Privacy Policy on the Processing of Personal Data in accordance with EU Regulation 2016/679 and applicable Italian law
This Privacy Policy aims to describe the management methods of the Funziona website regarding the processing of personal data of users who consult it. Users are invited to read this Privacy Policy carefully before providing any personal information and/or filling out any electronic form on the site.
- Data Controller of the Collected Data The Data Controller of the data collected on the Site, pursuant to the European Regulation 2016/679 on the protection of personal data, is Funziona srl, with its registered office at Via Mario Pagano 56, 20145 Milan, and operational office at Via V. Gioberti 5, 20123 Milan, VAT number 06244000961, tel. 0289356098, Pec address funzionasrl@crcpec.it.
- Data Protection Officer The Data Protection Officer can be contacted:
– By email at the following email address: privacy@funzionasrl.com; or
– By phone at the number: +390289356098. - Purposes and Legal Basis of the Processing Performed on the Site Through the Site, personal data is collected and processed for the following purposes:
(a) Service Requests: The personal data voluntarily provided by the user through the contact form or received through the “Contacts” section (name, surname, email address, phone number, and other information indicated therein) are processed by the Company to respond to the requests made.
(b) Cookies: On the Site, in addition to the data expressly provided, other data deriving from the user’s navigation may be recorded: when the user accesses it, the Site can send a “cookie”. A “cookie” is a small text file that the Site can send to the user’s computer when they view our pages. “Cookies” are used to make navigation more convenient, as well as to allow the operation of some services that require the identification of the user’s path through different pages of the Site. For any access, regardless of the presence of a “cookie”, the Site records the type of browser (e.g., Internet Explorer, Chrome, Firefox), the operating system (e.g., Windows, Macintosh), and the host and URL of the user’s origin, in addition to the data of the requested page. These data can be used in aggregate and anonymous form for statistical analysis on the use of the Site. On this point, we invite you to read the specific Cookie Policy.
(c) Navigation Data or Metadata: The computer systems and software procedures responsible for the operation of this website acquire, during their normal operation, some traces or metadata (considered personal data) whose transmission is implicit in the use of Internet communication protocols. The acquisition of this information (also called “passive”) can occur even in the absence of registration to the service by the user and without their active role. These data, necessary for the use of web services, are also processed for the purpose of:
Obtaining statistical information on the use of services (most visited pages, number of visitors by time slot or daily, geographical areas of origin, etc.);
Checking the correct functioning of the services offered. These data could be used to ascertain responsibility in case of hypothetical computer crimes against the site or upon request by public authorities.
The personal data collected and processed by the Company are provided directly by the user, except for the navigation data mentioned in the “Navigation Data or Metadata” section and the “Cookies” section regulated by the Cookie Policy.
The legal basis for processing the user’s personal data lies: (i) For the purposes referred to in point 3 (a), in the legitimate interest of the Company to respond to the service requests made by the user; (ii) For the purposes referred to in point 3 (c), in the legitimate interest of the Company to ascertain responsibility in case of hypothetical computer crimes against the site or upon request by public authorities.
For the purposes referred to in point 3 (b), please refer to the specific Cookie Policy. - Categories of Recipients of Personal Data The Company communicates the personal data of the Site users only within the limits allowed by law and as illustrated below. In particular, the user’s personal data may be processed or known by: (i) Employees of the Company, who operate as authorized persons for processing and are instructed in this regard by the Company; (ii) Companies that perform specific technical and organizational services related to the Site for the Company, as Data Processors pursuant to Article 28 of the Regulation; (iii) Law enforcement agencies or judicial authorities, in accordance with the law and upon formal request by them, or if there are reasonable grounds to believe that the communication of such data is reasonably necessary to: (a) investigate, prevent, or take action regarding suspected illegal activities or assist state supervisory and control authorities; (b) defend against any claims or accusations from third parties, or protect the security of the website and the Company; or (c) exercise or protect the rights, property, or safety of the Company, its customers, its employees, or any other subject. Personal data will not be disseminated; in any case, any transfer of data abroad, including to non-EU countries, will only occur ensuring adequate levels of protection and safeguards according to legal standards, such as the Standard Contractual Clauses approved by the European Commission.
- Methods of Processing Personal Data and Retention Period The personal data collected through the Site are processed with predominantly electronic and telematic methods and tools, adopting security measures to minimize the risks of destruction or loss, even accidental, of the data themselves, unauthorized access, or processing not allowed or not in accordance with the purposes of collection indicated in this Privacy Policy. The personal data provided by the user during navigation and related to it will be retained for a period not exceeding 12 months. The personal data processed to provide a service will be retained for the time strictly necessary to provide the user with the requested service.
- Mandatory or Optional Nature of Providing Data Except for navigation data regulated by the Cookie Policy, the provision of personal data collected through the Site is optional. Failure to provide it does not limit the use of the Site but may make it impossible for the Site to meet the service requests made or proceed with the evaluation of the user for the purpose of establishing an employment relationship.
- Rights Recognized to the User The user has the right to:
Access personal data concerning them and obtain confirmation of their existence or not, their communication in an intelligible form, and their integration;
– Request the update, rectification, or, when interested, the integration of personal data;
– The limitation of processing concerning them, the deletion, transformation into anonymous form, or blocking of personal data processed in violation of the law, including those for which retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
– Object, in whole or in part, for legitimate reasons, to the processing of their personal data even if pertinent to the purpose of collection;
– Obtain the transmission of their data to another data controller (so-called right to data portability).
Furthermore, the user, if the processing is based on consent, pursuant to Article 7, paragraph 3, of the Regulation, can revoke the consent given at any time, without prejudice to the lawfulness of the processing carried out before the revocation.
The user can make any requests to exercise their rights in writing, sending the Model for the exercise of rights in the field of personal data protection – available at the address https://www.garanteprivacy.it/home/modulistica-e-servizi-online duly completed, and accompanied by a copy of a valid identification document – to the Data Controller or, for them, to the Data Protection Officer, as identified above. - Right to Lodge a Complaint The user has the right to lodge a complaint, pursuant to Article 77 of the Regulation, with the national supervisory authority (for Italy, the Data Protection Authority: www.garanteprivacy.it).
- Final Clause Given the current state of evolution of the legislation on personal data protection, it is communicated that this Privacy Policy may be subject to updates.
