Privacy

PRIVACY POLICY - INFORMATION ON THE TREATMENT AND PROCESSING OF PERSONAL DATA

GENERAL INFORMATION

Thank you for visiting Turboden website!

Turboden respects your concerns about the privacy of the personal information you may provide to us.

This Privacy Notice is made pursuant to article 12 and 13 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, “General Data Protection Regulation” (hereinafter the “GDPR”), to inform you about the methods of processing of the information and data that may be collected from you as user of this web site (www.turboden.com). This Privacy Notice is made exclusively for this website and does not affect any other websites reached by the user via the links on the same.

We guarantee the security, confidentiality and protection of the personal data in our possession at any stage of the processing process. The personal data collected are processed in accordance with the GDPR.

We invite you to read this Privacy Policy carefully. If you do not agree with the present Privacy Policy, please leave our website.

WHO IS THE DATA CONTROLLER

The Data Controller of the data processing is the company Turboden S.p.A. (hereinafter referred to as “Turboden”, “we”, “us” or “our”), with headquarters in Brescia (Italy), Via Cernaia, 10, phone +390303552001 and dedicated email [email protected].

HOW WE COLLECT YOUR DATA AND WHICH DATA WE COLLECT

AUTOMATIC INFORMATION. When you access our website, the computer systems and software procedures involved in the operation acquire some personal data for which the transmission is implied in the use of the Internet communication protocols. For their very nature, this information could, through processing and association with data held by third parties, allow the identification of users. This data category includes technical data and usage data, such the IP addresses or domain names of the computers used by the users who connect to the web site, URI addresses (Uniform Resource Identifier), the resources required, the time of request, the method used to submit the request to the server, the file size obtained in response, the numeric code indicating the status of the response data from the server (a good outcome, error, etc.) and other parameters related to the operating system and user computing environment.

COOKIES: We automatically collect technical data about your equipment, browsing actions and patterns, using the cookies which use you accept by accessing this website. Please refer to our “cookies policy” for further details.

DATA YOU PROVIDE VOLUNTARILY. If you send is e-mails to the addresses displayed in this website or within the dedicated request modules, we consequently acquire your email address and the other personal data you decide to enter in your message.

This website is not intended for children and we do not knowingly collect data about children.

HOW WE PROCESS YOUR DATA

AUTOMATIC INFORMATION: These data are used only for the purpose of obtaining anonymous statistical information on the use of the site and to check for correct operation. The data could be used for ascertaining responsibility in the case of hypothetical computer crimes against the site. The processing is necessary for the purposes of the legitimate interests pursued, namely to operate, manage the website and keep it updated and relevant.

COOKIES: We collect your technical data based on the consent you give us when you access our website. Please refer to our “cookies policy” for further details.

DATA YOU PROVIDE VOLUNTARILY: The personal data you supply when you submit requests for receiving information are processed for the sole purpose of providing the requested service. To process your data for this specific purpose, we ask you to provide us your consent. When you ask receiving products or services, the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

NEWSLETTER: Turboden uses personal data to send communications via e-mail, mail, and other communication tools related to advertising and business initiatives concerning our technology, references and our products and services. The processing is based on your consent for the specific purpose of receiving the newsletter. You can ask to stop receiving our messages at any time in accordance to opting out procedure displayed in the newsletters.

JOB APPLICATION: Visitors can send letters of application or reply to job offers via the “Work with us" section. Specific information will be displayed and your personal data will be used for the purpose of data processing in accordance with the internal process for HR administration. The processing is necessary in order to take steps at users’ request prior to entering into a contract.

Turboden will retain and process your data for as long as we require it for the purposes for which it was collected or as is otherwise required by applicable law. To determine the appropriate retention period for your personal data, we consider the amount, nature and sensitivity of the personal data, the risk of potential harm from its unauthorised use, alteration or disclosure, the purposes for which we process it, whether we can achieve our purposes through other means, and the applicable legal requirements. Once your personal data is no longer needed, we will securely delete or anonymise it. We may continue to use anonymised data, which cannot be associated with you, for research or statistical purposes.

Your personal data are processed with both manual and automated instruments for the time strictly necessary to achieve the purposes for which they were collected.

DISCLOSURE TO THIRD PARTIES

The processing of data connected to the web services of this website is undertaken by Turboden staff, duly appointed for the treatment, and, with limitation to marketing survey and navigation data, by external technicians for operations of maintenance and management regarding the computerised data.

Regarding the communication of your personal data, the information may be disclosed to the following subjects or categories of subjects in compliance with the specific provisions of the GDPR, for the purposes set out herein: (i) holding companies, associate companies or subsidiaries of Turboden; (ii) other companies bound contractually to Turboden and appointed specifically to process the personal data of the users.

We may also disclose data we collect to third parties (i) if we undergo a change of control or any of our business or assets are sold or transferred (in which case we may disclose your data to the prospective seller or buyer); (ii) if we are under a duty to disclose or share your information in order to comply with any legal obligation or legal process (for example, a court order), or in order to enforce or apply our contractual rights or any other agreement; (iii) in order to protect the rights, property, or safety of our website users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow such third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Turboden will not sell, exchange or otherwise distribute your personal data to unaffiliated third parties without your consent, except to the extent required by applicable laws and regulations, or as set out in this privacy policy.

NON-MANDATORY NATURE OF THE PROVISION OF DATA

Except as specified for the navigation data, the user is free to provide his or her personal data in the request modules, or at any rate to indicate them in order to encourage the receipt of information or other communications. The lack of supply of personal data may, however, lead to the inability to obtain the requested service. The optional, explicit and voluntary submission of electronic e-mail or mail to the addresses indicated on this web site entails the subsequent acquisition of the sender’s address, in order to respond to the requests, and any other personal data included in the communication. Specific summary information will be made for particular services.

RIGHTS OF PARTIES CONCERNED

In some circumstances, you have rights in relation to your personal data we hold. Please write to the Turboden, as Data Controller, at the above address, or by e-mail, specifying the subject of his request, the right you intends to exercise and enclosing a photocopy of an identity document attesting to the legitimacy of the request.

Pursuant to the GDPR you may exercise the following rights:

(Article 15 GDPR) Request access to your personal data (known as "data subject access request"). This enables you to receive confirmation as to whether we process your data and a copy of the personal data we hold about you and to check that we are lawfully processing it.

(Article 16 GDPR) Request rectification of the personal data that we hold about you. This enables you to have any incomplete or imprecise data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(Article 17 GDPR) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(Article 18 GDPR) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

(Article 20 GDPR) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a viable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(Article 21 GDPR) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(Article 7 par. 3 GDPR) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products and/or services to you. We will advise you if this is the case at the time you withdraw your consent.

(Article 13, 2, d) You have also the right to lodge a complaint with a supervisory authority.

You will not usually have to pay a fee to exercise these rights but if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee (or refuse to comply with your request). We may need specific information from you to help us confirm your identity and to speed up our response; this helps keep your personal data safe and speeds up our response to your request.

CHANGES TO INFORMATION

This information may undergo further subsequent changes, also connected to the possible entry into force of new sector regulations, the updating or provision of new services by Turboden or to technological innovations.

In all these cases, amendments and additions to the Privacy Policy may be viewed by all users in the Privacy Policy section of the website and are binding with effect from publication on the website.