Privacy Policy

Privacy Notice for Clients and Suppliers and for their respective contacts pursuant to Articles 13/14 and Article 21 of the General Data Protection Regulation (GDPR) of INKOUT UNIPERSONALE SRL (hereinafter referred to as “INKOUT UNIPERSONALE SRL” or “we”)

Who is the Data Controller? Who can I contact?

Name and address of the Data Controller:

INKOUT UNIPERSONALE SRL, VIA DEL MANZASCO 4R

E-mail: amministrazione@inkout.it

Website: www.aidi-polimi.com

Which categories of data are processed by INKOUT UNIPERSONALE SRL and for what purposes?

We process the following categories of data relating to clients and suppliers: company name, legal form, registered office, legal representatives and contact persons (first name, last name, e-mail address and telephone/fax numbers) and billing data.

Such data are stored and processed where necessary:

for the preparation and execution of a contract (including the management of the customer relationship);

for billing purposes;

for marketing purposes, promotional, commercial and advertising activities, such as, for example, the sending of materials and advertising communications related to the products and/or services marketed by INKOUT UNIPERSONALE SRL, the sending of promotional e-mails and SMS messages and the sending of newsletters and e-books, provided that no objection has been raised to the use of the data for commercial purposes.

On what legal basis do we process data?

The legal basis for the processing of personal data is the General Data Protection Regulation (GDPR) and in particular:

Article 6(1)(b) GDPR, which allows processing for the purposes of entering into and performing contracts;

Article 6(1)(f) GDPR, which allows processing for the protection of our legitimate interests, provided that there is no overriding interest of the data subject that prevents such processing.

In addition, we process personal data on the basis of the consent given by the data subjects. Data subjects may withdraw their consent at any time. Such action shall not have retroactive effect. However, the withdrawal of consent will prevent the further processing of the data subject’s personal data by us. The other provisions allowing data processing (Article 6(1)(b) and Article 6(1)(f) GDPR) shall remain unaffected.

With whom do we share the data provided? Where are personal data stored?

We share personally identifiable information with recipients within the INKOUT UNIPERSONALE SRL group who need to know such information in the performance of their functions and obligations, and with third parties appointed to process data on our behalf, as service providers, who are in turn bound by the contracts required by law on data protection matters, or to whom INKOUT UNIPERSONALE SRL must provide information in order to comply with its legal obligations. We also share personally identifiable information with INKOUT UNIPERSONALE SRL business partners who provide products and services sold by INKOUT UNIPERSONALE SRL.

Personal data are stored on INKOUT UNIPERSONALE SRL servers within the European Union.

Are data transferred to recipients outside the European Union or the European Economic Area (so-called third countries) or to international organizations?

Personal data of clients/suppliers will be transferred to third countries only if necessary for the performance of the contract.

How long are the data provided to INKOUT UNIPERSONALE SRL stored?

We retain personal data only for the time necessary to achieve the purposes described above, after which they are deleted; in any case, they will be deleted in accordance with the retention periods provided for by law.

What are the rights of the Data Subject? Where can a complaint be lodged?

Article 15 GDPR provides the right to be informed about the data concerning the data subject that we hold.

In the presence of inaccurate or outdated information, the data subject has the right to request correction at any time pursuant to Article 16 GDPR.

Furthermore, pursuant to Article 17 GDPR, the data subject may have the right to request the erasure of personal data, in the absence of overriding powers or rights on our part to continue processing.

Finally, pursuant to Article 18 GDPR, the data subject has the right to restrict/limit the processing of personal data.

To obtain information regarding the data we hold, for correction, erasure or restriction/limitation of processing, please contact the address indicated in Section 1.

It is possible to request the transmission of the information provided to us in a structured, commonly used and machine-readable format, or the transmission of such information to third parties.

Furthermore, the data subject has the right to object to processing pursuant to Article 21 GDPR. Please refer to the information notice below.

To contact the competent supervisory authority,

The Italian Data Protection Authority (Garante per la protezione dei dati personali), write to:

Garante Privacy
Piazza di Monte Citorio n. 121
00186 ROME

Tel.: (+39) 06.696771
Email: garante@gpdp.it

Is the provision or updating of data mandatory?

Providing personal data is a free choice. However, we are authorized to process the personal data of subjects with whom we maintain contractual or pre-contractual relationships, for the preparation and execution of contracts and for billing purposes.

Are the personal data provided used for automated decision-making processes?

In principle, we do not use client/supplier data for automated decision-making processes as described in Article 22 GDPR.

Are data used for profiling/scoring?

No.

Right to object pursuant to Article 21 GDPR

Right to object based on a particular situation:

Pursuant to Article 21(1) GDPR, the data subject has the right to object to the processing of his or her personal data at any time on grounds relating to his or her particular situation. In the event of objection, we will cease processing personal data unless we can demonstrate compelling legitimate grounds for the processing that override the interests of the data subject (e.g. to assert our rights or defend ourselves in legal proceedings).

Right to object to processing for commercial purposes:

Pursuant to Article 21(2) GDPR, the data subject also has the right to object to processing for direct marketing purposes. In such case, we will cease using the personal information received for promotional purposes.

An objection may be sent in any form to the contact details indicated in Section 1.

Privacy Notice – Online Privacy

The protection of personal information is of primary importance to us. We will use the identifying data that the user chooses to provide to us, or that are collected during the use of the website, only as described in this Online Privacy Notice and in accordance with the applicable data protection regulations.

This Online Privacy Notice specifies the type, purpose and scope of the collection, processing and use of personal information that the user chooses to provide during browsing and/or that may be transmitted through the INKOUT UNIPERSONALE SRL website (www.aidi-polimi.com
) (hereinafter “our website”). Please note that no personal information is required in order to use our website.

Users who provide personal information for collection, storage or use by INKOUT UNIPERSONALE SRL have the right to be informed about the methods of storage, use and transfer of such information and have the right to access the information and to control its use, pursuant to Legislative Decree No. 196 of 30 June 2003 (Personal Data Protection Code) and (as of 25 May 2018) the GDPR (General Data Protection Regulation), hereinafter “the Law”. The term Personal Data means any information relating to an identifiable person, even indirectly, by reference to any other information, including a personal identification number, such as name, e-mail address, telephone number and similar. For further information on the right of access, rectification and erasure of any personal data held by us, on the exercise of such rights and for our contact details, please consult Section 6 and Section 7.

As provided for by the Law, the Data Controller is the legal representative of INKOUT UNIPERSONALE SRL, VIA DEL MANZASCO 4R (hereinafter “INKOUT UNIPERSONALE SRL”). For further information about INKOUT UNIPERSONALE SRL, please consult Section 7.

The competent data protection authority is the Italian Data Protection Authority (Garante per la protezione dei dati personali) www.garanteprivacy.it
. If the user considers that the processing of data carried out by us does not comply with this Online Privacy Notice or with applicable laws and regulations, he or she may lodge a complaint with the Italian Data Protection Authority. For completeness, in certain circumstances, as provided for by Article 157 of Legislative Decree No. 196/2003 (not subject to the ordinary management of the website), INKOUT UNIPERSONALE SRL must transmit information and updates to the competent authorities for the verification of the processing of personal data. In such cases, the response is mandatory, under penalty of administrative sanctions.

Section 1
Information collected during the use of our website and use of such information
a) Contact forms

Our website offers the possibility to provide us with personal information by filling in a contact form, for example to request a quotation or information relating to our products, or to express interest in a job offer at INKOUT UNIPERSONALE SRL. The information provided may include name, address, e-mail address and telephone number, age and date of birth.

We use the information in order to:

provide the user with the requested information, products and services;

personalize the user’s experience on our website and ensure that the website is displayed in the best way for the user and for the device used.

Data transmitted via the internet (e.g. via e-mail transmission) are subject to security risks. It is therefore not possible to guarantee complete protection against access by third parties to transmitted data.

b) Log information

During browsing, standard log information and details of user behavior patterns are collected, such as:

date and time of visit; browser type and version; operating system; Internet Protocol (IP) address; full clickstream and related URLs to and from our website, such as websites visited and products viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse movements) and methods used to leave the page; plug-in types and versions for system administration.

We have a legitimate interest in processing these data in anonymous form as they allow us to improve and develop our website. We are in no way interested in identifying users who visit our website. The data thus collected will not be associated in any way with any identifying information relating to the user from any other source.

c) Newsletter and commercial offers

Our website offers the user the possibility to download and/or register to receive commercial offers sent by us or our newsletter (hereinafter “newsletter”). To subscribe, the user must enter a valid e-mail address. At the time of registration for commercial offers or the newsletter, the IP address, date and time will be stored in our archives. This is necessary to protect us in the event that a third party improperly and without consent uses the user’s e-mail address to register for our commercial offers/newsletter. No other data will be collected. The data thus collected are used solely for the purpose of sending commercial offers or newsletters. The data are not transferred to third parties and are not combined in any way with any information that may be collected on our website. In the event of downloading commercial offers or newsletters, we use the tracking system offered by Google Analytics (see below). You may cancel your registration for commercial offers/newsletters at any time. Further details are contained in the confirmation e-mail and in each commercial offer/newsletter.

For e-mail communications, we use services and software offered by third parties and we track user activities in order to ensure that the content sent is targeted and to improve the user experience.

e) Cookies

Our website uses Cookies, Pixel Tags, Local Shared Objects (also known as “Flash Cookies”) and similar technologies during browsing to enable certain specific functionalities of our website and to facilitate the analysis of user behavior on the website in order to improve the user experience.

For further information on the cookies used and their operation, please visit our cookie policy.

To prevent the installation of cookies, adjust your browser settings accordingly. However, this may prevent the user from fully using all website functions.

f) Use of Google Analytics IP anonymization function

Our website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (hereinafter “Google”). Google Analytics uses so-called “cookies”, text files stored on the user’s computer, to help analyze how users use the website. The information generated by these cookies, such as time, place and frequency of visits to our website, including IP addresses, are transmitted to Google in the United States for storage.

Google states that the IP addresses transmitted by the user’s browser will never be associated with other data held by Google.

On our website we use Google Analytics with IP anonymization enabled. For this purpose, Google shortens and thus anonymizes IP addresses before transmission from EU Member States or from States party to the Agreement on the European Economic Area.

Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on website activity for us and to provide other services related to website and internet usage. This information is used by us for statistical purposes. Google may also transfer this information to third parties where required by law or where such data are processed by third parties on behalf of Google.

We use Google Analytics including the Universal Analytics function. Universal Analytics allows us to analyze website activities across devices (e.g. if a user accesses our website via a laptop and later via a tablet). The process consists of assigning a pseudonymous user ID to each user. This assignment takes place at the time of registration or login with a username and password. Google does not receive any personal information. The addition of further features to Google Analytics through Universal Analytics does not reduce or invalidate the security measures adopted to protect personal data, such as IP masking or additional browser add-ons.

The user may prevent the installation of cookies by adjusting browser settings accordingly. However, this may prevent full use of all website functions.

Google offers a deactivation function for the most common browsers, giving users greater control over the data collected and processed by Google. By activating this option, no information relating to visits to our website will be transmitted to Google Analytics. However, activation will not prevent the transmission of information to us or to our web analytics service providers. Further information on the deactivation option provided by Google and how to activate it can be found at https://tools.google.com/dlpage/gaoptout

Marketing services may be disabled at the following link: https://support.google.com/ads/answer/2662922?hl=it&ref_topic=7048998

For further information on Google’s terms of use and data protection, please visit http://www.google.com/analytics/terms

g) Use of Google Remarketing

This website uses the remarketing function of Google Inc. (see Google Inc. address under point f above). This function is designed to display interest-based advertising messages to users through the Google advertising network. The user’s browser stores cookies that allow recognition of the user when visiting websites that belong to Google’s advertising network. These pages may display promotional messages related to content previously viewed by users on websites that use Google Remarketing. Google states that it does not collect any personal data in this process. Users may disable Google Remarketing on the page http://www.google.com/settings/ads
Alternatively, users may disable the use of cookies for interest-based advertising through the Advertising Network Initiative by following the instructions on http://www.networkadvertising.org/managing/opt_out.asp

h) Use of Hotjar

To improve the browsing experience on our websites, we use services and software provided by Hotjar Ltd. (Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, http://www.hotjar.com
). Hotjar allows us to measure and evaluate user behavior on our website. The purpose is to improve the user browsing experience, remember preferences, resolve technical issues, analyze trends and generally improve our website. For these purposes, Hotjar places cookies on users’ devices to collect non-personal information about the device and browser (e.g. IP address in anonymized form, screen resolution, device type, operating system and browser type, country of access, language settings), user interaction data (such as mouse movements, keystrokes, scrolling, etc.) and log data (such as pages visited, time spent on a page, referring URL and domain, date and time of access, etc.). Hotjar may store such collected data in anonymized form. For further information on Hotjar’s privacy policies, please see https://www.hotjar.com/privacy

To prevent data processing by Hotjar, users may disable cookies in their browser settings and delete any active cookies. Users may also object to data collection and processing by Hotjar at https://www.hotjar.com/opt-out

Section 2
Storage and transmission of information to third parties

Information will be stored on our secure servers and may be shared with our service providers who assist us in targeted communications to specific audiences, personalized advertising and website optimization.

Personal information may be transferred outside Italy and, in some cases, outside the European Economic Area (EEA), where necessary for the purposes described above (including the transfer of confidential information to third parties). In such cases, personnel operating outside the EEA, whether employed by us or by one of our suppliers, may process personal information. By submitting personal information, users consent to such transfer, storage and processing.

Where personal information is transferred outside the EEA, we ensure that appropriate measures are in place to protect personal information and verify that it is always processed in accordance with the Law.

Section 3
Retention period

Personal data are retained only for the period necessary to achieve the purposes described above. Personal data will be deleted when they are no longer necessary for the purposes described or upon expiry of the retention periods provided for by law.

Section 4
Links to other websites

This Privacy Notice does not cover links contained on our website that lead to other websites. Users are advised to review the privacy notices of the websites visited.

Section 5
Amendments to our online privacy notice

INKOUT UNIPERSONALE SRL may amend this Online Privacy Notice from time to time. Amendments will be communicated through updates on the website. Users are advised to regularly access the website to review acceptance of any changes.

Section 6
Access to personal information / right to rectification and erasure

Pursuant to Article 15 GDPR (Right of Access by the Data Subject), users have the right to know exactly which personal information is contained in our records.

If the information we hold is not up to date or is incorrect, users have the right to request correction and updating. Pursuant to Article 16 GDPR (right to rectification), users may also request the erasure of their data, provided that there is no legal obligation or overriding legitimate interest requiring retention.

Right to object pursuant to GDPR Article:

Right to object based on a particular situation:

Pursuant to Article 21(1) GDPR, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data at any time.

In the event of objection, we will no longer process personal data unless compelling legitimate grounds for processing can be demonstrated which override the interests, rights and freedoms of the data subject (e.g. to initiate or defend legal claims).

Right to object for commercial purposes:

Furthermore, pursuant to Article 21(2) GDPR, the data subject has the right to object to the use of personal data for direct marketing purposes. In such cases, we will no longer use the data subject’s data for commercial purposes.

An objection may be sent in any form to the contact details indicated in the following Section 7.

The Italian Data Protection Authority can be contacted at the following details:

Address: Piazza di Monte Citorio n. 121 – 00186 ROME
Fax: (+39) 06.69677.3785
Telephone: (+39) 06.696771
E-mail: garante@gpdp.it

If data processing is based on consent, the data subject may withdraw such consent at any time, regardless of whether it was given before or after the GDPR entered into force. Withdrawal of consent shall not affect the lawfulness of processing activities carried out up to the date of withdrawal.

Section 7
Contact address

For questions and comments relating to this Online Privacy Notice, the use of personal information or for any requests, please contact:

INKOUT UNIPERSONALE SRL
VIA DEL MANZASCO 4R

E-mail: amministrazione@inkout.it

Website: www.aidi-polimi.com

Privacy Notice – Cookie Management

No personal data are intentionally collected through cookies.

Cookies are not used to transmit personal information, and we do not use persistent cookies or other user tracking systems.

The use of so-called session cookies (which are not stored on the user’s computer and are deleted when the browser is closed) is limited to the transmission of session identifiers (random numbers generated by the server) which enable safe and efficient browsing.

Session cookies are used in place of other techniques that could compromise user privacy and do not collect any personal data or other personal information.