as the compilation and submission of the Contact Forms found on the Friem website, implies the acquisition of the Data Subject contact data required to reply, as well as of all the personal data included in the communications.

Cookies

For further information about the cookies used by this website, please refer to the cookie policy at the following link.

Purposes of the processing, legal grounds, data retention period

Processing of website browsing data

Friem uses website browsing data for activities that are strictly necessary for the site operation, for the provision of the platform browsing service, as well as for the monitoring and prevention of frauds and cyber attacks/for IT security purposes.

The legal grounds of this processing are the legitimate interests – article 6 letter f), and considering 47: the processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, taking into account the reasonable expectations of the data subject in the light of his relationship with the Controller.

Data is retained for 6 months from the date of its collection.

Filling in of any contact data collection form

Friem used data provided by the Data Subject in the “Contacts” form, with his prior express consent, to contact the user for the provision of goods or services.

The legal ground of this processing is the consent expressed by the Data Subject (article 6.1.a of the Regulation).

Friem shall only process the Data Subject data within the limits of the mandatory retention obligations provided for by the law.

Data processing by Friem for generic marketing purposes

If the Data Subject fills in the dedicated data collection form, with the prior express consent of the Data Subject, Friem shall process their personal data to send them information and promotional notices on the goods and/or services it provides, by email, messages (SMS or other), the postal service and/or phone contacts.

The legal ground of this processing is the consent expressed by the Data Subject (article 6.1.a of the Regulation).

The Data Subject can revoke his consent at any time, and/or object to the processing of his data for marketing purposes:

By contacting Friem: privacy@friem.com
through the relevant link included in any promotional notice sent by Friem.

The provision of the data for generic marketing purposes is optional: the Data Subject has no legal or contractual obligation to provide the data in question for this purpose, and/or to give his consent to the processing of his personal data for that purpose.

For the generic marketing purposes, Friem shall retain the Data Subject data until his consent is withdrawn and/or the right to object is exercised, and in any case, for no more than five years from the data collection, reserving the right, before the term in question expires, to request that the Data Subject again give his consent and/or update his data.

Processing of the email address by Friem for soft-spam purposes

Friem shall retain the email coordinates (i.e., the email address) provided by the data subject within the context of the sale of a product/service or of an event, to send promotional notices regarding the goods and/or services it provides. The notices in question shall be sent by Friem by mail, without requiring the express and prior consent of the data subject, as provided for by article 130, paragraph IV of the Privacy Code, unless the Data Subject exercises the right to object as specified below (the so-called soft-spam).

The legal ground of this processing is article 130, paragraph IV, of the Privacy Code, that expressly permits the processing in question.

The Data Subject can object to the reception of soft-spam notices:

by contacting Friem at the following address: privacy@friem.com
through the relevant link included in any promotional notice sent by Friem.

For the soft-spam purposes, Friem shall process the Data Subject data until the right to object is exercised.

Processing of the data provided by the applicant

Friem shall process the data provided by the data subject in the “Work with us” form and contained in the attached Curriculum, including identification data, contact data and information on prior work experiences for purposes related to the staff selection process.

The legal grounds of this processing are the consent expressed by the Data Subject (article 6.1.a of the Regulation) and the legitimate interests – article 6 letter f) and considering 47.

The Data Subject can withdraw his consent at any time, and/or object to the processing of his data:

By contacting Friem: privacy@friem.com
through the relevant link included in any promotional notice sent by Friem.

The personal data provided by the data subject shall be processed through IT and manual electronic tools, and shall be retained by Friem to the extent required for the fulfilment of the obligations and for the time strictly necessary to achieve the purposes for which it has been collected, in compliance with the General Data Protection Regulation. Should Friem no longer need to use the personal data of the applicant, it shall delete the data in question from its systems and records and shall take action to properly anonymise the data, to ensure that the applicant can no longer be identified through it.

The personal data may be retained for up to one year from the date of reception of the Curriculum through the Friem website, unless the data subject is hired and/or requests the data to be erased.

Disclosure of the collected personal data

The provided personal data shall be shared with persons that shall process the data in their capacity of Processors (article 28 of EU Reg. 2016/679) and/or in their capacity of natural persons acting under the authority of the Controller and of the Processor (article 29 of EU Reg. 2016/679), for the above-listed purposes.

More precisely, the data shall be shared with:

providers of services for the management of the information system used by Friem and of the telecommunication networks, including email, newsletters and websites; freelancers, firms or companies providing support and consultancy services;
competent authorities, for the fulfilment of legal requirements and/or of public body provisions, on requisition;

The list of the Data Processors is constantly updated and can be obtained by writing to privacy@friem.com or by visiting the registered office of Friem S.p.A.

Transfer of the data from extra-EEA countries

The personal data provided shall not be transferred to countries outside the EEA.

Rights of the data subject

The Data Subject can assert the rights provided for by articles 15, 16, 17, 18, 19, 20, 21 of EU Regulation 2016/679, by contacting the Data Controller at the address privacy@friem.com .

The data subject has the right, at any time, to request from the controller access to and rectification or erasure of his personal data, restriction of processing and data portability, if desired. He also has the right, at any time, to object to the processing of personal data based on consent and/or legitimate interests.

In order to stop receiving generic marketing notices and soft-spam (email, SMS) he will just have to send an email message, at any time, to privacy@friem.com with the subject “richiesta cancellazione”, or to use our automatic unsubscribing systems, available for email messages only (opt-out right).

Without prejudice to any other administrative and legal recourse, if the Data Subject believes that the treatment of any personal data breaches the provisions contained in EU Reg. 2016/679, pursuant to article 15 subparagraph f) of the above-mentioned EU Reg. 2016/679, he has the right to lodge a complaint with the Italian Data Protection Authority (Garante, Supervisory Authority www.garanteprivacy.it).

Response time and procedures, in case the data subject should exercise any of his rights

The Data Controller provides the data subject with information about the actions undertaken with reference with a request to exercise any of the rights granted by articles 15 to 22 of the Regulation (i.e., right of access, right to rectification, right to erasure, right of processing restriction, right to data portability, right to object) and provided for by sections 18, 19, 20, 21, 22 and 23 of this notice (“Rights of the data subject“), without any undue delay and anyway within a month of receiving the request. If the Data Subject sends the request by electronic means, the information is provided, where possible, by electronic means, unless otherwise specified by the data subject.

Further information

The Data Controller reserves the right to change, update, add or remove any parts of this privacy notice, at its own discretion and at any time. For easier checking, the notice shall specify the update date.

January 2022