1. Introduction

The following document is part of the policy provided in accordance with Article 13 of the Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, concerning the protection of natural persons with regard to the processing of personal data, as well as to the free movement of such data (“Regulation”), of the Legislative Decree n. 196 of 2003, as amended by Legislative Decree no. 101 of 10 August 2018 (“Privacy Code”) and other applicable regulations on the protection of personal data.

2. Scope of the Privacy Policy

Neodata Group s.r.l. with registered office in V.le XX Settembre 21 – 95128 Catania (CT), hereinafter referred to as “Neodata”, has among its corporate objectives the protection of users’ privacy.

This document intends to regulate the processing, carried out by Neodata, of the personal data of users who consult or enter their data on the websites: www.neodatagroup.com, blob.neodatagroup.com, hereinafter referred to as “sites”.

The policy is drawn up with reference to EU Regulation 2016/679, with the intention of presenting users with clear information on the processing carried out by Neodata as data controller and refers to the personal data that is collected on the website owned by Neodata.

The Regulation states that, before proceeding with the Processing of Personal Data, it is necessary that the person to whom such Personal Data belongs (“Concerned”) is informed about the reasons for which their Data is requested and how it will be used.

Neodata Group’s websites use cookies. To find out more about it, we invite you to consult our Cookie Policy.

The privacy officer, who can be contacted to exercise the rights under Art. 12 can be reached at privacy@neodatagroup.com.

3. Identity and contact details of the Data Controller

The Data Controller is Neodata Group S.r.l. (hereinafter, “Neodata”), with registered office in Viale XX Settembre, 21 – 95128 Catania.

Neodata Group has provided, Pursuant to art. 37, paragraph 1 letter. a) of the Regulations, the appointment of a DPO (Data Protection Officer) who can be contacted at the email address: dpo@neodatagroup.com for any clarifications regarding the protection of personal data.

Among the tasks that the DPO is called to perform, there are the following:

  1. “Inform and advise the data controller or the data processor as well as the employees who carry out the processing on the obligations deriving from the regulation as well as from other EU or EU Member State’s provisions relating to data protection” (see art. 39, paragraph 1 letter a) of the Regulation)
  2. “Monitor compliance with this Regulation, with other EU or EU Member State’s data protection policies, as well as with the owner’s or controller’s personal data protection policies, including the attribution of the responsibilities, awareness and training of personnel participating in the processing and related monitoring activities “(see Article 39, paragraph 1, letter b) of the Regulation)
  3. “Interested parties may contact the data protection officer for all matters relating to the processing of their personal data and the exercise of their rights deriving from this regulation” (see Article 38, paragraph 4 of the Regulation)

4. Types of Personal Data processed

Neodata processes various types of Personal Data:

So-called “identification” data

This category of Personal Data includes information such as: your name, surname, email address etc. For the collection of such data, we ask you to fill in the appropriate online forms on our websites. The data is collected by filling in forms, it may vary from time to time depending on the form and it is that corresponding to the fields in the completed form.

 

Data collected automatically during your browsing on our webites

This is information such as: the IP addresses (both static and dynamic) or the domain names of the devices used to browse, the URI (“Uniform Resource Identifier”) addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used, etc.

5. Purpose of data processing

The Regulation establishes that anyone who processes Personal Data must have a legitimate reason for doing so and these reasons are known as “legal bases for the processing” (see Article 6 of the Regulation).

 

At any time it is possible to freely revoke the consent given by using the opt-out links on this privacy policy for the various processings.

 

It is also possible to read the Cookie Policy, at the following link https//www.neodatagroup.com/cookiepolicy, in which specific information on the technologies adopted are available.

The purposes of the processing of personal data and on which legal basis such processing is founded are illustrated below:

  • For the operational management of navigation on the Neodata Group websites

The Personal Data collected automatically during your navigation allows the website to function, so that it is possible to actually consult the contents of the website.

  • To manage the security of your data and of Neodata Group domains

To guarantee the security of the information and data processed and to protect the properties of Neodata.

  • For the processing of statistical data

Neodata carries out, also through services provided by third parties, statistical analysis on the use of the contents of its websites. These are analyzes, carried out at an aggregate and, therefore, anonymous level, allow us to understand fundamental aspects related to the use of the websites to improve the quality of their services.

  • Protection or defense of rights in court

To protect or defend our right before a judge, or other competent authorities.

  • Fulfillment of the obligations established by laws or regulations in force, including in accounting and tax matters

To fulfill the obligations imposed by law that involve the processing of the personal data of the interested party for the purposes provided for by the law itself.

  • Provision of the requested services.

Whenever the interested party wishes to use the services offered by the websites such as, for example, applying for a job position, we will process Personal Data to provide what is requested and, therefore, to fulfill contractual obligations.

To subscribe to the newsletter service, this service can only be provided if expressly requested.

 

In particular, we point out, with reference to the following services:

Participation in initiatives promoted by Neodata Group

It is possible to process personal data to allow adherence to initiatives of commercial and social nature promoted by Neodata Group. In this case, the Personal Data processed will be that requested to participate in the specific initiative.

Newsletter

Following consent, Neodata may send commercial or promotional newsletters to the email address provided when registering for this service. You can unsubscribe from the newsletter at any time by clicking on the unsubscribe button that will be located at the bottom of each email.

6. Data recipients

The user’s Personal Data may be disclosed to specific Recipients, to whom the Data is disclosed to allow us to properly carry out all the processing activities illustrated in this document.

 

These Recipients may process Personal Data as:

  • Data Processors or
  • Individuals Authorized for Processing.

 

If required by law or to prevent or suppress the commission of offenses or crimes, your Personal Data may be disclosed to public bodies or judicial authorities without these being considered Recipients (see Article 4 number 9 of the Regulations) and, therefore, without them receiving instructions regarding the processing they will have to carry out.

To obtain more information on the subjects to whom your data may be disclosed, contact us at the email address contained in the Introduction to this document.

7. Data retention period

Without prejudice to all further specific information that has been provided to you in this document with reference to each treatment, we inform you that, in compliance with this principle, we will store your data only for the time necessary to pursue the processing purposes listed in paragraph 5 of this document, without prejudice to any period of time provided for by the relevant sector regulations.

Regarding the processing activities that we carry out on the basis of your consent, we remind you that you can always revoke this consent by requesting us to immediately cease the related processing activities. For more information on the withdrawal of consent, see paragraph 5 of this document.

8. Rights of the interested party

 

The subjects to whom the Personal Data refers have the right at any time to obtain confirmation of its existence from the Data Controller, but also to know its content and origin, to verify its accuracy or request its integration, the cancellation, limitation, updating, rectification, transformation into anonymous form or blocking of Personal Data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, to their Processing. The request can be sent to privacy@neodatagroup.com alongside a document that identifies the requesting person.

 

Access to personal data

The interested party can request confirmation of the existence of data within the Neodata systems with the verification of the purposes for which the consent has been given and also request whether such data has been shared with third parties if required.

Change of personal data

The interested party may request the integration or modification of personal data.

Portability of the data

The interested party can request their personal data, contained in Neodata’s systems, such as personal data as it is collected in the Neodata systems.

Deletion of data

The interested party can request Neodata, that their data is no longer visible within their systems. This right may not be contextual to the cancellation if there are constraints that oblige Neodata to keep the data. Neodata commits to process the user’s request within 30 days of receiving the request.

Change of consent

The processing of personal data carried out by Neodata for the purposes described in this policy is based on the explicit consent of the user. Consent may be requested during the navigation phase of the website as well as during the phase of data-entry in the contact forms. In this sense, the interested party has the right to modify the consents whether they are based on cookies or otherwise using the channels described on this page.

If the user has given consent to profiling and / or geolocation, it is possible to modify these consents through the procedures described on the Web and Cookie Policy and / or through the Opt-in / Opt-Out page.

Neodata does not specifically deal with requests relating to tracking from third parties. To understand and oppose to the use of third-party cookies, please consult the respective privacy policies available on the Web and Cookie Policy.

9. Where the Data is processed

The personal data of the interested parties will be processed by Neodata within the European Economic Area.

10. Changes to this Privacy Policy

Neodata reserves the right to make changes to this Privacy Policy at any time by giving notice to Users on this page. Therefore, please periodically consult this page or section of the website, taking as reference the date of the last modification indicated at the bottom.

In the event of non-acceptance of the changes made to this Privacy Policy, the User is required to cease using the website and may request the Data Controller to remove their Personal Data.

Last Update: 03/01/2022