With this document (the “Privacy Policy”), the Data Controller provides you with information concerning the data collected and the processing activities related to the company’s services carried out through the website www.advepa.it, in accordance with Regulation (EU) 2016/679 (GDPR), and in strict compliance with the general principles set forth in Articles 5 and 6 of the GDPR, namely in accordance with the principles of fairness, accuracy, completeness and relevance in relation to the purposes indicated.
The Data Controller is Advepa Communication S.r.l., which, in accordance with applicable laws, is the company responsible for managing the website (hereinafter, the “Company”), with registered office in Palermo, Via Marchese Ugo 52, 90141. The Company may be contacted through the CONTACT section or at the following email address: info@advepa.it.
This website primarily processes data on the basis of users’ consent. Consent is provided through the banner displayed at the bottom of the page, or through the use of or access to the website, which constitutes conclusive conduct. By using or accessing the website, visitors and users accept this Privacy Policy and consent to the processing of their personal data in accordance with the methods and for the purposes described below, including, where necessary for the provision of a service, disclosure to third parties. Additional consent relating to the specific purpose of the service may be collected through communication or service request forms.
The provision of data, and therefore consent to the collection and processing of data, is optional. The User may refuse to provide consent and may withdraw consent previously given at any time (through the banner at the bottom of the page, the browser’s cookie settings, or the Contact link). However, refusing consent may make it impossible to provide certain services and may adversely affect the browsing experience on the website.
Data processed for website security and the prevention of abuse and SPAM, as well as data used for traffic analysis (statistics) in aggregated form, are processed on the basis of the Data Controller’s legitimate interest in protecting the website and its users. In such cases, the User always has the right to object to the processing (User Rights).
Data provided for consultancy services or professional assignments are processed on the basis of the performance of a contract and compliance with a legal obligation. In such cases, a specific privacy notice will be provided.
The IT systems and software procedures responsible for the operation of this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected in order to be associated with identified data subjects but, by its very nature, could, through processing and association with data held by third parties, make it possible to identify users. This category includes IP addresses or domain names of the computers used by users connecting to the website, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the response provided by the server (successful, error, etc.), and other parameters relating to the user’s operating system and IT environment.
This data is used solely to obtain anonymous statistical information on website usage and to monitor its proper functioning, and is deleted after processing. The data may be used to establish liability in the event of alleged cybercrimes against the website. Except in such circumstances, data collected through the website is retained for 12 months.
With regard to IP addresses, please note that the Data Controller uses third-party analytics services (Google Analytics), which use website users’ IP addresses to provide data in reports and install cookies through the website, including profiling cookies. Please refer to the relevant information available on the website in the Cookie Policy section.
The optional, explicit and voluntary sending of emails to the addresses indicated on this website and the completion of the forms results in the subsequent acquisition of the sender’s email address, which is necessary to respond to requests, as well as any other personal data voluntarily provided to the Data Controller.
Unless you provide additional personal data for the management of your request, for the purposes indicated in this Privacy Policy, the Data Controller processes the following personal data:
personal identification data: first name, surname, address, telephone number, email address and other contact details;
data relating to the contract entered into with the Data Controller.
In order to manage your request, including the management of your application, the Data Controller may also process special categories of personal data, such as data revealing trade union membership (holding of positions or requests for deductions of membership fees), membership of political parties, religious beliefs (where you request to take part in certain religious holidays), as well as health data if voluntarily communicated by you to the Data Controller. For the processing of such categories of personal data, the Data Controller requires your explicit consent to the processing.
Specific summary notices will progressively be provided or displayed on the website pages prepared for particular services available upon request.
Through the website, the Data Controller will also process your personal data through the use of cookies.
For such processing activities, the Data Controller invites you to consult the Cookie Policy available at the relevant link.
The purposes for which the personal data of data subjects may be processed are related to commercial information activities expressly requested by users interested in the services offered by the Company through the contact form published on this website.
No marketing and/or profiling activities are carried out through this website.
In general, data processing is carried out for the purposes indicated from time to time, subject to your consent. Your personal data is processed:
without your express consent (Article 24(a), (b), (c) of the Italian Privacy Code and Article 6(b), (e) of the GDPR), for the following Service Purposes: entering into contracts for the services provided by the Data Controller;
to fulfil pre-contractual, contractual and tax obligations arising from existing relationships with you; to comply with obligations established by law, regulations, EU legislation or orders issued by the Authorities (such as, for example, anti-money laundering requirements); and to exercise the Data Controller’s rights, including the right of defence in legal proceedings;
only with your specific and separate consent (Articles 23 and 130 of the Italian Privacy Code and Article 7 of the GDPR), for the following Marketing Purposes: sending you by email, post and/or SMS and/or telephone contact newsletters, commercial communications and/or advertising material relating to products or services offered by the Data Controller, as well as surveys concerning your level of satisfaction with the quality of the services;
sending you by email, post and/or SMS and/or telephone communications of a commercial and/or promotional nature concerning third parties (for example, partners or other companies within the Group).
The processing of data collected through the website, in addition to purposes connected with, instrumental to and necessary for the provision of the service, is carried out for the following purposes:
Collection of data and information exclusively in aggregated and anonymous form in order to verify the proper functioning of the website. None of this information is associated with the individual User of the website and does not in any way allow their identification. Consent is not required.
Collection of data and information in order to protect the security of the website (anti-spam filters, firewall, virus detection) and Users and to prevent or detect fraud or abuse affecting the website. The data is recorded automatically and may potentially include personal data (IP address), which may be used, in accordance with applicable laws, to block attempts to damage the website or harm other users, or activities that are otherwise harmful or constitute offences. Such data is never used to identify or profile the User and is periodically deleted. Consent is not required.
Communication of data to third parties that perform functions necessary or instrumental to the operation of the service (e.g. comment boxes), and to allow third parties to perform technical, logistical and other activities on our behalf. Suppliers have access only to the personal data necessary to perform their duties and undertake not to use the data for other purposes. They are also required to process personal data in compliance with applicable legislation.
If you voluntarily provide data in order to request professional consultancy or a professional assignment, the data will be used solely for the purpose of assessing the assignment and, where applicable, carrying it out. In such cases, a specific privacy notice will be provided.
Through the “Work with Us” section of the website or by email, you may provide the Data Controller with your personal details and CV in order to apply for open positions or possible future positions. Your personal data is processed solely for the management of your application and related activities. The legal basis for processing your personal data for the purpose of managing your application is the need to fulfil your request, pursuant to Article 6(1)(b) of the GDPR. Consequently, your prior consent to the processing is not required.
For the purpose of assessing your application, the Data Controller may also process special categories of personal data included in your CV (for example, health data or philosophical or religious beliefs). The Data Controller requires your explicit consent for the processing of such special categories of personal data.
Your personal data may be processed by the Data Controller in order to fulfil requests made by writing to one of the email addresses available on the website or by completing the forms available on the website. Failure to provide the requested data will make it impossible for the Data Controller to fulfil your request. The legal basis for the processing is the need to fulfil your request, pursuant to Article 6(1)(b) of the GDPR. Therefore, your prior consent to the processing is not required.
In order to manage your request, the Data Controller may also process special categories of personal data transmitted by you to the Data Controller. For the processing of such special categories of personal data, the Data Controller requires your explicit consent on the “Contact” page.
If you wish to be updated on the latest news concerning the products and services offered by the Data Controller, you may join our marketing initiatives by consenting to receive newsletters and additional commercial communications concerning products and services. The legal basis for sending commercial communications and newsletters is your express consent, which the Data Controller requests on all website pages where it is possible to subscribe to this service, pursuant to Article 6(1)(a) of the GDPR.
Your personal data will be processed until you decide to withdraw your consent or object to the processing.
Please be informed that you have the right, at any time, to object to direct marketing activities by contacting the Data Controller using one of the contact details indicated in Section 1 of this Privacy Policy or by clicking on the appropriate link contained in each communication sent by the Data Controller.
Your personal data described in Sections 2.1–2.3 above will also be processed by the Data Controller in order to manage the website, carry out anonymous statistical analyses of website usage to verify its proper functioning and/or establish liability in the event of alleged cybercrimes against the website. In any event, such data is processed in anonymous form and deleted immediately after processing.
The legal basis for the processing is the Data Controller’s legitimate interest in ensuring the proper use of the website and preventing any possible cybercrime, pursuant to Article 6(1)(f) of the GDPR. Therefore, your consent is not required. Your personal data will be anonymised immediately and in any event deleted at the end of your browsing session. However, if offences are established, your personal data will be retained for the time necessary to manage the dispute.
Data provided by the data subject through the contact form will not be transferred to third-party companies for commercial purposes or for any other purposes. Instead, it will be communicated to the relevant commercial and administrative personnel within the Company in order to fulfil the activities indicated in Section 3 (Purposes).
Data collected through the website is generally not provided to third parties, except in specific cases: where legitimately requested by judicial authorities and only in cases provided for by law; where necessary for the provision of a specific service requested by the User; or for the performance of security checks or website optimisation activities.
This website may share some of the data collected with services located outside the European Union. In particular, with Google, Facebook and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorised on the basis of specific decisions of the European Union and the Data Protection Authority, in particular Decision 1250/2016 (Privacy Shield – information page of the Italian Data Protection Authority), and therefore no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.
Your data may be processed electronically. The data for which Advepa Communication S.r.l. is the Data Controller is limited to that necessary for processing related to the services provided through the website. The Data Controller uses servers located within the European territory. We inform you that the data will be collected, processed and stored in full compliance with the applicable security requirements and with the measures deemed appropriate pursuant to the new EU Regulation 2016/679. The data will also be processed in full compliance with the self-regulatory rules concerning the processing of personal data contained in the applicable professional codes of conduct.
We process visitors’/users’ data lawfully and fairly, adopting appropriate security measures designed to prevent unauthorised access to, disclosure, alteration or destruction of data. We undertake to protect the security of your personal data during transmission by using Secure Sockets Layer (SSL) software, which encrypts information in transit. Processing is carried out using IT and/or telematic tools, with organisational procedures and logic strictly related to the purposes indicated. In addition to the Data Controller, in certain cases, data may be accessed by personnel involved in the organisation of the website or by external parties (such as third-party technical service providers and hosting providers).
Data will be processed for the period strictly necessary to achieve the purposes for which it was collected. It will also remain available to the Data Controller, Data Processor and authorised personnel where retention is required by law (Article 22, paragraph 5, of the Italian Privacy Code), only for the period necessary or until a different date is requested by the User for its deletion. In any event, the maximum retention period is that established by law for contractual liability, namely 10 years.
In relation to the processing activities described in this Privacy Policy, you may exercise the rights provided for under Articles 15 to 21 of the GDPR, in particular:
right of access – the right to obtain confirmation as to whether or not personal data concerning you is being processed and, where this is the case, to obtain access to your personal data, including a copy thereof;
right to rectification – where applicable, the right to obtain, without undue delay, the rectification of inaccurate personal data concerning you and/or the completion of incomplete personal data;
right to erasure (right to be forgotten) – where applicable, the right to obtain, without undue delay, the erasure of personal data concerning you;
right to restriction of processing – where applicable, the right to obtain restriction of processing where the conditions established by law are met;
right to data portability – where applicable, the right to receive, in a structured, commonly used and machine-readable format, the personal data concerning you that you have provided to the Data Controller and the right to transmit such data to another controller;
right to object – the right to object at any time to the processing of personal data concerning you where the legal basis for the processing is the legitimate interest;
right to withdraw consent – the right to withdraw consent at any time, with the same ease with which it was provided, without affecting the lawfulness of processing based on consent given prior to its withdrawal.
The data subject also has the right to lodge a complaint with the Italian Data Protection Authority ([www.garanteprivacy.it]).
The exercise of these rights is not subject to any formal requirement and is free of charge pursuant to Article 12 of the GDPR. However, in the event of requests that are manifestly unfounded or excessive, including due to their repetitive nature, the Data Controller may charge a reasonable fee in light of the administrative costs incurred in handling the request, or refuse to comply with the request.
To exercise your rights, you must complete the data subject rights exercise form available on the website of the Italian Data Protection Authority or downloadable through the relevant link, and send it to Advepa Communication S.r.l. using one of the following methods:
Registered letter with acknowledgement of receipt (A.R.) addressed to the Advepa Communication S.r.l. office, Palermo, Via Marchese Ugo 52, 90141;
Certified email (PEC): advepa@certificazioneposta.it
Any rectification, erasure or restriction of processing carried out at your request will, unless this proves impossible or involves disproportionate effort, be communicated by the Company to each recipient to whom the personal data has been disclosed.
