1) Introduction

EUROPARTNERS SRL takes the user’s privacy seriously and undertakes to respect it. This privacy policy (“Privacy Policy”) describes the personal data processing activities performed by
through its website and the relevant
commitments undertaken by the Company in this regard. The policy is not to be considered valid for
other websites that may be consulted through links on the owner’s domain website, which is not to be
considered in any way responsible for t he websites of third parties.

Where required by EU Reg. 2016/679, the user’s consent will be requested before processing his/her personal data. If the user provides personal data of third parties, he/she must ensure that the communication of the data to EUROPARTNERS SRL and the subsequent processing for the purposes specified in the applicable privacy policy is in accordance with EU Reg. 2016/679 and the applicable legislation.

2) Identification details of the data controller

The Data Controller is EUROPARTNERS srl with head office in Rome VIA CARDINAL DE LUCA, 1


3) Type of data processed

Visiting and consulting the WEB Site does not generally involve the collection and processing of the
user’s personal data, excep
t for navigation data and cookies as specified below. In addition to the so called “surfing data” (see below), personal data voluntarily provided by the user when interacting with the functionalities of the WEB Site or asking to use the services offered on the WEB Site may be processed. In compliance with the Privacy Code, EUROPARTNERS SRL may also collect the user’s personal data from third parties in the course of its business. The WEB Site may contain links to other sites (so called third party sites). EUROPARTNERS SRL does not have any access to or control over cookies, web beacons and other user tracking technologies that may be used by third party sites that the user may access from the website; EUROPARTNERS SRL does not have any control over the contents and mate rials published by or obtained through third party sites, nor over the relevant methods of processing the user’s personal data, and expressly disclaims any responsibility for such eventualities. The user is required to check the privacy policy of third party sites accessed through the WEB Site and to inform himself about the conditions applicable to the processing of his personal data. This Privacy Policy applies only to the WEB Site as defined above.

4) Processing methods and period of storage of personal data

Personal data are stored and processed through computer systems own ed by EUROPARTNERS SRL or by third party technical service providers. The data is processed exclusively by specifically authorised personnel, including personnel in charge of extraordinary ma intenance operations. Your personal data will be stored for the duration of the contract and after the end of the contract in order to fulfil EUROPARTNERS SRL‘s legal obligation, including claims, in accordance with applicable law, and will then be deleted or made anonymous. The processing of your personal data is carried out by means of the operations indicated in art. 4 Privacy Code and art. 4 n. 2) GDPR and precisely: collection, recording, organization, storage, consultation, processing, modification, s election, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is processed both on paper and electronically and/or automatically, through the use of websites hosted on the data controller’s server or on websites of external companies that enable the data controller to offer its services. The Data Controller shall process personal data for the time necessary to fulfil the above purposes and in any case for no longer than 10 years fro m the termination of the relationship for service purposes and for no longer than 2 years from the collection of the data for other purposes. In compliance with the provisions of art. 5, paragraph 1, letter e) of EU Reg. 2016/679, the personal data collected will in any case be stored in a form that allows the identification of the persons concerned for a period of time not exceeding the achievement of the purposes for which the personal data are processed.

5) Purposes and methods of data processing

EUROPARTNERS SRL may process your common and personal data for the following purposes

  • managing and maintaining the Site or allowing you access to dedicated areas;
  • to allow you to use the Services you may have requested;
  • to guarantee you access to programmes and services;
  • to offer you assistance and advice, also remotely;
  • process a contact request;
  • for administrativeaccounting activities in general;
  • to comply with the obligations provided for by the Law, by a regulation, by the Community legislation
    or by an order of the Authority or upon requests of the Italian or foreign government or of the Italian
    Chamber of Commerce;
  • prevent or discover fraudulent activities or abuses harmful to the Site;
  • exercise the rights of the Data Controller, for example the exercise of a right in a court of law.

6) Security and quality of personal data

EUROPARTNERS SRL undertakes to protect the security of the User’s personal data and complies with the security provisions provided for by the applicable regulations in order to avoid loss of data, illegitimate or unlawful use of data and unauthorised access to the same, with particular refere nce to the Technical Regulations concerning minimum security measures. EUROPARTNERS SRL uses a number of advanced security technologies and procedures to favour the protection of users’ personal data; for example, personal data are stored on secure servers located in places with protected and controlled access. The user can help EUROPARTNERS SRL to update and keep his/her personal data correct by communicating any changes regarding his/her address, qualification, contact information, etc.

7) Data communication and access

The user’s personal data may be communicated to:

  • all subjects whose right to access such data is recognised by virtue of regulatory provisions;
  • to our collaborators, employees, within the scope of their duties;
  • to all those physical and/or juridical, public and/or private persons when the c ommunication is necessary or functional to the development of our activity and in the ways and for the purposes illustrated above. Without your express consent (ex art. 24 lett. a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes of art. 2) to Supervisory Bodies and Judicial Authorities, as well as to all other subjects to whom communication is mandatory by law. We assure you, however, that your personal data will never be made public on the Owner’s website.

8) Data transfer

The management and storage of personal data will take place in Europe, on servers located in Italy of the Data Controller and/or third party companies, also abroad, appointed and duly designated as Data Processors for the use of the services requested. The personal data provided may be transferred abroad within and outside the European Union, within the limits and under the conditions set out in Articles 44 et seq. of EU Regulation 2016/679, in order to comply with pur poses related to the transfer itself.

9) Type of the provision of data and consequences of refusal to answer

The provision of data for the purposes referred to in art. 2 is mandatory. Without it, we will not be able to guarantee registration on the Site or the Services. You may therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided. In any case, you will continue to be entitled to the Services referred to in Article 2.

10) Rights of the data subject

10.1 Art. 15 (right of access), 16 (right of rectification) Reg. UE 2016/679

The subject shall have the right to obtain from the controller confirmation as to whether or not personal data relating to him are being processed and, if so, to obtain access to the personal data and the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular to recipients in third countries or international organisations (d) the proposed period for which the personal data will be stored or, if that is not possible, t he criteria used to determine that period (e) the existence of the right of the data subject to request from the controller the rectification or erasure of personal data or the restriction of the processing of personal data concerning him or her or to object to the processing of personal data concerning him or her (f) the right to lodge a complaint with a supervisory authority; (g) the existence of an automated decisionmaking process, including profiling and, at least in such cases, meaningful information on the logic used, as well as the importance and the envisaged consequences of such processing for the data subject.

10.2 Right under Article 17 of EU Reg. 2016/679 right to erasure (“right to be forgotten”)

The subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall be obliged to erase the personal data without undue delay if any of the following grounds applies: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) the data subject withdraws the consent on which the processing is based and if there is no other legal basis for the processing; (c) the data subject objects to the processing pursuant to Article 21(1) and there is no overriding legitimate ground for processing, or objects to the processing pursuant to Article 21(2); (d) the personal data have been unlawfully processe d; (e) the personal data must be erased in order to comply with a legal obligation laid down by Union or Member State law to which the controller is subject; (f) the personal data have been collected in connection with the provision of information society services as referred to in Article 8(1) of EU Reg. 2016/679.

10.3 Right referred to in Article 18 Right to restriction of processing

The subject shall have the right to obtain from the data controller the restriction of processing when one of the following cases occurs: (a) the data subject contests the accuracy of the personal data, for the period necessary for the controller to verify the accuracy of such personal data; (b) the processing is unlawful and the data subject objects to the erasure of th e personal data and requests instead that their use be restricted (c) although the controller no longer needs the personal data for processing purposes, the personal data are necessary for the establishment, exercise or defence of legal claims by the data subject; (d) the data subject has objected to the processing pursuant to Article 21(1) of EU Reg 2016/679 pending verification as to whether the legitimate reasons of the controller over ride those of the data subject

10.4 Right referred to in Article 20 Right to data portability

The data subject shall have the right to receive in a structured, commonly used and machine readable format personal data concerning him or her that has been provided to a data controller and s hall have the right to transmit such data to another data controller without hindrance by the data controller

11. Revocation of consent to processing

The interested party may revoke consent to the processing of his/her personal data by sending a registered letter with return receipt to the following address: EUROPARTNERS SRL, Via Cardinal De Luca n. 1 00196 Rome accompanied by a photocopy of your identity document, with the following text: <<revocation of consent to the processing of all my personal data>> or by email to the following address:
the end of this operation, your personal data will be removed from the archives as soon as possible.

12. Changes to this policy

This Policy may be subject to change. We therefore recommend that you check this Policy regularly and refer to the most uptodate version.