Privacy Policy

PRIVACY POLICY

 

The General Data Protection Regulation (GDPR) has replaced the European Directive 95/46/EC. The Regulation aims to provide a modern, uniform and sound framework for data protection in Europe based on the accountability principle. The new provisions have an impact in organisational, operational and technological terms, and they also establish a stricter sanctioning system compared with the previous Directive.

 

The most notable change in the regulatory landscape for data protection is related to the wide jurisdiction of the GDPR, since the latter applies to personal data processing carried out within the scope of an enterprise’s activities by a data controller or data processor in the European Union, regardless of whether or not the processing is carried out there. Moreover, the Regulation is applicable to processing personal data of data subjects who are in the EU by a data processor or controller that is not located therein when the processing activities are related to: the offering of goods or services, regardless of whether or not the data subject must make a payment; or the monitoring of their behaviour as far as their behaviour takes place within the Union.

The Regulation is also applicable to personal data processing carried out by a controller that is not located in the European Union but in a place where Member State law is applicable by virtue of public international law.

 

The GDPR requires companies to implement appropriate technical and organisational measures in order to apply data protection principles and safeguard individual rights; this is known as "Data Protection by Design and by Default”.

 

Data Protection by Design ensures that the company considers the issues related to privacy and data protection in the design stage of any system, service, product or process and, thus, throughout the lifecycle thereof.

Data Protection by Default requires Arconvert S.A. to ensure that the Company processes only the data required to achieve a specific purpose and for a period of time no longer than that required for the purpose for which the data have been collected and subsequently processed.

 

Arconvert S.A. has adopted a Management Model for Personal Data Protection in accordance with the GDPR, bearing in mind the provisions in the Italian Legislative Decree 196/2003, which was amended by the Italian Legislative Decree 101/2018, defining binding rules and procedures for the Company and every employee thereof. Arconvert S.A. reviews and updates its Data Protection and Information Security Policy as required on a regular basis, and it determines progress guidelines that translate into an implementation plan for the updates. Pursuant to Article 13 and 14 of the GDPR, Arconvert S.A. provides all the information required by the regulations in the various documents contained in the “Privacy” section, which varies depending on the purpose for which the Data Subjects’ Personal Data are processed. If the user requires clarification regarding the sections dealt with in the Information Notices, he/she should contact our contact person for the matter by using the following email address: gdpr@arconvert.es.

 

INFORMATION NOTICE ABOUT PERSONAL DATA PROCESSING PURSUANT TO ARTICLE 13 OF THE GDPR 2016/679

 

Arconvert S.A., owner of the website www.arconvert.es , would like to inform you about the way in which the website is managed regarding data processing and the protection of persons (users concerned) who browse the website.

This document represents an information notice pursuant to the provisions in Article 13 of the European Regulation number 679 of 27 April 2016 (hereinafter referred to as the “GDPR”) and it is solely and exclusively valid for the website belonging to the Company and not for other websites that the user may visit via the links contained therein. We would like to point out that the "Ask Arconvert" service is rendered by the legal entity Arconvert S.A. (España), which is the controller for this specific data. Therefore, please consult the corresponding information notice.

 

1. The Data Controller

The Data Controller is Arconvert S.A., with registered office at Carretera de Cartellà, nº 6; 17150 - Sant Gregori (Girona) Spain, C.I.F. ESA17001801A.

For the purpose of exercising the rights stipulated in the Regulation and for any query you may have regarding your personal data, you can contact the Data Controller by sending a message to the following email address: gdpr@arconvert.es

 

2. Purpose and legal basis of the data processing

The legal basis of the processing described in this information notice is that specified in Article 6, point a) of the European Regulation: “the data subject has given consent to the processing of his or her personal data for one or more specific purposes.

The purposes of the data processing are as follows:

Contact form” section

a) The data are collected and processed in order to reply to Users’ requests for information;

b) The data are collected and processed in order to send informative and promotional material and/or commercial messages related to new products or updates and news about existing products and/or promotional events organised by Arconvert S.A., including sending newsletters; to conduct market surveys.

 

3. Type of personal data processed

Data provided by the user

Within the scope of the various aforementioned purposes, the following data will be processed:

Contact form: Full name, name of the company the user belongs to, business position, email address, telephone number, address of the user (street, city, post code, province and country);

Data that we collect automatically

During their normal operation, the IT systems and software procedures used for the functioning of the Website collect certain data, the transfer of which is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but due to its nature, it could lead to users being identified through processing of and association with data held by third parties. IP addresses or domain names of the computers and the terminals used by users, the URI/URL addresses (Uniform Resource Identifier/Locator) of the requested resources, the time of the request, the method used to send the request to the server, the size of the reply file obtained, the numeric code that indicates the status of the reply provided by the server (processed correctly, error, etc.) and other parameters related to the operating system and the IT environment of the user are included in this data category. These data are only used to collect anonymous statistical information about the use of the Website and to monitor its proper functioning. The data could be used to assign liability in alleged cyber-crimes against the website or other users, only at the request of the responsible supervisory bodies.

 

4. Data processing methods

The collected data are processed solely by authorised parties using automated and non-automated tools and appropriate methods to ensure the security and confidentiality thereof, and they are processed for the time required to achieve the purposes for which they were collected.

 

5. Possible recipients or categories of recipients of the personal data

The personal data held by Arconvert S.A. shall not be disseminated. They may be disclosed within the Company, transferred to duly authorised persons, and disclosed, if necessary, to the companies belonging to the Fedrigoni Group, to which Arconvert S.A. belongs, solely for the purposes specified in this information notice.

Moreover, solely for the purposes object of this information notice, the data may be disclosed to technical service providers, accommodation providers, IT companies and communication agencies, which will also be appointed as Data Processors by the Controller, if necessary. The updated list of Data Processors can be requested at any time from the Data Controller.

 

6. Transfer of personal data to other countries

Arconvert S.A. does not intend to transfer your personal data to countries outside the European Union.

In any case, if this occurs, Arconvert S.A. guarantees that this transfer will be made:

- To companies that form part of the Fedrigoni Group that adopt the same procedures regarding personal data processing (Corporate Binding Rules approved by the competent Supervisory Authority, or standard clauses pursuant to Article 46 of the GDPR);

- To countries outside the EU that, according to the European Commission, ensure an adequate level of protection (Article 45 of the GDPR) or have previously adopted the mechanisms specified in Article 46 of the GDPR;

- With the data subject’s prior consent when this is permitted by law (Article 49, point a) of the GDPR).

The foregoing may only be derogated in the situations stipulated in Article 49 of the GDPR.

 

7. Term for storing the personal data

Contact form:

The personal data processed to reply to Users’ requests for information will be stored for the time required to provide a reply and, in any case, up to a maximum term of three months after the request is made.

The personal data processed for marketing purposes will be stored for 36 months from the date consent is granted. Once this term expires, unless contractual relations have been established with the company to which the data subject belongs, the request for consent shall be renewed, if necessary.

The data may be kept for a longer period of time due to petitions received from the Public Authorities or another judicial, government or regulatory body or due to the company that has drawn up these information notices being involved in legal proceedings that imply processing the personal data provided by you.

 

8. Mandatory and optional nature of providing data

Providing your personal data is optional. Failure to provide the data or refusal to grant consent for the purposes outlined in point a) will prevent Arconvert S.A. from replying to the User’s requests. Failure to provide the data or refusal to grant consent for the purposes outlined in point b) will prevent Arconvert S.A. from carrying out the specified activities with such purpose. Refusal to grant consent for the purposes outlined in point b) will not prevent the purpose in point a) from being carried out.

 

9. Rights of the data subject

The data subject shall have the right to obtain access to the personal data from the data controller. In particular, the data subject has the right to obtain the following: a) information about the source of the personal data, the purposes and methods of the processing, the logic involved if processing is carried out using electronic tools; b) the rectification or update of data; c) the erasure of data or the restriction of data processing (making them anonymous, blocking data that were processed in breach of the law, including data that do not need to be stored for the purposes for which they were collected and subsequently processed); d) the portability of processed data in a structured manner.

In any case, the data subject is entitled to revoke the consent granted to process personal data. However, revoking the consent granted for data processing shall not affect the legality of the processing that was carried out based on the consent granted prior to such revocation.

A data subject resident in Spain is entitled to file a claim with the Supervisory Authority, represented in Spain by the Spanish Data Protection Authority, with registered office at C/ Jorge Juan, 6. 28001 - Madrid. Any data subject who resides outside of Spain may file a claim with the Supervisory Authority appointed in their country of residence.

In any case, we would like to inform you that pursuant to Article 21 of the European Regulation 2016/679, if the data are processed for direct marketing purposes, you are entitled to object to the processing of your personal data for such purpose at any time.

 

10. Non-existence of an automated decision-making process

Arconvert S.A. does not subject the data processing object of this information notice to automated decision-making processes.

 

11. Interaction with social media and external platforms

This kind of service allows users to directly interact with social media, or other external platforms, from the pages on this Website. The interactions and information collected by this Website are in any case subject to the User’s privacy settings for each social network. If a social media interaction service is installed on the latter, it is possible that it could collect traffic data related to the pages on which it is installed, even if users do not use the service.

The social networks identified are Facebook, Twitter, Instagram, LinkedIn and YouTube. Please consult the relevant information notices and privacy policies of each of the aforementioned social networks.

 

Request for consent

The undersigned specifically consents to the processing of his/her personal data pursuant to Article 6, point a) of the European Regulation number 2016/679 in order to enable Arconvert to process and reply to the request for information sent

 

□ I consent □ I do not consent

 

The undersigned specifically consents to the processing of his/her personal data pursuant to Article 6 point a) of the European Regulation number 2016/679 and in accordance with the Guidelines on promotional activity and prevention of spam of the Italian Data Protection Authority of 4 July 2013 for marketing purposes (sending informative and promotional material and/or commercial messages related to new products or updates and news about existing products and/or promotional events organised by Arconvert S.A.), including sending newsletters

 

□ I consent □ I do not consent

 

INFORMATION NOTICE ON PERSONAL DATA PROCESSING PURSUANT TO ARTICLE 13 AND 14 OF EU REGULATION NUMBER 679/2016

 

Data Subjects: employees of customers, potential customers and suppliers

  

Throughout the valid term of a contract entered into with its own customers and suppliers, during inspections, verifications or audits, or as a result of commercial relationships, Arconvert S.A. may obtain access to personal data related to the workers of customer companies, suppliers or potential customers (hereinafter referred to as the “Data Subjects”). Pursuant to the regulation in force, Arconvert S.A. provides the following information notice to the Data Subjects, in accordance with Article 13 and 14 of EU Regulation number 679/2016.

 

Identity and contact details of the data controller

The Data Controller is Arconvert S.A., with registered office at Carretera de Cartellà, nº 6; 17150 - Sant Gregori (Girona) Spain, C.I.F. ESA17001801A.

For the purpose of exercising the rights stipulated in the Regulation and for any query you may have regarding your personal data, you can contact the Data Controller by sending a registered letter to the aforementioned address, or a message to the following email address: gdpr@arconvert.es

 

Purposes of the processing to which the personal data are subject

Arconvert S.A. processes the Data Subjects’ personal data for the purpose of executing the agreement entered into with the holder of the work relationship or carrying out inspection, verification or audit activities before or after the execution of the agreement, as well as executing the existing commercial relationship.

 

Legal basis of the processing

The Data Subjects’ personal data must be processed due to the legitimate interests of the company that has drawn up these information notices and, in particular, to execute the agreement entered into by Arconvert S.A. and the organisation to which the worker belongs, either within the scope of the negotiations to enter into the agreement or for the purpose of conducting inspections, verifications or audits.

 

Categories of personal data subject to processing

General personal data will be processed (data related to the work relationship, the professional post, identification and tax information, contact details, etc.), to the extent that this is strictly required for the specified purposes.

 

Possible recipients or categories of recipients of the personal data

Personal data may be disclosed to the employees of Arconvert S.A. that are authorised to carry out data processing and/or third parties that are duly appointed as Data Processors, such as factoring companies, debt recovery companies, credit insurance companies, manufacturing companies and/or companies that grant licences to use possible services/products supplied, only when such disclosure is necessary and to the extent that it is essential for the specified purposes.

 

Transfer of data to third countries

At present, Arconvert S.A. does not intend to transfer your personal data to countries outside the European Union.

In any case, if this occurs, Arconvert S.A. guarantees that the data will be transferred to countries outside the EU that, according to the European Commission, ensure an adequate level of protection (Article 45 of the GDPR) or are subject to the standard contractual clauses approved by the European Commission.

The foregoing may only be derogated in the situations stipulated in Article 49 of the GDPR.

 

Term for storing the personal data

The organisation that has drawn up these information notices will keep the personal data for the valid term of the agreement entered into with the organisation that holds the employment contract and for ten years following the termination of such contract and/or in any case, pursuant to the requirements in the civil, tax and administrative law in force on storing data. The data may be kept for a longer period of time due to petitions received from the Public Authorities or another judicial, government or regulatory body or due to the company that has drawn up these information notices being involved in legal proceedings that imply personal data processing.

The personal data processed by Arconvert S.A. in the stage prior to signing an agreement with the worker’s organisation will be kept for the time strictly required for the negotiations and to draw up the contract, as well as for the inspection, verification and audit activities.

 

Rights of the data subject

The data subjects shall have the right to request that the data controller grant them access to the personal data, free of charge and notwithstanding the rights and freedoms of third parties. In particular, they are entitled to receive confirmation as to whether or not their data are currently being processed, as well as the following information: a) the source of the personal data, when the data have not been disclosed by the data subject; b) the personal data categories; c) the purposes and the methods of the processing; d) the existence of an automated process, including profiling and, in such case, the logic involved, as well as the significance and envisaged consequences of this processing for the data subject; e) the update or rectification of the data; f) the erasure of data or restriction of data processing (making them anonymous, blocking data that were processed in breach of the law, including data that do not need to be stored for the purposes for which they were collected and subsequently processed); g) the recipients or categories of recipients to which the data have been or will be disclosed, specifically if they are to be sent to international organisations or third countries (in the latter case, the data subject is entitled to receive information about the existence of suitable guarantees pursuant to Article 46 on the transfer of data); h) when possible, the envisaged period for which the data will be stored or, if this is not possible, the criteria used to determine this period.

When the Data Subject’s consent is required, he/she will be entitled to revoke the consent granted to process the personal data. However, revoking such consent shall not affect the legality of the processing that was carried out based on the consent granted prior to such revocation. 

Moreover, the Data Subjects are entitled to data portability and to oppose data processing.

 

The right to file a claim with a supervisory authority

The data subject is entitled to file a claim with the supervisory authority, represented in Spain by the Spanish Data Protection Authority, with registered office at C/ Jorge Juan, 6. 28001 - Madrid. The data subject may file a claim using the methods he/she considers most convenient: delivered in person, by means of a registered letter with acknowledgement of receipt, by fax or email. For further information, the data subject is encouraged to visit the website of the Spanish Data Protection Authority at the following address: www.aepd.es/

 

Source of the personal data

The personal data have been provided by the organisation to which the Data Subject belongs, or directly by the Data Subject.

  

Non-existence of an automated decision-making process

The processing object of this information notice will not be subject to automated decision-making processes that imply significant legal effects for the data subject.

 

INFORMATION NOTICE FOR CANDIDATES

 

Information pursuant to Article 13 of EU Regulation number 679 of 27 April 2016

 

Dear Sir/Madam,

The European Regulation number 2016/679 (hereinafter referred to as the “GDPR”) requires that the person who processes personal data informs the Data Subject (in other words, the person to whom the data refer) about the methods of the processing, which must be conducted fairly, legally and transparently, ensuring the confidentiality and rights of the Data Subject. By fulfilling Article 13 of the aforementioned Regulation, we hereby inform you of the following:

 

PROCESSING METHODS

The processing will be carried out through collection, recording, organisation, storage, consultation, preparation, alteration, selection, retrieval, alignment, use, combination, restriction, disclosure, erasure and destruction, and it shall be carried out by the controller, processors or persons authorised to carry out the processing.

The data shall be processed in a lawful, fair and transparent manner, and they shall be collected for specific, explicit and legitimate purposes; they shall not be processed in a manner that is incompatible with these purposes. The data shall be adequate, relevant and limited to what is necessary for the purposes for which they are processed. They shall be accurate, up to date and processed with the utmost confidentiality, mainly using electronic and IT tools and stored on IT devices, hard copy, and any other suitable medium, observing the principles outlined in the European Regulation on personal data protection and the provisions issued by the Supervisory Authority. In any case, the data shall be processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing or loss, including accidental loss, using appropriate technical and organisational measures. The data shall be kept in a form that enables the data subject to be identified throughout the time strictly required to achieve the purposes for which they were processed.

 

IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER

The Data Controller is Arconvert S.A., with registered office at Carretera de Cartellà, nº 6; 17150 - Sant Gregori (Girona) Spain, C.I.F. ESA17001801A.

For the purpose of exercising the rights stipulated in the Regulation and for any query you may have regarding your personal data, you can contact the Data Controller by sending a registered letter to the aforementioned address, or a message to the following email address: gdpr@arconvert.es

 

PURPOSES AND LEGAL BASIS OF THE PROCESSING

The Company will collect the data provided by you for the specific purpose of searching for and recruiting staff. The legal basis is therefore that contained in Article 6(1), point f) of the GDPR: processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Since the Company may become aware of the specific data categories related to you, in this case the data processing shall be based on Article 9(2), point a) of the GDPR the data subject has given explicit consent to the processing of those personal data .

 

PERSONAL DATA PROCESSED

Within the scope of the purposes outlined in the previous section, the following data will be processed:

  1. Identification data (full name, date of birth, place of residence, possible special data categories);

  2. Contact details (email address, telephone number, address);

  3. Sensitive data, if any (membership in trade unions, health situation).

 

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE PERSONAL DATA

The personal data held by Arconvert S.A. shall not be disseminated. They may be disclosed within our organisation and transferred to authorised persons and data processors appointed by the Company.

 

TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

At present, Arconvert S.A. does not intend to transfer your personal data to countries outside the European Union. In any case, if this occurs, Arconvert S.A. guarantees that the data will be transferred to countries outside the EU that, according to the European Commission, ensure an adequate level of protection (Article 45 of the GDPR) or are subject to standard contractual clauses approved by the European Commission.

The foregoing may only be derogated in the situations stipulated in Article 49 of the GDPR.

 

TERM FOR STORING PERSONAL DATA

The personal data provided to search for and recruit staff will be stored for a maximum term of 6 months counted from the date of the first interview.

The data may be kept for a longer period of time due to petitions received from the Public Authorities or another judicial, government or regulatory body or due to the company that has drawn up these information notices being involved in legal proceedings that imply processing personal data provided by you.

 

MANDATORY OR OPTIONAL NATURE OF PROVIDING DATA

Providing the data is mandatory. The possible refusal to provide us with all or some of your personal data will prevent the Company from examining the application form of the data subject and/or properly fulfilling all the obligations related to the search for and recruitment of staff.

 

RIGHTS OF THE DATA SUBJECT

The Data Subject shall have the right to obtain access to the personal data from the data controller. In particular, the Data Subject has the right to obtain the following: a) the source of the data; b) the purposes and methods of the processing; c) the logic involved if the processing is carried out using electronic tools; d) the rectification or update of data; e) the erasure of data or the restriction of data processing (making them anonymous, blocking data that were processed in breach of the law, including data that do not need to be stored for the purposes for which they were collected and subsequently processed).

The Data Subject is also entitled to revoke the consent granted to process personal data. However, revoking such consent shall not affect the legality of the processing that was carried out based on the consent granted prior to such revocation.

The data subject also has the right to data portability.

The data subject is entitled to file a claim with the Supervisory Authority, represented in Spain by the Spanish Data Protection Authority, with registered office at C/ Jorge Juan, 6. 28001 - Madrid.

 

NON-EXISTENCE OF AN AUTOMATED DECISION-MAKING PROCESS

The processing object of this information notice will not be subject to automated decision-making processes.

 

The Data Controller

Arconvert S.A.

 

I state that I have received the information notice about personal data processing and I consent to the processing of my personal data, including confidential data, for the purposes and using the methods specified above.

 

In Girona, on ______________________________________

 

Full name_________________________________________

 

Signature of the Data Subject_________________________

 

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