INFORMATION PURSUANT TO ARTICLE 13 OF EU REGULATION 2016/679

A – Data controller, data processors and persons authorized to process personal data

Enginius S.r.l. (hereinafter, “Company”, “Organization” or “Owner”), with registered office in Largo Oratorio, 13 – 15076 Ovada (AL) and operational headquarters in Via Scarsellini 119, Torre B – 16149 Genoa, e-mail: info@enginius.com, informs you that the data you provide in relation to existing and/or future legal relationships (as user/interested party) will be processed in compliance with the above-mentioned legislation.

Said processing will be done lawfully and in accordance with the principles set forth in Art. 5 of the EU Regulation 2016/679 (GDPR). Further announcements may be made at a later date, including verbally.

The updated list of external data processors and authorized persons is kept on file by the Company at its registered office.

B – Data subject to processing

Processing of personal data shall mean any operation or set of operations, whether or not by automated means, applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, restriction, erasure or destruction. Specifically, this is data you voluntarily provide for the execution of existing legal relationships with the Data Controller.

Personal data is any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, by reference in particular to an identifier such as a name, an identification number, location data, an online identifier, or one or more characteristic elements of his or her physical, physiological, genetic, mental, economic, cultural or social identity.

The data subject to processing, summarized below by way of example, will be provided by you voluntarily for the execution of existing and/or future legal relationships:

• Full name, registered residence or tax domicile, telephone number, fax number, cell phone number, e-mail address, PEC address, VAT number.

In addition to this, navigation data, computer systems and software procedures responsible for the operation of this website, which may acquire, in the course of their normal operation, your personal data, the transmission of which is implicit in the use of Internet communication protocols. This is, however, information that is not collected to be associated with identified data subjects, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the user’s operating system and computer environment. This data is used for the sole purpose of obtaining anonymous statistical information about the use of the site and to check its correct operation and is deleted immediately after processing. The data could be used to ascertain liability in case of hypothetical computer crimes against the site or requests by the authorities.

C – Purpose of processing

The personal data you provide will be processed for the following purposes:

1. Management of existing and/or future legal relationships;
2. fulfillments related to obligations arising from the above legal relationships;
3. Organizational management of any existing or emerging legal relationships;
4. Fulfilment of regulatory, accounting and/or tax obligations;
5. Protection of contractual rights;
6. Functional purposes of carrying out statistical analysis;
7. Promotion of marketing and commercial communication activities by e-mail, or by telephone, regarding the services provided by the Owner, including through partners. Should you express your consent, your personal data will be made visible and stored in a computerizedCustomer Relationship Management (CRM) archive, as well as possibly stored in one or more special archives or databases of the company that can be accessed by other related companies.

D – Legal basis for processing

With respect to the purposes set forth in items 1 through 6 of paragraph C, the processing is necessary for the performance of a legal relationship to which you are, as well as may be, a party or for the performance of pre-contractual measures taken at your request. The processing is, therefore, lawful (Art. 6, co. 1(b), GDPR).

With reference to the purposes referred to in paragraph 7 above, the processing is optional and therefore subject to your consent in order to be lawful (Art. 6, co. 1 lett. a, GDPR).

E – Duration of treatment

Personal data collected for the purposes set forth in items 1 through 6 of paragraph C will be processed for a period of time not exceeding the fulfillment of the purposes for which they are processed and for the next ten (10) years for legal requirements.

The data related to the purpose in Section 7 will be processed for two (2) years, from the date of their acquisition, unless requested by the data subject. Such data, upon the expiration of that period, will be destroyed.

Personal data contained in documents relevant for administrative-accounting purposes will in any case be retained in compliance with legal obligations.

F – Nature of provision of data

The provision of data is obligatory for purposes 1 to 6 of paragraph C, i.e., to fulfill obligations of a legal nature regarding an established legal relationship and for any other purposes related to legal obligations, regulations and EU regulations. Refusal to provide the data will prevent the Data Controller from fulfilling these obligations and consequently the inability to provide you with the services and/or benefits you have requested.

Providing your data and consenting to its processing for the purposes mentioned in Section 7 of Paragraph C is entirely optional. Failure to consent to the processing or consent to the processing of your personal data for this purpose will result in the impossibility of carrying out promotion activities in the field of marketing and commercial communication by e-mail, or by telephone, regarding the services provided by the Owner, including through partners.

G – Method of data processing 

The data will be processed and stored exclusively for the purposes indicated above through the use of both paper and computer media, entered into relevant databases and processed with appropriate tools to ensure the integrity, security and confidentiality of the data, in accordance with the provisions of the GDPR. All appropriate technical and organizational measures will be taken to ensure a level of data protection that complies with the provisions of the GDPR. Access will be granted only to persons authorized in writing to process personal data. Data may also be communicated and/or collected to/from third parties (such as in cases of data acquisition from processing centers or other Companies). They will be appropriately designated Personal Data Processors and will be involved in the fulfillments required by the existing legal relationship, as well as by specific legal obligations.

H – Social platforms

The website may offer gateways to social networking services and platforms.

Enginius S.r.l. advises exercising caution about the dissemination of personal information on thematic channels through “comments” or “public posts” while using these platforms. The terms of use and privacy policies applicable to each of these means of social communication, posted on their respective sites, govern the information provided. Enginius S.r.l. does not perform any form of control over the use of personal information communicated in a public forum, comment area, or bulletin board, making the user solely responsible for any disclosure. For more specific information about the above, we invite you to visit the social policy section of the site, at the web address https://enginius.com/social-policy/.

I – Cookies

The website https://www.enginius.com/ uses exclusively technical cookies, necessary and functional for the provision of the same, and third-party, which do not allow to collect information about visitors (profiling). For more specific information about the above, we invite you to visit the cookie policy section of the website, at https://enginius.com/cookie-policy/.

L – Disclosure to third parties and/or dissemination of data

For the purposes mentioned in numbers 1 to 6, Enginius S.r.l. Informs you that your data may be disclosed to external parties, designated in writing, if this is necessary to fulfill an obligation under the law, to perform obligations arising from a contract to which you are/will be a party, as well as to fulfill, prior to the conclusion of the contract, your specific requests.

Recipients of communications of personal data of the data subject can also be identified in the following categories of recipients:

• supervisory bodies, judicial authorities, entities, professionals, companies, public administrations or other designated structures for the performance of processing related to the fulfillment of administrative, accounting and management obligations associated with the ordinary course of the Holder’s economic activity (legal obligations);
• banks, financial institutions, freelancers, professional firms and consultants to whom the communication of the above-mentioned data is necessary for the performance of the Holder’s activities and, in particular, in connection with the fulfillment of contractual obligations undertaken towards the data subject (contractual obligations);

The data collected will not be disseminated in any way.

M – Intent to transfer data abroad.

Data will be transmitted only in Italy and within the European Union.

N – Rights under EU Regulation 2016/679

The interested party may, at any time, exercise the rights set forth in Art. 7(3) and Articles 15 et seq. of EU Regulation 2016/679:

1. Right of access to personal data;
2. Right to obtain rectification or cancellation of the same or restriction of processing;
3. Right to object to processing;
4. Right to data portability;
5. Right to withdraw consent, where provided (withdrawal of consent does not affect the lawfulness of processing based on consent given before withdrawal);
6. Right to file a complaint with the supervisory authority (Privacy Guarantor).

O – Identification details of the personal data controller.

The Data Controller for the processing of personal data is Enginius S.r.l. (hereinafter, “Company,” “Organization,” or “Data Controller”), with registered office in Largo Oratorio, 13 – 15076 Ovada (AL) and operational headquarters in Via Scarsellini 119, Torre B – 16149 Genoa, Italy.

A data subject may exercise the rights outlined above by sending an email to: info@enginius.com

Additional information regarding the processing of personal data may also be communicated verbally at the time of data collection.

Genoa, January 17, 2025

The Holder

Enginius Srl.