PRIVACY NOTICE PURSUANT TO ART. 13 OF REGULATION (EU) 2016/679

In relation to the cookies used on this website

The following information is provided to the user in implementation of the directive issued by the Italian Supervisory Authority for the protection of personal data on 8 May 2014 “Identification of simplified procedures for the provision of information and the acquisition of consent for the use of cookies”.

  1. The Data Controller

P.L.S. S.r.l. Professionisti per il Lavoro in Sicurezza

Via Turati n. 26

20121 – Milan (MI) Italy

Telephone number: +39 02 39443190

E-mail address: privacy@gruppopls.com

WHAT ARE COOKIES?

Cookies are text files with small amounts of data that a website can place on your device while you are browsing (whether you use a PC, notebook, smartphone or tablet, cookies are normally stored directly on the browser you are using). The same website that placed them can then read and store the cookies that are on the device being used, in order to obtain various types of information. What kind of information? Let’s have a look at the specific role of each type of cookie.

HOW MANY DIFFERENT TYPES OF COOKIES ARE THERE?

There are two main categories with different characteristics: technical cookies and cookies for profiling purposes.

Technical cookies are generally necessary for the website to work properly and to make browsing possible; without them, you may not be able to view the pages correctly or use certain services. For example, a technical cookie is required to keep you logged in throughout your visit to a website, or to store your language settings, display settings, and so on. Technical cookies can be further divided as follows:

  • Browser cookies, which ensure the website works properly and improve user experience (e.g., allowing users to make a purchase or identifying users who log in to their personal area);
  • Analytical cookies, which are only considered as technical cookies when used directly by the website manager to collect information, in aggregate form, on the number of users and how they visit the site.
  • Functional cookies, which allow the user to browse the website according to a chosen series of criteria (e.g., language settings, products selected for purchase) in order to improve the service provided to the user.

Cookies for profiling purposes are more sophisticated! These cookies serve to produce a user profile in order to display advertisements in line with the preferences expressed by the user while browsing.

Cookies can be further classified as follows:

  • Session cookies: these are immediately deleted as soon as the session ends, i.e., on closing the internet browser.
  • Persistent cookies: unlike session cookies, these remain in the browser for a set period of time. By way of example, they are used to recognise the device that connects to the website, facilitating user authentication.
  • First-part cookies: i.e., cookies generated and managed directly by the webmaster and/or owner of the website which the user is browsing
  • third-party cookies, which are generated and managed by parties other than the webmaster and/or owner of the website that the user is browsing (in some cases by virtue of a contract between the website owner and the third party). Third-party cookies may also include profiling cookies as mentioned and described previously (please refer to the point above for information in relation to this type of cookie, and for the procedure used to obtain free and informed consent prior to activation and operation of the cookies). Detailed, up-to-date information on the use and the relevant expiry dates of third-party cookies can be obtained from the third parties in question, on consulting the specific explanatory pages they provide, which can be accessed, as required, using the links provided in the description of the individual cookies used as well as in the list hereunder.

 

GOOGLE ANALYTICS EXEMPTION FROM LIABILITY

This website also Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). Google Analytics uses cookies, which are text files placed on your computer to help the website analyse the information which these cookies generate about your use of the website (including your IP address). The IP address will be anonymised and Google will not associate the IP address with any other data held by Google. It is possible to prevent the use of cookies by adjusting the applicable settings on your browser. However, please note that if you do this, the website’s full range of functions may not be available. You can also prevent data (cookies and IP address) from being gathered and used by Google by downloading and installing the browser add-on available at:  https://tools.google.com/dlpage/gaoptout?hl=en

Further information on terms and conditions of use and on personal data protection is available at: Global Terms of Service – Google Analytics

Click for an overview of Google’s privacy policy, and to opt out of being tracked by Google Analytics on all websites visited: https://tools.google.com/dlpage/gaoptout?hl=en

As an alternative to the browser add-on or when browsing on mobile devices, you can disable Google Analytics by clicking on one of the following links. An opt-out cookie will be placed on your device which prevents future data collection when visiting this website (this opt-out will only work on the browser in question on your device. If you delete all cookies on your device, but wish to continue to block this website’s tracking activities, you will need to click on the link again).

Here are links to pages on the most popular browsers, in which you can find information on how to disable storage of cookies, or delete cookies already stored on your browser:

The exercise of rights by the data subject

In relation to the personal data which are the subject of this privacy notice, the data subject is entitled to exercise the rights established in the EU Regulation, as detailed hereunder:

  • Right of access by the data subject [art. 15 of the EU Regulation]:the data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the information as expressly provided for in the aforementioned article, including but not limited to the purposes of the processing, the categories of data and recipients, period for which the personal data will be stored, the existence of the right to rectification or erasure of personal data or restriction of processing, the right to lodge a complaint, all available information as to the source of the data, the existence of an automated decision-making process pursuant to Article 22 of the Regulation, as well as the right to obtain a copy of his or her personal data.
  • Right to rectification of Personal Data [art. 16 of the EU Regulation]: the data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her and/or the completion of incomplete data;
  • Right to erasure (”right to be forgotten”) [art. 17 of the EU Regulation]: the data subject shall have the right to obtain the erasure of personal data concerning him or her without undue delay where one of the grounds expressly provided for in the aforementioned article applies, including but not limited to: the personal data are no longer necessary in relation to the stated purposes, the withdrawal of the consent on which the processing is based, objection to the processing where there are no overriding legitimate grounds for the processing, unlawful processing, erasure in compliance with a legal obligation, personal data relating to minors processed without fulfilling the conditions envisaged in Article 8 of the EU Regulation.
  • Right to restriction of processing [art. 18 of the EU Regulation]:in the cases provided for in article 18, including where the processing is unlawful, the accuracy of the data is contested, the data subject objects to the processing and the controller no longer needs the personal data for the purposes of the processing; such personal data shall, with the exception of storage, only be processed with the data subject’s consent or in the other cases envisaged in the aforementioned article.
  • Right to data portability [art. 20 of the EU Regulation]:where processing is based on consent or on a contract, and the processing is carried out by automated means, the data subject shall have the right to receive the personal data concerning him or her in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
  • Right to object [art. 21 of the EU Regulation]:the data subject shall have the right to object to the processing of his or her personal data where there are no overriding legitimate grounds for the processing or where personal data are processed for direct marketing purposes;
  • Right not to be subject to automated decision-making [art. 22 of the EU Regulation]:the data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, (e.g., carried out exclusively by means of digital tools or computer programs).

References to the legislation governing the data subject’s rights 

Article 15 – Rights of access by the data subject

  1. The data subject shall have the right to obtain confirmation from the data controller as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
  2. a) the purposes of the processing;
  3. b) the categories of personal data concerned;
  4. c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  5. d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  6. e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  7. f) the right to lodge a complaint with a supervisory authority;
  8. g) where the personal data are not collected from the data subject, any available information as to their source;
  9. h) the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
  10. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
  11. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
  12. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Article 16 GDPR – Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Article 17 GDPR – Right to erasure (the «right to be forgotten»)

  1. The data 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 have the obligation to erase personal data without undue delay where one of the following grounds applies:
  2. a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  3. b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6 paragraph 1, or point (a) of Article 9 paragraph 2, and where there is no other legal ground for the processing;
  4. c) the data subject objects to the processing pursuant to Article 21 paragraph 1 and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 paragraph 2;
  5. d) the personal data have been unlawfully processed;
  6. e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
  7. f) the personal data have been collected in relation to the offer of information society services referred to in Article 8 paragraph 1.
  8. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
  9. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
  10. a) for exercising the right of freedom of expression and information;
  11. b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  12. c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9 paragraph 2 as well as Article 9 paragraph 3;
  13. d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 paragraph 1 in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  14. e) for the establishment, exercise or defence of legal claims.

Article 18 GDPR – Right to restriction of processing

  1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
  1. a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  2. b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  3. c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
  4. d) the data subject has objected to processing pursuant to Article 21 paragraph 1 pending the verification whether the legitimate grounds of the controller override those of the data subject;
  1. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
  1. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

Article 19 GDPR – Notification obligation regarding rectification or erasure of personal data or restriction of processing

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17 paragraph 1 and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

Article 20 GDPR – Right to data portability

  1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
  2. a) the processing is based on consent pursuant to point (a) of Article 6 paragraph 1 or point (a) of Article 9 paragraph 2 or on a contract pursuant to point (b) of Article 6 paragraph 1; and
  3. b) the processing is carried out by automated means.
  1. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
  2. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
  3. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21 GDPR – Right to object

  1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6 paragraph 1, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
  2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
  4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
  5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
  6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89 paragraph 1, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Article 22 GDPR – Automated individual decision-making, including profiling

  1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
  2. Paragraph 1 shall not apply if the decision:
  1. a) is necessary for entering into, or performance of, a contract between the data subject and a data controller;
  2. b) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
  3. c) is based on the data subject’s explicit consent.
  4. In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
  5. Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9 paragraph 1, unless point (a) or (g) of Article 9 paragraph 2 applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.

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