(document updated on May 25th, 2018)
Dear Customers, Suppliers, Potential Customers and Web Site Users,
Ego International Group SRL, located in 47924 Rimini (RN), Italy, Via Nuova Circonvallazione 69/B, Vat No. 04175920406 (hereinafter referred to, for the sake of simplicity, as “EGO Int.” or “Controller”) is committed to safeguarding your personal data to the greatest possible extent.
With regard to this, EGO Int. is going to comply with the New EU Regulation 2016/679 for the personal data protection (hereinafter “GDPR” or “the New Regulation”), and with the Italian Privacy Code, as updated according to Italian D. Lgs. 101/2008.
- Who are the Controllers, the Processors and the persons responsible for the processing of your data
The Controller of your personal data is Ego International Group SRL, located in in 47924 Rimini (RN), Via Nuova Circonvallazione 69/B, Italy, VAT code IT 04175920406, E-mail: firstname.lastname@example.org – Tel-: (+39) 0541779511 -.
Please note that EGO Int. IS NOT requested to appoint a DPO (Data Protection Officer) according to art. 37 of the new Regulation. As a consequence of that, any request of information regarding your personal data shall be addressed to the above contacts.
Furthermore, please note that an updated list of the processors and of the other persons responsible for processing, including nominated professionals, is held at the legal premises of the Controller.
- What is a personal data and what data EGO Int. processes
We would like to inform you as to the meaning of “personal data” and “processing”.
Personal Data refers to any information by means of which it is possible to identify, or to render identifiable with reasonable ease, a physical person.
By contrast, the processing of Data includes the following operations stated in article 4 of the New Regulation: collection, registration, organisation, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of Data.
EGO Int. processes mainly legal entities’ data, which are not subject to the New Regulation.
However, EGO Int. might process data of professionals and/or sole proprietorships with whom it maintains business relationships, and those data are to be qualified as Personal Data. This category of personal data includes for instance name, surname, telephone, e-mail, fiscal code, bank account of a professional or a sole proprietorship.
Furthermore, EGO Int. might process personal data of legal entities’ employees, such as for instance the business e-mail addresses which include the employee’s name and surname (eg. Claudio. email@example.com).
EGO Int. also processes Personal Data (see for instance the user IP) of those persons who visit and use our Web Site http://www.egointernational.eu (please see our cookies policy on the web site). The optional, explicit and voluntary sending of email to the addresses specified on the Website or of messages by the form on website will result in the acquisition of the address of the sender, which is required in order to reply to requests, as well as in the acquisition of any other personal data included in the communication / message.
On the other hand, EGO Int. does NOT process the so called Particular Personal Data, such as those concerning health, legal proceeding, genetic or biometric data.
Should you provide us with the Data of third parties, you will be required to take all necessary steps to ensure that the communication of the Data to the Controller and our consequent processing of the same comply with the applicable provision. Therefore, for example, before providing us with the Data of third parties, you should duly inform such parties and obtain their consent to processing, if required by the aforementioned provision.
- How your personal data are collected by EGO Int. and why
EGO Int. collect the Personal Data which is provided directly by the Data Subject (ie the owner of the personal data):
- When it is necessary for the execution and/or the performance of a contract to which the data subject is party;
- When it is necessary to take steps at the request of the data subject prior to entering into a contract regarding EGO Int.’s products and services, or regarding the organization of the same company;
- When it is necessary to reply the requests voluntarily sent by the sender for instance to the e-mail address indicated on the Web Site. In said circumstances, it will result in the acquisition of the address of the sender, as well as in the acquisition of any other personal data included in the communication.
In addition, EGO Int. collects – from third companies – Personal Data regarding people employed in legal entities which might be interested in EGO Int.’s Client Services and / or Products (said data regards in particular e-mail address). In this circumstance, EGO Int. declares that said third companies have ensured that the processing of data (and therefore their collection and transer) is in compliance with the law.
- how your personal data are processed
Your Personal data shall be processed by EGO Int. according to the principles stated at Art. 5 of the New Regulation, ie: lawfulness, fairness and transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality.
Ego Int. processes Data in both printed and electronic form. In such context, EGO Int. will guarantee the logistic and physical security of the Data and, in general, the confidentiality of the Data processed, by taking all necessary technical and organisational measures, so as to reduce the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
EGO Int. does not carry out profiling activities with your data, and your data will not be disclosed without previous and explicit consent.
- Why do we process Your Data
EGO Int. collects and processes your Personal Data, without a specific consent, for the following purposes:
- To complete necessary precontractual activities (e.g. sending of quotations, verification of credit rating and solvency);
- To carry out contractual and taxation obligations towards yourself;
- To protect our assets and/or defend our rights on the basis of our legitimate interests;
- To fulfil legal requirements and comply with requests of authorities, as well as to comply with fraud and money laundering prevention provisions, etc.;
- To reply to requests sent via email or via the Website form;
- To evaluate the profile of candidates and select the same, where these have sent curricula of their own free choice;
- To send electronic communication (e-mail) regarding the services provided by EGO Int and / or the products of EGO Int.’s clients. However, you shall have the right to oppose the processing of Data for the purpose of marketing at any time, by contacting us (as indicated below), or for instance by unsubscribing from the e-mail (OPT OUT procedure).
Should you have given us your specific consent, then your Persona Data shall be processed in order to:
- Carry out direct marketing activities;
- Transfer your Personal Data to third parties;
- Analyze or predict your behavior or your personal preferences;
- Disclose your Personal Data.
Please note that you can revoke, at any time, any possible consent already given, by contacting the Controller by e-mail.
The table below describe the lawfulness of processing stated by the New Regulation, according to which your data are processed.
|Processing||Lawfulness of processing|
|Sending of quotation||Execution of Pre-contractual activities|
|Supply of services, purchase of products and services||Performance of contractual obligation|
|Assets protection – defence of rights||Legitimate interest pursued by the Controller|
|Sending of information to public authority||Legal obligation to which the Controller is subject|
|Reply to requests sent via email or via the Website form||Execution of Pre-contractual activity|
|Candidates profiles evaluation||Execution of Pre-contractual activity|
|Sending of electronic communication (e-mail) to companies potentially interested in services provided by EGO Int.||Legitimate interest pursued by the Controller and / or consent of the data subject.|
|Marketing activity||Consent of the data subject|
|Transferring or communication of data to third persons||Consent of the data subject|
|Analyze or predict behaviors or personal preferences||Consent of the data subject|
|Disclosure of data||Consent of the data subject|
In determining the existence of a legitimate interest (eg when we decide to send e-mail to company potentially interested in our services), we balance the different potential opposite interests, ie
- That of EGO Int. to carry out a specific activity of its core business, and
- The fundamental right of each data subject.
EGO Int. may rely on a legitimate interest provided that the individual rights shall not contrast with nor prevail over EGO Int. interests, taking into consideration the reasonable expectations of the data subject, based on his / her relationship with the Controller.
- Is it necessary to provide my personal data or consent
The provision of data for the purposes set out in previous clause letters a) – d) is obligatory. Should it not be provided then contract execution cannot be guaranteed.
The provision of data for the purposes set out in previous clause letters e) – k) is instead optional. Therefore, you may decide not to provide data or to successively deny the possibility to process previously-supplied data: in such case, failure to provide data may mean that it is not possible to fulfil your requests or evaluate potential job applications.
In relation to the purposes for which explicit consent is requested from yourself, failure to provide consent does not constitute a valid reason for the Controller to withdraw from a contract or to not fulfil your requests in relation to other purposes.
- Who is your Data communicated to
Without having to obtain your express consent, EGO Int. may communicate your Data, for the above referred to purposes, to prefectures, insurance supervision institutes (such as IVASS), judicial authorities, insurance companies (for the provision of insurance-related services), as well as to parties to which such communication is required by law for the fulfilment of the afore-mentioned purposes. Said parties will process the Data as autonomous controllers.
- Who can access your Data
Your Data may be made accessible for the above- mentioned purposes
- To employees and collaborators of the Controller, in their role as persons responsible for processing and/or internal processors and/or system administrators;
- To third parties or other parties (such as, for example, credit institutes, professional offices, consultants, insurance companies for the provision of insurance services, etc.) that carry out activities which have been outsourced by EGO Int., in their role as external processors or co-controllers should they process Data for their own purposes.
- Where is your Data stored and where is it transferred to
The Data is processed at the operative premises of the Controller, in 47924 Rimini (RN), Via Nuova Circonvallazione 69/B, as well as in any other place where the parties involved in the processing are located. For further information, please contact us as indicated below.
The Data is held in electronic form on servers located within the European Union. In all cases, it should be understood that EGO Int., should it prove necessary, will have the faculty to move the server to non-EU countries. In such case, EGO Int. guarantees from hereon in that the transfer of Data outside of the EU will take place in accordance with applicable legal provisions following on from the stipulation of standard contractual clauses provided for by the European Commission or in conformity with the Privacy Shield, in relation to those countries that do not, according to the European Commission, offer adequate provisions.
- How long do we hold your Data for
Your Data will be held in accordance with the principles of proportionality and necessity, and until the purposes for which it was collected have been fulfilled.
In any case, the storing time differ according to the purpose of the processing, as described in the table below.
|Sending of quotations||Six months|
|Supply of services, purchase of products and services||11 years after the business relationship conclusion|
|Assets protection – defence of rights||11 years after the business relationship conclusion|
|Sending of information to public authority||11 years after the business relationship conclusion|
|Reply to requests sent via email or via the Website form||Six moths|
|Candidates profiles evaluation||In case EGO Int. is not interested in the CV, the CV shall be cancelled after 6 (six) month from their receipt.|
|Sending of electronic communication (e-mail) to companies potentially interested in services provided by EGO Int.||Until the Data Subject does not revoke the provided consent|
|Marketing activity||Until the Data Subject does not revoke the provided consent|
|Transferring or communication of data to third persons||Until the Data Subject does not revoke the provided consent|
|Analyze or predict behaviors or personal preferences||Until the Data Subject does not revoke the provided consent|
|Disclosure of data||Until the Data Subject does not revoke the provided consent|
Once the above terms have been expired, your Data will be cancelled automatically.
- What are your rights
As the Data Subject, you have the right to
- Know if the Controller holds and/or processes your Data, obtaining information relative to the: origin, category, purposes and method of processing, the recipients to whom such data can be communicated, the logic applied in the case of processing carried out by electronic means, the period for which data is held; as well as the right to access the same in its entirety and obtain a copy (art. 15 Right of access);
- Have rectified Data that relates to yourself and to complete Data which is incomplete (Art. 16 Right to rectification);
- Obtain the cancellation of Data in possession of the Controller where such cancellation is provided for by the New Regulation (art. 17 Right to erasure – Right “to be forgotten”)
- Request the Controller to limit the processing to only certain Data, where this is provided for by the New Regulation (Art. 18 Right to restrict processing);
- Be informed as to who the recipients to whom any rectifications, cancellations or processing restrictions have been communicated are (art. 19 Obligation of notification);
- Request and receive all your Data, in a format that is structured, commonly used and readable on an automatic device or to request its transmission to another controller without impediment (Art. 20 Right to portability);
- Oppose entirely or in part, the processing of Data for the purposes of marketing (sending of advertising material, direct sales, market research and commercial communications) and for the purposes of profiling connected to such marketing (art. 21 Right of opposition).
Finally, you have the right to present a claim/petition directly to the Personal Data Protection Authority, located at Piazza di Montecitorio n°. 121 – 00186 ROME, Italy tel. (+39) 06.696771 and Fax: (+39) 06.69677.3785.
The exercise of the rights set forth in this paragraph is completely free of charge.
- How can you exercise your rights
At any time, you may exercise your rights by sending:
- A registered letter with return receipt addressed to Ego International Group SRL, 47924 Rimini (RN) Italy, Via Nuova Circonvallazione 69/B;
- or an e-mail to firstname.lastname@example.org