PRIVACY POLICY

Information notice pursuant to art. 13 EU Reg. 2016/679 – General Data protection regulation (GDPR)

 

Pursuant to UE Reg. 2016/679 (General Data Protection Regulation) we provide you the deserved information concerning processing of collected personal data. This notice shall not to be considered valid for other websites attainable trough links and the Data Controller shall not be held responsible for third parties web pages. A separate privacy policy will be provided for ICAM’s domain websites that can be accessed through the aforementioned links.

DATA CONTROLLER

The Data Controller, pursuant to articles 4 and 24 GDPR is ICAM S.p.A., a company with registered address at via Pescatori, 53 – 23900 Lecco (LC), duly represented by its legal representative. The contact email is: privacy@icamcioccolato.it.

 

PURPOSE OF PROCESSING | LEGAL GROUND | DATA RETENTION | PROVISION OF PERSONAL DATA

 

Purpose of processing Legal ground  Data retention Nature of data conferral
A Website browsing Legitimate interest of the Data Controller

Art. 6 lett. f) and recital 47 GDPR

activities strictly necessary for site operation and platform browsing services

 Until the end of the browising session Necessary for the data controller’s legitimate interest, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration his reasonable expectations based on the relationship with controller.
B Eventual contact request or request of information submitted by the data subject (through phone call or the dedicated form on this website) Legitimate interest of the Data Controller

Art. 6 lett. f) and recital 47 GDPR

 1 year Necessary for the data controller’s legitimate interest, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration his reasonable expectations based on the relationship with controller.
C Direct marketing (e.g. informational and/or promotional newsletters about ICAM’s products). With regard to email communications, statistical tracking systems may be used to detect the opening of a message and the clicks made on the links (hyperlinks contained in the email), identifying in particular their quantity and date according to the technical specifications of the platform used by the Data Controller. Consent of the data subject 

Art. 6 lett. a) GDPR

 Until consent withdrawal (opt – out) Free and optional. Failure to provide it will in no way affect the processing of your contact/information request. 
D Registration to ICAM’s private area Contract – execution of precontractual measures

Art. 6 lett. b) GDPR

 2 years  Necessary in order to perform precontractual measures upon data subject’s request.
E Recruitment activities based on the CV submitted by the data subject to the dedicated form on the present website Execution of precontractual measures 

Art. 6 lett. b) GDPR

 12 months Necessary in order to proceed with the recruitment and in order to perform precontractual measures upon data subject’s request.
F Managing requests forwarded as data subject in accordance with articles 15 et seq. GDPR Fulfillment of a legal obligation

Art. 6 lett c) GDPR

 5 years from receipt of the request and until the end of any litigation that may arise. Required. Failure to provide it will result in the inability to process requests made under the GDPR.

 

DATA RECIPIENTS 

Personal data provided by you may be communicated to recipients who will act as Processors (art. 28 of the Reg. EU 2016/679) and/or persons acting under the authority of the Controller and the Processor (art.29 of the Reg. UE 2016/679) for the purposes pointed ahead.

Precisely, personal data will be communicated to: 

 

  • subjects providing services for the management of the information system and telecommunication network (including email as well as mailing list/newsletter services); 
  • Studies or companies in the context of assistance and consultancy relationships; 
  • Eventual third parties, such as labor consultants and companies for the purpose of personnel selection, as part of assistance and consulting relationships;
  • Competent authorities for compliance with legal obligations and / or provisions of public bodies, upon request.

You can request a complete listing of processors by writing to privacy@icamcioccolato.it.

 

TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES AND/OR INTERNATIONAL ORGANIZATIONS

Personal data will not be transferred to third countries outside the European Union.

 

DATA SUBJECTS’ RIGHTS

You may freely exercise your rights, at any time, pursuant to artt. 15 et sub. of GDPR by writing to the Data Controller at the email address privacy@icamcioccolato.it.

You have the right, at any time, to obtain from the Data Controller the access to your personal data, request their rectification, erasure or processing restriction. You have the right to object (21), at any time, to the processing of personal data grounded on a legitimate interest, and whether the processing is based on consent you have the right to withdraw the consent without prejudice to the lawfulness of the processing previously grounded on the latter. In case of a request for data portability, the Data Controller shall provide your personal data to you in a structured, commonly used and machine-readable format. You have the right to oppose to the processing based upon consent and/or legitimate interest. In order to unsubscribe from our newsletter please use our automated unsubscribing tools.

 

Without prejudice to any other administrative or judicial remedy, in case you consider the processing conflicting with Reg. UE 2016/679, pursuant to article 15 lett. f) you have the right to lodge a complaint with a supervisory authority (www.garanteprivacy.it).

 

Last update: June 23rd 2023

 

Data Controller

ICAM S.P.A.