Cookie policy

WHAT ARE COOKIES? WHAT ARE COOKIES USED FOR? For more information about the cookies used by this website see the cookies policy in the footer.

1. WHO IS THE DATA CONTROLLER? HOW TO CONTACT HIM? The Data Controller is CINIUS S.r.l., with registered office in Via Edoardo Collamarini 25, Bologna(BO), in the person of its pro-tempore Legal Representative, who can be contacted for any information by e-mail privacy@cinius.com

2. HAS THE DATA PROTECTION OFFICER BEEN APPOINTED? WHAT ARE HIS OR HER CONTACT DETAILS? Cinius S.r.l. has appointed its own Data Protection Officer (DPO/DPO- Data Protection Officer) in accordance with Articles 37, 38 and 39 of the GDPR. The DPO can be reached at the Owner’s office listed above and via e-mail privacy@cinius.com

3. PURPOSE OF PROCESSING, LEGAL BASIS, DATA RETENTION PERIOD, AND NATURE OF PROVISION OF DATA

3.1 Purposes of NAVIGATION ON THIS WEBSITE The data required to use the web services are processed in order to: – obtain statistical information on the use of the services (most visited pages, number of visitors per time slot or daily, geographical areas of origin, etc.); – check the correct functioning of the services offered. The data will be used to ascertain responsibility in case of hypothetical computer crimes against the site. Legal basis: The processing is necessary for the pursuit of the legitimate interest of the data controller or third parties, provided that the interests or the fundamental rights and freedoms of the data subject requiring the protection of personal data do not prevail, taking into account the reasonable expectations of the data subject and the activities strictly necessary for the operation of the site and navigation itself (Art. 6, para. 1 lett. f and C47 of the GDPR). Period of storage: The storage of navigation data is up to the duration of the browsing session and in any case they do not persist for more than 7 days (except for any need to ascertain crimes by the Judicial Authority). Nature of conferment: The conferment of data is necessary for the navigation of the website. 3.2 Purpose related to the use of cookies and comparable technology. Legal basis: the processing is based on consent to the processing of personal data (Art. 6 par. 1 letter a and C42, C43 of the GDPR). For the nature of the conferment and the storage period See the cookie policy in the footer of the site. In addition to navigation: A) Personal data will be processed, according to the individual data collection area for the management of the requested service and related activities for:

3.A.I. Purposes of CONTACT MANAGEMENT The processing is related to sending contact requests, information. Legal Basis: The processing is necessary for the performance of a contract to which the data subject is a party or the execution of pre-contractual measures taken at the request of the data subject; (C44) art. 6 par. 1 lett. b) of the GDPR. Storage period: The storage period is 5 years. Nature of provision: The provision of data is necessary. Failure to provide the necessary data will result in the inability to receive the service.

3.A.II. Purpose of SERVICE AND PRODUCT SATISFACTION SURVEY The purpose of processing is not related to marketing purposes but for qualitative purposes, through email and telephone communication. Legal basis: Processing is necessary for the pursuit of the legitimate interest of the data controller (C47-C50) Art. 6 PAR. 1 lett. f) GDPR. In this specific case, the legitimate interest consists in the possibility of receiving useful feedback to improve the quality of the service and/or products. Retention period: The retention period lasts until opposition (opt-out). Nature of data provision: Data provision is optional. You may object to processing initially or during subsequent communications. 3.A.III. Purpose of DIRECT MARKETING, automated “SOFT-SPAM” email (art. 130 co 4 privacy code) The data controller will use, for the purpose of direct sales of its own products or services, the email coordinates provided by the data subject in the context of the sale of a product or service, without requesting the data subject’s consent, for promotional and commercial communications and newsletters on services similar to those subject to the sale, and the data subject, adequately informed, does not refuse such use, initially or during subsequent communications. The data subject, at the time of collection and during the sending of each communication made for the purposes referred to in this paragraph, is informed of the possibility to object at any time to processing, in an easy and free manner. The Controller, to compare and possibly improve the results of communications, uses systems for sending newsletters and promotional communications with reports. Thanks to the reports, the Controller will be able to know, for example: the number of readers, openings, unique “clickers” and clicks; the devices and operating systems used to read the communication; details on individual user activity; details of emails sent, emails delivered and not delivered, and those forwarded; All this data is used for the purpose of comparing and possibly improving the results of communications. Legal basis: Processing is necessary for the pursuit of the legitimate interest of the data controller or third parties, provided that the interests or fundamental rights and freedoms of the data subject that require the protection of personal data do not prevail (C47-C50) Art. 6 PAR. 1 lett. f) GDPR. In this specific case, the Controller’s legitimate interest consists in the possibility of informing the customer of the presence of products similar to those purchased by the same customer. Retention period: The retention period lasts until opposition (opt-out). Nature of data provision: Data provision is optional. You may object to processing initially or during subsequent communications. 3.B) Purpose of DIRECT MARKETING For sending advertising or direct sales material or for conducting market research and analysis, satisfaction surveys or commercial and promotional communications, newsletters, communications about events, invitations or similar through automated means (email, SMS, social network messaging systems) and traditional means (telephone). We also inform you that we may use social platforms (Meta, Google and TikTok) for commercial communications. Communications may contain promotional activities and/or logos of third-party partners and group companies. There will be no transfer of personal data. For complete list of group companies and partners, you can write to privacy@cinius.com. The Owner to compare and possibly improve the results of automated communications, uses systems with reports. Thanks to the reports, the Owner will be able to know, for example: the number of readers, openings, unique “clickers” and “clicks”; the devices and operating systems used to read the communication; the detail on the activity of individual users; the detail of sent e-mails, delivered and undelivered e-mails, and forwarded e-mails; All these data are used for the purpose of comparing, and possibly improving, the results of communications. Processing is based on consent to the processing of personal data (C42, C43). Legal basis: Art. 6 para. 1(A) GDPR Retention period: until consent is revoked (or opt-out). Nature of data provision: Data provision is optional. Failure to provide the necessary data will result in the inability to receive direct marketing communications. Sending direct marketing communications by telephone will be done in compliance with the regulations on the Public Register of Oppositions.

3.C) Purposes of NON-AUTOMATIC PROFILING In order to carry out analysis, evaluations and to divide the interested parties into homogeneous groups by specific characteristics of activities for a better management of services; to allow the analysis of its profile, also according to the area and sector of belonging, for the creation of clusters, aimed at the analysis of habits of consumption choices and behavioral; this in order to build loyalty and to improve the commercial offer, the services proposed and send communications more in line with its interests. The processing of personal data could also concern customer care activities, consisting in the offer of personalized services and courtesy services. These purposes are also pursued through the inclusion of data in the company’s Data Base/CRM/platforms. The processing is based on consent to the processing of personal data; (C42, C43) Legal basis: art. 6 par. 1(A) of the GDPR. Retention period: The retention period is until revocation of consent and in any case maximum 5 years. Nature of data provision: Data provision is optional. Failure to provide the necessary data will result in the inability to conduct analysis and/or send targeted communications.

3.D) Purposes of PREVENTION AND CONDUCT OF DISPUTES AND OTHER LEGAL ASPECTS AND FOR DEFENSE IN CASE OF JUDGMENT Legal basis: The processing is necessary for the pursuit of the legitimate interests of the data controller or a third party, provided that the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data do not prevail (C47-C50) Art. 6 PAR. 1(f) GDPR. In this case, the legitimate interest of the Data Controller takes the form of the need to protect itself in case of litigation. Retention period: 10 years, unless objected to and except for the time necessary for defense in court. Nature of provision: The provision of data is necessary. Denial will have to be balanced against the legitimate interest of the Controller stated in the purposes of this section.

3.E) Purposes of SELECTING PERSONNEL IN WORK WITH US AREA. For the purpose of applying for personnel selections, carrying out the activity of research and selection of personnel for the purpose of the possible establishment of an employment relationship, even for any positions different from those for which the person concerned has spontaneously applied; preservation of personal data also for future selections; management of applications in response to job offers posted on our website; interviews and any video interviews (data processing also image/audio).For other purposes related to the selection, please refer to specific information in dedicated area where present on the site. Legal basis: Processing is necessary for the performance of a contract to which the data subject is a party or the execution of pre-contractual measures taken at the data subject’s request; (C44) art. 6 par. 1 lett. b) of the GDPR. For other purposes related to the selection, please refer to specific information in dedicated area where present on the site. Retention period: The retention period is a maximum of 12 months. In principle, data collected during the recruitment process will be deleted as soon as it becomes clear that no offer of employment will be made or that the offer will not be accepted by the candidate. For other purposes related to selection, please refer to specific information in dedicated area where on the site. Nature of Conferral: Conferral is necessary to process data for selection purposes. Failure to provide the necessary data will result in the inability to apply. For other purposes related to the selection, please refer to specific information in dedicated area where on the site.

3.F) PURPOSE OF MANAGEMENT OF REQUESTS TO EXERCISE THE RIGHTS OF INTERESTED PARTIES, pursuant to Art. 15 et seq. of the GDPR (rights of the data subject) Legal basis: The processing is necessary to comply with a legal obligation to which the data controller is subject (C45) Art. 6 par. 1(c) of the GDPR. Retention period: The retention period is 5 years from the closing of the request, subject to litigation. Nature of provision: The provision of personal data is mandatory, as it is indispensable in order to be able to execute the obligations of the Law.

3.G) Purpose of MARKETPLACE MANAGEMENT JOINT CONTROLLERSHIP with Adeo Market Services Legal basis: Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject; (C44) art. 6 par. 1 lett. b) of the GDPR. Please refer to specific information notice in dedicated area. Retention period: The retention period is referred to specific information notice in dedicated area. Nature of data provision: Data provision is necessary. Please refer to specific information notice in dedicated area.

4. TO WHOM WILL PERSONAL DATA BE COMMUNICATED? RECIPIENTS OF THE DATA Personal data will be communicated, according also to the purposes envisaged in specific areas, to subjects who will process the data as autonomous Data Controllers, or Data Processors (Art. 28 GDPR) and processed by natural persons (Art. 29 GDPR) acting under the authority of the Data Controller and Data Processors on the basis of specific instructions given regarding the purposes and methods of processing, for specific purposes according to the area of reference. The data will be communicated to recipients belonging to the following categories:

  • Subjects that provide services for the website and communication networks, including e-mail, host, website management, platforms and CLOUD, management;
  • Studies or Companies in the context of assistance and consulting relationships;
  • For online payments to banks and lending institutions and for installment payments/financing;
  • Business information companies for evaluation of creditworthiness and payment habits and/or to entities for debt collection purposes in case of administrative accounting purposes;
  • For direct marketing, soft spam similar product and with prior consent for generic marketing and profiling with prior consent, to entities for the management of direct marketing activities;
  • By area works with us, to individuals for managing recruitment activities and dedicated platforms;
  • Competent authorities for fulfillment of legal obligations and/or provisions of public bodies, upon request.

The list of Data Processors is available by writing to this address: privacy@cinius.com or to the other contact details above.

5. WILL THE DATA BE TRANSFERRED TO NONSEE COUNTRIES? Personal data may be transferred to countries outside the EEA, in order to comply with related purposes stated above. The transfer is put in place in accordance with Art.46 EU Reg. 2016/679. Regarding the purpose 3. E), as indicated in the appropriate information, there is a transfer to the U.S. pursuant to art.45 “Third countries international organizations for which the Commission has intervened with an adequacy assessment” and in compliance with art.46 to entities that have provided adequate guarantees, with standard contractual clauses (SCC) of the Commission. The data subject may obtain information about data transfer guarantees by writing an email to privacy@cinius.com

6. IS THERE AN AUTOMATED PROCESS? Personal data will be subject to traditional manual, electronic and automated processing. It should be noted that fully automated decision-making processes are not carried out. With reference to the profiling activity, possibly carried out upon the express consent of the interested party as indicated in the purposes, it will be carried out through the intervention of the operator who will process the profile of the interested party and analyze their habits and consumption choices, in order to improve the commercial offer and services of the owner (non-automated profiling).

7. WHAT ARE YOUR RIGHTS? HOW CAN HE EXERCISE THEM? You may assert your rights as expressed in the EU Regulation 2016/679 at art.15 s.s. by contacting the Data Controller, by sending an email to privacy@cinius.com or by writing to the DPO at the contacts above. You have the right, at any time, to request access to your personal data (art.15), rectification (art.16), deletion of the same (art.17), restriction of processing (art.18). The data controller shall notify (art. 19) each of the recipients to whom the personal data have been transmitted of any rectification or erasure or restriction of processing carried out. The data controller shall inform the data subject of such recipients if the data subject so requests. In addition, in the cases provided for, you have the right to the portability of your data (art.20), in which case you will be provided with the data in a structured, commonly used and machine-readable format. You have the right to object in the cases provided for (art.21), at any time, to the processing of data based on legitimate interest, as well as to revoke the consent given without affecting the lawfulness of the processing based on the consent before revocation. To stop receiving automated direct marketing communications (e-mail or SMS) it will be sufficient to write at any time an e-mail to privacy@cinius.com with the subject “unsubscribe from” indicating the communication tool you no longer want to be used or use our automatic unsubscribe systems provided for e-mails only. To stop receiving marketing communications, you will simply write an e-mail to privacy@cinius.com with the subject line “unsubscribe marketing” at any time. You may revoke your consent to (non-automated) profiling by writing an e-mail to privacy@cinius.com with the subject line “no profiling” at any time. In the event that you believe that the processing of personal data carried out by the Data Controller is in violation of the provisions of Regulation (EU) 2016/679, you have the right to lodge a complaint with the Supervisory Authority, in particular in the Member State in which you normally reside or work or in the place where the alleged violation of the Regulation occurred, or to take appropriate legal action. 8. Changes to the policy The Owner reserves the right to change, update, add or remove parts of this policy. In order to facilitate verification and modification of the text, the notice will contain the date of update. Update date: May 14, 2024

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