Privacy policy

TRANSPARENCY AND LEGALITY

Information pursuant to art. 13 of the Regulation (EU) n. 679/2016 (“GDPR”) SINTEL ENGINEERING S.r.l. protects the confidentiality of personal data and ensure that they have the necessary protection from any event that could put them at risk of violation. As required by the European Union Regulation no. 679/2016 (“GDPR”), and in particular to the art. 13, below we provide the user (hereinafter “Concerned”) the information required by law concerning the processing of their personal data. Who we are and which data we treat (article 13, paragraph 1 letter a, article 15, letter b GDPR) SINTEL ENGINEERING S.r.l., in the person of its legal representative, based in Rome (RM), Via Giacomo Carissimi n. 37 / A, operates as Data Controller and can be contacted at info@sinteleng.it and collects and / or receives information concerning the interested party, such as:

TYPES OF DATA                                 DESCRIPTION
Biographical data name, surname, physical address, nationality, province and municipality of residence, landline and / or mobile phone, fax, tax code and / or VAT number, e-mail address and / or pec address
Banking data IBAN bank details and bank / postal data (except credit card number)
Data of electronic traffic IP address of origin, Log

SINTEL ENGINEERING S.r.l. does not require the Data Subject to provide data c.d. “Particulars”, i.e. as provided for the GDPR (Article 9), personal data revealing racial or ethnic origin, political opinions, religious or philosophical convictions, or union membership, as well as genetic data, data biometrics designed to uniquely identify a natural person, data relating to a person’s health or sexual life or sexual orientation. In the event that the performance requested by SINTEL ENGINEERING S.r.l. impose the processing of such data, the interested party receive prior notice and will be required to give appropriate consent. For what purposes we need the party’s data (Article 13, paragraph 1 of the GDPR) The data are used by the Data Controller to follow up the registration request and the contract for the supply of the selected Service and / or the purchased Product, manage and execute the contact requests sent by the Interested Party, provide assistance, comply with legal and regulatory obligations. which the holder is kept in function of the activity exercised. In no case is SINTEL ENGINEERING S.r.l. resells the personal data of the interested party to third parties or uses them for undeclared purposes. In particular the data of the interested party will be processed for: Registration and contact requests and / or information material. The processing of personal data of the interested party takes place to carry out the preliminary activities and consequent to the registration request, to the management of requests for information and to contact and / or sending information material, as well as for the fulfillment of any other obligation arising. The legal basis of these treatments is the fulfillment of the services inherent to the request for registration, information and contact and / or sending of informative material and compliance with legal obligations. The management of the contractual relationship.The processing of personal data of the interested party takes place to carry out preliminary activities and consequent to the purchase of a Service and / or a Product, the management of the related order, the provision of the Service itself and / or production and / or the shipment of the purchased Product, the related invoicing and management of the payment, the handling of complaints and / or reports to the assistance service and the provision of the assistance itself, the prevention of fraud and the fulfillment of any other obligation arising from the contract. The legal basis of these treatments is the fulfillment of the services inherent in the contractual relationship and compliance with legal obligations. Promotional activities on services/products similar to those purchased by the person concerned (Recital 47 GDPR). The data controller, even without your explicit consent, may use the contact details provided by the Interested Party, for the purpose of direct sale of their Services / Products, limited to the case in which the Services / Products are similar to those under sale, unless the interested party explicitly oppose. The trade promotion activities on different services of those of the party. The personal data of the interested party may also be processed for purposes of commercial promotion, for surveys and market research with respect to Services / Products that the Holder offers only if the Data Subject has authorized the processing and does not oppose to this. This treatment can be automated, in the following ways: e-mail; – sms; – telephone contact and can be carried out: 1. if the interested party has not revoked his consent for the use of the data; 2. if, in the event that the processing takes place through contact with the telephone operator, the interested party is not registered in the register of oppositions referred to in the D.P.R. n. 178/2010; The legal basis for such processing is the consent given by the prior interested party, who can be revoked by the interested party freely and at any time. IT security. The Owner, in line with the provisions of Recital 49 of the GDPR, treats, also through its suppliers (third parties and / or recipients), the personal data of the interested party relating to traffic to a strictly necessary and proportionate extent to ensure the security of networks and information, ie the ability of a network or an information system to resist, at a given level of security, unforeseen events or illicit or malicious acts that compromise availability, authenticity, integrity and confidentiality of personal data stored or transmitted. The Data Controller will promptly inform the Interested parties, if there is a particular risk of violation of their data without prejudice to the obligations arising from the provisions of art. 33 of the GDPR concerning notifications of violation of personal data. The legal basis of these treatments is compliance with legal obligations and the legitimate interest of the Data Controller to carry out processing related to the protection of the company assets and security of the headquarters and systems of SINTEL ENGINEERING S.r.l Profiling. The personal data of the party may also be processed for purposes of profiling (such as analysis of the transmitted data and the selected Services / Products, proposing advertising messages and / or commercial proposals in line with the choices expressed by the users themselves) exclusively in the case which the interested party has provided an explicit and informed consent. The legal basis of such processing is the consent given by the interested party prior to the processing itself, which can be revoked by the interested party freely and at any time. Fraud prevention (recital 47 and Article 22 of the GDPR). The personal data of the interested party, with the exclusion of those particular (Art 9 GDPR) or judicial (Art 10 GDPR) will be processed to allow controls for the purpose of monitoring and preventing fraudulent payments, by software systems that carry out a verification in order automated and preliminary to the negotiation of Services / Products; exceeding these checks with a negative result will make it impossible to carry out the transaction; the interested party may in any case express his opinion, obtain an explanation or challenge the decision, motivating his / her reasons to contact info@sinteleng.it; personal data collected for the sole purpose of anti-fraud, unlike the data necessary for the correct execution of the requested service, will be immediately canceled at the end of the control phases. Protection of minors. The Services / Products offered by the Data Controller are reserved to subjects legally able, on the basis of the national reference legislation, to conclude contractual obligations. The Data Controller, in order to prevent illegal access to its services, implements prevention measures to protect its legitimate interest, such as the control of the tax code and / or other checks, when necessary for specific Services / Products, the correctness of the data identification of identity documents issued by the competent authorities. Communication to third parties and categories of recipients (Article 13, paragraph 1 of the GDPR). Communication of personal data of the interested party takes place principally towards third parties and / or recipients whose activity is necessary for the performance of the activities related to the relationship established and to meet certain legal obligations, such as:

CATEGORIES JUSTIFICATION
Providers* Services provision (assistance,maintenance,delivery / delivery of products, provision of additional services, network providers and electronic communication services) related to the requested service
Professionals and advisor Fulfillment of legal obligations, exercise of rights, protection of contractual rights, recovery of credit
The credit institutes and digital payment Collections management, payments, refunds related to the contractual performance
Financial administration, public bodies, judicial authorities, supervisory authorities and control Compliance with legal obligations, defense of rights; lists and registers held by public authorities or similar bodies on the basis of specific legislation, in relation to the contractual performance.

* The Data Controller imposes on the Third Party its suppliers and the Data Processors the respect of security measures equal to those adopted towards the interested party, restricting the perimeter of action of the Manager to the treatments related to the requested service. The Data Controller does not transfer your personal data to countries where the GDPR (non-EU countries) is not applied, unless there are specific indications to the contrary for which you will be informed in advance and your consent will be requested if necessary. The legal basis of these treatments is the fulfillment of the services inherent to the relationship established, compliance with legal obligations and the legitimate interest of SINTEL ENGINEERING S.r.l. to carry out treatments necessary for these purposes. What happens if the Data Subject does not provide his data identified as necessary for the execution of the requested service? (Article 13, paragraph 2, letter and GDPR) The collection and processing of personal data is necessary to follow up the requested services as well as the provision of the Service and / or the supply of the requested Product. If the Data Subject does not provide the personal data expressly provided for as necessary in the order form or the registration form, the Data Controller will not be able to process the processing of the requested services and / or the contract and the Services / Products connected to it, or to the obligations that depend on them. What happens if the Data Subject does not give consent to the processing of personal data for commercial promotion activities on Services / Products different from those purchased? In case the party does not give his consent to the processing of personal data for such purposes, said processing will not take place for the same purposes, without this having effects on the provision of services requested, nor for those for which he has already consent if requested. In the event that the interested party has given consent and should subsequently withdraw or oppose the treatment for commercial promotion activities, his data will no longer be processed for such activities, without this having consequences or detrimental effects for the interested party and for the requested services. How we process the data of the interested party (Article 32 GDPR) The Data Controller provides for the use of adequate security measures to preserve the confidentiality, integrity and availability of the personal data of the interested party and imposes similar security measures on third parties and on the Managers. Where we process the data of the interested party The personal data of the interested party are stored in paper, computer and electronic archives located in countries where the GDPR (EU countries) is applied. How long are the data of the interested party stored? (Article 13, paragraph 2, letter to GDPR) Unless he expressly expresses his will to remove them, the personal data of the interested party will be kept until they are necessary with respect to the legitimate purposes for which they were collected. In particular, they will be kept for the entire duration of their registration and in any case no longer than a maximum period of 12 (twelve) months of inactivity, or if, within this period, no Services and / or purchased Products are associated the registry itself. In the case of data provided to the Owner for the purposes of commercial promotion for services other than those already acquired by the Data Subject, for which he initially consented, these will be retained for 24 months, subject to revocation of the consent given. In the case of data provided to the Owner for the purposes of profiling, these will be retained for 12 months, unless revocation of consent given. It should also be added that, in the event that a user sends to SINTEL ENGINEERING S.r.l. personal data not requested or not necessary for the execution of the requested service or for the provision of a service closely connected to it, SINTEL ENGINEERING S.r.l. can not be considered owner of these data, and will delete them as soon as possible. Regardless of the determination of the interested party to their removal, the personal data will in any case be kept according to the terms established by the current legislation and / or by national regulations, for the sole purpose of guaranteeing specific and contractual obligations. Furthermore, personal data will in any case be kept for the fulfillment of the obligations (eg fiscal and accounting) that remain even after the termination of the contract (Article 2220 of the Civil Code); for these purposes the Data Controller will retain only the data necessary for the relative prosecution. Except in cases where the rights deriving from the contract and / or registration, in which case the personal data of the interested party, exclusively those necessary for such purposes, will be processed for the time necessary to their pursuit. What are the rights of the interested party? (Articles 15 – 20 GDPR) The interested party has the right to obtain from the data controller the following: a) Confirmation that the processing of personal data concerning him or her is in progress and, if so, to obtain access to personal data and the following information: 1. the purposes of the processing; 2. the categories of personal data in question; 3. the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if recipients of third countries or international organizations; 4. when possible, the retention period of the personal data provided or, if not possible, the criteria used to determine this period; 5. the existence of the right of the data subject to request the data controller to rectify or delete personal data or limit the processing of personal data concerning him or to oppose their treatment; 6. the right to lodge a complaint with a supervisory authority; 7. if the data are not collected from the data subject, all information available on their origin; 8. the existence of an automated decision-making process, including profiling, and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the data subject; 9. the appropriate guarantees provided by the third country (non-EU) or an international organization to protect any data transferred; b) the right to obtain a copy of the personal data being processed, provided that this right does not affect the rights and freedoms of others; In case of further copies requested by the interested party, the data controller may charge a reasonable fee contribution based on administrative costs. c) the right to obtain from the data controller the correction of inaccurate personal data concerning him without undue delay. d) the right to obtain from the data controller the cancellation of personal data concerning him without undue delay, if the reasons provided for by the GDPR in art. 17, among which, for example, in the case in which they are no longer necessary for the purposes of the processing or if this is assumed to be illegal, and the conditions provided for by law still exist; and in any case if the treatment is not justified by another equally legitimate reason. e) the right to obtain from the data controller the limitation of processing, in the cases provided for by art. 18 of the GDPR, for example where you have challenged its accuracy, for the period necessary for the Data Controller to verify its accuracy. The interested party must be informed, in reasonable time, also of when the suspension period has been completed or the cause of the limitation of the treatment has ceased, and therefore the limitation itself revoked; f) the right to obtain communication from the holder of the recipients to whom the requests for any corrections or cancellations or limitations of processing have been transmitted, unless this proves impossible or involves a disproportionate effort. g) the right to receive personal data concerning him in a structured, commonly used and automatically readable format, and the right to transmit such data to another data controller without impediments by the data controller who provided them , in the cases provided for by art. 20 of the GDPR, and the right to obtain direct transmission of personal data from one controller to another, if technically feasible. For any further information and in any case to send your request you must contact the Owner at info@sinteleng.it. In order to ensure that the rights mentioned above are exercised by the Data Subject and not by unauthorized third parties, the Data Controller may request the same to provide any additional information necessary for the purpose. How and when can the data subject oppose the processing of personal data? (Article 21 GDPR) For reasons relating to the particular situation of the interested party, the same may oppose at any time the processing of their personal data if it is based on legitimate interest or if it takes place for business promotion, by sending the request to the owner at info @ sinteleng .com. The interested party has the right to cancel his / her personal data if there is no legitimate overriding reason for the Data Controller than the one giving rise to the request, and in any case in case the Data Subject opposes the processing for commercial promotion activities. To whom can the interested party submit a complaint? (Article 15 GDPR) Without prejudice to any other action in administrative or judicial, the interested party may lodge a complaint with the competent supervisory authority on the Italian territory (Authority for the protection of personal data) or the one carrying out its duties and exercising its powers in the Member State where the GDPR violation took place. Each update of this Information will be promptly communicated and by means of reasonable means and will also be communicated if the Data Controller processes the data of the Data Subject for further purposes than those referred to in this Notice before proceeding and following the manifestation of the relative consent of the ‘Interested if necessary. COOKIES General information, Cookies are data that are sent from the website and stored by the internet browser on the computer or other device (for example, tablet or mobile phone) of the user. Technical cookies and third-party cookies may be installed on our website or by sub-domains. In any case, the user can manage, or request general deactivation or cancellation of cookies, modifying the settings of his internet browser. This deactivation, however, may slow down or prevent access to some parts of the site. The settings to manage or disable cookies may vary depending on the internet browser used, therefore, for more information on how to perform such operations, we suggest you to consult the manual of your device or the “Help” function or “Help” of your internet browser. Below are the links to the Users that explain how to manage or disable cookies for the most popular Internet browsers:

  • Internet Explorer: http://windows.microsoft.com/it-IT/internet-explorer/delete-manage-cookies
  • Google Chrome: https://support.google.com/chrome/answer/95647
  • Mozilla Firefox: http://support.mozilla.org/it/kb/Gestione%20dei%20cookie
  • Opera: http://help.opera.com/Windows/10.00/it/cookies.html
  • Safari: https://support.apple.com/kb/PH19255

Technical cookies The use of technical cookies, that is cookies necessary for the transmission of communications on the electronic communication network or cookies strictly necessary to the supplier to provide the service requested by the customer, allows the safe and efficient use of our site. Session cookies may be installed in order to allow access to and access to the reserved area of ​​the portal as an authenticated user. Technical cookies are essential for the proper functioning of our website and are used to allow users normal browsing and the opportunity to take advantage of the advanced services available on our website. The technical cookies used are distinguished in session cookies, which are stored exclusively for the duration of navigation until the browser is closed, and persistent cookies that are saved in the user’s device memory until their expiration or cancellation by the user same. Our site uses the following technical cookies:

  • Technical browsing or session cookies, used to manage normal browsing and user authentication;
  • Functional technical cookies, used to store customizations chosen by the user, such as, for example, the language;
  • Technical analytics cookies, used to know the way in which users use our website so as to be able to evaluate and improve the functioning.

Third-parties cookies Third-party cookie may be installed: these are cookies, analytical and profiling, Google Analytics, Google Doubleclick, Criteo, Rocket Fuel, Youtube, Yahoo, Bing and Facebook. These cookies are sent from the websites of the aforementioned third parties external to our site. The analytical cookies of third parties are used to detect information on the behavior of users on the site. The survey takes place anonymously, in order to monitor the performance and improve the usability of the site. The third-party profiling cookies are used to create profiles related to users, in order to propose advertising messages in line with the choices expressed by the users themselves. The use of these cookies is governed by the rules set by the third parties themselves, therefore, users are invited to view the privacy policies and indications to manage or disable cookies published on the following web pages: For Google Analytics cookies: – privacy policy: https://www.google.com/intl/it/policies/privacy/ – indications to manage or disable cookies: https://support.google.com/accounts/answer/61416?hl=it For Google Doubleclick cookies: – privacy policy: https://www.google.com/intl/it/policies/privacy/ – directions to manage or disable cookies: https://www.google.com/settings/ads/plugin For Criteo cookies: – privacy policy: http://www.criteo.com/it/privacy/ – indications to manage or disable cookies: http://www.criteo.com/it/privacy/ For Facebook cookies: – privacy policy: https://www.facebook.com/privacy/explanation – indications to manage or disable cookies: https://www.facebook.com/help/cookies/ For CrazyEgg cookies: – privacy policy: https://www.crazyegg.com/privacy/ – indications to manage or disable cookies: https://www.crazyegg.com/cookies/ For Rocket Fuel cookies: -privacy policy: http://rocketfuel.com/it/privacy/ – indications to manage or disable cookies: http://rocketfuel.com/it/cookie-policy/ For Youtube cookies: -privacy policy: https://www.youtube.com/intl/it/yt/about/policies/#community-guidelines – indications to manage or disable cookies: https://support.google.com/accounts/answer/61416?hl=it For Yahoo cookies: -privacy policy and indications to manage or disable cookies: https://policies.yahoo.com/ie/it/yahoo/privacy/euoathnoticefaq/ For Bing cookies: -privacy policy and instructions to manage or disable cookies https://privacy.microsoft.com/it-it/privacystatement Profiling cookies They can be installed by the Owner (s) using the software of c.d. web analytics, profiling cookies, which are used to prepare detailed and real-time analysis reports on information about: visitors to a website, search engines of origin, keywords used, language of use, most visited pages. The same can collect information and data such as IP address, nationality, city, date / time, device, browser, operating system, screen resolution, navigation source, pages visited and number of pages, duration of the visit, number of visits. Such data may be transferred to SINTEL ENGINEERING, in compliance with and with the limitations imposed by current legislation and the provisions of this Information.