Privacy

PRIVACY POLICY OF EZER WEBSITE AND DATA PROTECTION OF PERSONAL DATA

1. Foreword

1.1. Personal data protection and corporate social responsibility
EZER recognizes the importance of the right to the processing of personal data of its customers and how they relate to the same, with the awareness that the right to the processing of personal data is a fundamental human right.

In this perspective, which is in line with a steadfast commitment to high standards of Corporate Social Responsibility, EZER sets out in a transparent manner the purposes and the manner in which it carries out the processing of personal data, showing its willingness to cooperate with its Customers and Users of the EZER website, as identified below, to put in place, if required, the useful or necessary operations and to update, correct or delete personal data that may be processed by EZER, in accordance with current legislation and the particular needs of those concerned.

We report, therefore, the following information, to be understood also provided for the issue with the Art. 13 of Legislative Decree no. 196/2003 (the “Code regarding the protection of personal data”). This information is made, as well as in observance of this Code, also in accordance with Recommendation 2/2001 on minimum requirements for the collection of data on-line in the European Union, adopted by the Working Group under art. 29 of Dir. 96/46 / EC.

1.2. EZER website
It should be noted at the outset that, in this disclosure, any reference to the EZER website shall be understood to be implemented by the following sites: www.ezer.it, with the warning that every other site which may be cited verbatim or in which one or more links could be textually present in hypertext form or otherwise, do not belong to EZER, unless otherwise expressly indicated, and, therefore, is not attributable to instruments processing of personal data in the ownership of EZER.

2. Purpose of processing the data

2.1. Information and contacts
EZER, through its website, pursues information relating to the conduct of its business activities. The above information (concerning the description of services offered) are accompanied by an indication of the addresses of EZER, so that the company could be contacted to by those who want to relate or interact with the aforesaid Company (including customers, potential customers, suppliers, employees , etc.) with technological or traditional tools.

With regard to potential customers and to customers, the contact and the information provided on the website of EZER are available to them to make contract proposals or to adhere to the proposals that may be provided by EZER or to have contacts continue their relationship in order to arrive to a more efficient performance of the services, with increased levels of customer satisfaction.

Contact details and information contained on the website are also made available to suppliers or internal and external partners, in order to improve the network of relationships and the efficiency of the contacts.

Other finalities also include that of improving the efficiency of the website, through the indication of the email address of the webmaster, the contacts, to which one can direct voluntarily and optionally, specific communications related to the functionality and the presence of content of that site.

2.2. Known data to the person
Through the indication of the addresses made available to customers and / or users, including the e-mail, EZER can come to know the personal data that are sent to them by those mentioned above. Remember that these data, which are known to the person who presents it, there is still the exemption under Article. 13, co. 2, second sentence, of Legislative Decree no. 196/2003.

2.3. Un supported data by the express consent of the interested
Where the personal information provided should contain sensitive data and / or judicial proceedings and not found having a written consent, these data shall henceforth be deleted and / or destroyed by EZER.

EZER shall handle the personal data of those concerned, even without a expressly manifested consensus, for the cases provided by law, which will be verified by reference to a concrete case, like for eg., In the event that the processing of data is necessary to fulfill legal obligations, regulations or legislation, or is necessary to fulfill obligations arising from a contract to which the subject is a party or to fulfill specific requests that the person remains in pre-contractual stage, or in the additional assumptions set out in ‘art. 24 Legislative Decree no. 196/2003 and in more applicable regulatory requirements. EZER reserves the right to delete, data, also of the third party for which the necessary consent in writing, where requested has not been given.

2.4. Excluded OBJECTIVES
In any case, unless otherwise expressed manifestation of consent by the individual, the personal data collected directly from EZER and for which EZER is the data controller is not used for marketing purposes, to define profiles or personality for sending advertising materials or direct selling or for carrying out market research or commercial communication.

3. Purpose and methods of data processing in relation to certain types of processes

3.1. Technical assistance
In a special section of the website of EZER there is a “form” for the collection of personal data to the User solely to allow the users to request EZER to provide technical assistance services under a contractual relationship which is under progress.

In this case the provision of data marked with an asterisk, freely entered by the customer, is to be considered mandatory for the sole purpose of the treatment on the provision of the requested service. Where the User, who were to fill in the “form” prepared for the request for technical assistance, is not bound by a contractual relationship with EZER, it reserves the right to delete data supplied after sending the completed form of technical asistance, or, alternatively, contact the above user to the address provided on the form in order to process the request for technical assistance in the face of the data provided, which are intended to EZER sent as a pre-contract request in anticipation of art. 24, co. 1, letter. a) since. inc., of Legislative Decree no. 196/2003.

In this case, unless one were to reach an agreement for the provision of services, the personal data provided to EZER in pre-contractual phase these will be deleted and / or destroyed.

In order to improve service and better meet the contractual services, as well as to allow EZER a better fulfillment of its services for the benefit of the customers, the demands of absence may be advanced also through an e-mail address indicated in section site dedicated to contacts (info@ezer.it) or through telephone help desk, the phone numbers are also listed on the site.

3.2. Curricula
EZER does not intend to acquire, using the contact details on its website, any curriculum, unless it has been specifically requested.

Therefore, if EZER, using the contact exposed through its website, would still receive from anyone, spontaneously, curricula containing data of the afore-mentioned parties or interested third parties, EZER will look to either delete and / or destroy them.

Where EZER deemed if fit to require curricula for collaborations or, when there is a need for temporary or permanent recruitment, shall, within one specific section of its website or in the various forms that it considers appropriate, explicitly requests reports in relation to specific and certain professional profiles, whilst communicating the necessary prior information.

4. Methods of data processing

4.1. Instruments and media for the treatment of data
The data processing is carried out with computer systems and computer technology and electronic instruments.

The process is carried out in part on special servers owned by EZER or possibly of altra server farm. In the latter case EZER, pursuant to a contract, it has the exclusive legal availability of the server or servers used, without any disclosure of information to the company providing the service, which is in any case contractually obliged with EZER to take suitable and updated security measures and protection, both physical and logical servers used by EZER.

The data processing is carried out also with computer and telematics systems present at the headquarters of EZER or otherwise using computer owned by the same or, if necessary, in charge of data processing, in compliance with the safety measures required by law and, in any case, of those given by the data.

The data may also take place with non-electronic tools, including the use of paper.

4.2. Operation processes
Processing operations may consist of one or more transactions involving the collection of data, their recording, organizing, storing, retrieving, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication (as specified in the following section 4.3), cancellation and destruction, even apart from their registration in a database.

4.3. Data Communication
The personal information collected by EZER or those which EZER comes into contact during their work may be provided to (or may be the subject of knowledge on the part of) persons in charge and / or data processing, in relation to the specific powers and functions in order to fulfill the above purposes or to engage in regulatory requirements and / or contract.

Normally the data are not communicated or made known to other owners of the data, unless this should not be necessary in compliance with applicable or contractual regulations or to fulfill specific requirements. In this case, the aforementioned data may, in particular, be made aware of the following subjects or the following categories of persons, to the extent that this is necessary for the fulfillment of regulatory and / or contract: a) consultants or employees, internal and / or external, for compliance with applicable law and / or the performance of contractual relations with the individual concerned (employment consultants, legal advisors, accountants, tax consultants, auditors); b) other partner companies of EZER in activities complementary to the services provided to the customer.

4.4. Dissemination of data
In any case the personal information will not be disseminated without the express request of the person, possibly even in the execution of specific contractual provisions with the same person in question. In such cases, the scope of dissemination of the data remains contained within the limits of the request of the agreements or contracts executed.

It is possible, however, that data dissemination can be done by the navigation of the website, but in this case the dissemination of data will be in aggregate and anonymous form, in order to perform statistical surveys about the consultation of the website EZER or part of it.

4.5. Data navigation
The consultation on the website of EZER may result in the automatic processing of data navigated by the User for the sole purpose of making consultation technically possible, as well as to monitor and ensure the proper functioning in relation to the hardware and software used. Although the data processing is carried out to identify the person making the navigation on the website indicated above, however, there is the possibility that it can be traced equally to the identity of the User, these data then are associated with other data provided by EZER or third parties.

Among the data navigated these can be treated as follows: IP numbers of the instruments used by the User; access numbers; page views; access times and free; browser navigation; operating system used by the User; URL visited before accessing the website EZER; numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters regarding the operating system and computer environment.

They cannot be used except for the above purposes, including that of any monitoring anonymously for statistical purposes.

Where such information should be used for statistical purposes, the data relative to the user are treated in aggregate and anonymous form, in order to preserve a high level of protection of the persons concerned (see Point 4.4., Last sentence).

The navigation data could be used, where necessary, to ascertain responsibility in case of computer crimes against the site.

4.6. Cookies
4.6.1. “Persistent” Cookies
On the website of EZER there is no use of cookies cd “Persistent” for the transmission of personal data.

4.6.2. “Session” Cookies
It is possible, however, that use is made of cookies cd “Session”, consisting of small strings of text sent electronically on the User’s computer, which are not stored permanently, but disappear when the browser is closed. The use of cookies, “session” is intended to allow safe and efficient navigation of the website EZER and is limited only to the transmission of session identification codes, consisting of random numbers generated by the server.
THE SO-CALLED Session cookies used in this site avoid the use of other technologies that could compromise the privacy of the users and not allow the acquisition of personal identification data.

4.7. E-mail
If communication is forwarded via e-mail to e-mail addresses on the Internet site of EZER, it will automatically capture data for the e-mail addresses contained in the message, as well as any other personal data included in that notice.

The data relating to e-mail addresses is also processed in order to prepare any replies.

4.8. Reserved area
On the website of EZER a special reserved area is also planned, access to which is possible by entering an identification code and password, this allows EZER and those in charge of data processing to perform the necessary operations to deliver and manage services and to manage and maintain the entire information and communications system.

Access to the reserved area is also allowed to customers who have previously received specific personal authentication credentials in order to access the services required to EZER and by the latter provided.

By accessing the restricted area, the system can collect and process information related to the timing and methods of access and the operations performed. In this case the process is aimed exclusively to the management of the service offered and to maintaining system security.

5. Nature of provision

The provision of concerned personal data is optional, except in cases where, in the presence of a form, the field related to data entry is marked with asterisks. In such cases the transfer of the data is to be considered mandatory.

The automatic processing of navigation data is obligatory, the data related to access and visits in the restricted area and the data related to the request for technical assistance and contractual.

6. Consequences of Refusal

The failure to provide optional data will not in any case affect the requested services to EZER.

Where the provision of data is to be considered mandatory, in relation to the provisions in paragraph 5, the failure to provide the same, or to consent to treatment, may result in the inability, by EZER, to provide the service or to provide performance or response that are requested to it.

7. Rights of Interested parties

Interested parties, to which the personal data processed by EZER, shall enjoy the rights under Art. 7 of Legislative Decree no. 196/03 (“Code for the Protection of Personal Data”), and, in particular, have the right to obtain confirmation of the existence of personal data concerning them, even if not yet recorded, and their communication in intelligible form.

They also have the right to obtain information concerning the origin of these data, the purposes and methods of treatment, the logic of the treatment, the identity of the owner and manager where designated, of subjects or categories of persons to whom the data may be communicated. They also have the right to obtain the updating, rectification and integration, where there is an interest. They also have the right to verify the accuracy and to request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, and to oppose in any case, for legitimate reasons, to their treatment.

Requests may be made to EZER, as specified in paragraph 8 below.

8. Owner and Manager of process. Response to the interested parties

8.1. Tenure of treatment
Holder of the processing of personal data is now EZER, with registered office at (00142) Roma to Via F. Giacomelli, 45.

8.2. Provision of acknowledgment of requests of the interested parties and contacts
EZER also carries out functions of one who controls processes, including having as a scope the provision to provide for the interested parties the possibility to exercise the rights under Art. 7 of Legislative Decree no. 196/03 (“Code regarding the protection of personal data”).

EZER is therefore possible to send any request, clarification or feedback on the implementation of legislation on protection of personal data and for the effective exercise of the rights of, best indicated in paragraph 7 above, even if it becomes necessary to ensure updating, modification, integration, correction and / or deletion of data, as required by the provision of the law or in relation to the assessment of specific needs explicitly envisaged by the person concerned. To this end, in order to facilitate that the interested parties exercise their rights and in order to interact with the EZER as regards all operations indicated earlier, we provide the following contact information to contact in case of need: tel. 06.48789114, e-mail: info@ezer.it; Internet address: www.ezer.it; geographical address (at the headquarters): 00142 Rome (RM), Via F. Giacomelli, 45.