Personal Data Management Policy
Last updated: December 1, 2019
Praesidium International has long considered the protection of the personal data of its existing and/or potential customers and users to be of fundamental importance, ensuring that the processing of personal data, carried out by any means, whether automated or manual, is done in full compliance with the safeguards and rights recognised by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “Regulation“) and other applicable legislation on the protection of personal data.
Pursuant to article 4(1) of the Regulation personal data means “any information relating to an identified or identifiable natural person; identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person” (hereinafter “Personal Data”). In pursuance of Praesidium International’s objectives, it may learn of or request that you provide certain personal data such as your full name, your email address, your telephone number and postal address, your tax identification number or your VAT number, your date of birth and other data that could render you personally identifiable.
The Regulation requires that before personal data may be subject to processing – defined under article 4(2) of the Regulation as “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction” (hereinafter “Processing”) – the data subject must be informed about the purposes of the processing, the methods of processing as well as lots of other information required by law.
In this respect, the purpose of this page on the website www.praesidiumintl.com is to give you more information, in a simple and user-friendly manner, in addition to that contained in the specific privacy policies issued pursuant to article 13 of the Regulation when communicating and collecting your personal data.
This website page has been prepared on the basis of the principle of transparency and contains all of the elements required by articles 13 and 14 of the Regulation. This page is divided into different sections (hereinafter “Sections” or individually “Section”). Each section deals with one specific issue which makes for simple, straight-forward and intuitive reading (to simplify matters, these sections will be referred to as the “Policy”).
Praesidium International will process your personal data on an independent basis, depending on one or more of the purposes (such as those mentioned in Section D of this Policy) reported in a specific disclosure that you will be given during the collection of personal data:
- Praesidium International Srl with registered office at via al Sesto Miglio, 38 – 00189 – Roma registered at the Companies’ Register of Rome, Tax Code/VAT no. 14921431004
- Praesidium International Ltd with registered office at 183 Queen’s Road Central, Hong Kong – HK SAR registered at the Companies’ Register of Hong Kong, Tax Code/VAT no. 2600001
Praesidium International may act as the controller, defined in article 4(7) of the Regulation as “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data”.
Praesidium International may ask you to communicate your Personal Data which will be processed for the following purposes:
- Request for Information: For the Controller to respond to your request for information that it receives by means of one of the methods on its websites, it needs to process some of your Personal Data as requested in the collection form and/or voluntarily provided by you.
Legal basis and lawfulness of processing: for the pre-contractual purposes pursuant to article 6, point (b) of the Regulation – your Personal data will be processed by the Controller to respond to your request for information. The legal basis for processing is therefore the pre-contractual relationship that will be created between you and the Controller;
- Subscriptions or the Purchase of services: the Controller, in order to allow you to subscribe or purchase services, needs to collect some of your personal data, as requested in the subscription form or purchase order form.
Legal basis and lawfulness of processing: for the contractual purposes/statutory obligations pursuant to article 6, point (b) and (c) of the Regulation – your Personal Data will be processed by the Controller so that you will be able to receive what you requested and purchased. The legal basis for processing is the contractual relationship that will be created between you and the Controller;
- Execution of Contract Documents: in order to continue the contractual relationship between you and the Controller as well as to fulfil the related obligations, the Controller needs to collect and process some of your Personal Data as requested in each contractual document;
Legal basis and lawfulness of processing: for the contractual purposes/statutory obligations pursuant to article 6, point (b) and (c) of the Regulation – your Personal Data will be processed by the Controller to proceed with the signing of each contractual document. The legal basis for processing is the contractual relationship that will be created between you and the Controller;
- Video Surveillance Activities: The Controller uses surveillance cameras at its company offices to capture videos of the people entering the field of view of each video surveillance camera in order to protect its corporate assets, employees and contractors;
Legal basis and lawfulness of processing: legitimate interest/ statutory obligations pursuant to article 6, point (f) and (c) of the Regulation – your Personal Data will be processed by the Controller and the legal basis for processing is the legitimate interest of the Controller to safeguard and protect its offices and corporate assets and its employees and contractors as well as to fulfil applicable legal obligations;
- Access to company offices: in order for you to receive permission to enter the company offices of Praesidium International, the Controller needs to collect some of your Personal Data, as requested by the receptionist.
Legal basis and lawfulness of processing: legitimate interest/ statutory obligations pursuant to article 6, point (f) and (c) of the Regulation – your Personal Data will be processed by the Controller and the legal basis for processing is the legitimate interest of the Controller to safeguard and protect its offices and corporate assets and its employees and contractors as well as to fulfil applicable legal obligations
- Fulfilment of legal obligations: the Controller needs to collect and process some of your Personal Data as and when required by specific laws in order to fulfil legal obligations;
Legal basis and lawfulness of processing: for compliance with legal obligations pursuant to article 6, point (c) of the Regulation- Your Personal Data will be processed by the Controller to fulfil legal obligations. The legal basis for processing is compliance with applicable legal obligations;
- Employee selection process: the Controller needs to process your Personal Data in your Curriculum Vitae and/or in the specific form provided by the Controller, so that it can proceed with the employee selection process and properly evaluate whether your application is for a specific job or is a speculative application.
Legal basis and lawfulness of processing: for the pre-contractual purposes pursuant to article 6, point (b) of the Regulation – your Personal data will be processed by the Controller to evaluate your application. The legal basis for processing is therefore the pre-contractual relationship that will be created between you and the Controller;
- Direct Marketing: the communication of any advertising or marketing material carried out by the Controller directed to you. This category includes all activities carried out to promote products, services sold and/or distributed by the Controller;
Legal basis and lawfulness of processing: legitimate interest pursuant to article 6, point (f) of the Regulation – Your personal data will be processed by the Controller. The legal basis for processing is the legitimate interest of the Controller to promote its products and services, irrespective of the request for your consent and in any case until you object to such processing as better explained in recital 47 of the Regulation where “the processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest”. This will be possible following the evaluations carried out by the Controller to determine whether your interests, rights and fundamental freedoms which require the protection of Personal Data prevail on the Controller’s legitimate interest to send direct marketing communications. The reason of such interpretation shall be found in your interest expressed towards Data Controller by establishing a relationship with this latter;
The above purposes for processing should be considered as non-exhaustive examples since Praesidium International, based on the principle of transparency in relation to the data subject required by the Regulation, has adopted an approach whereby your Personal Data will be processed for the specific purposes explained to you in the policy, in short and/or long form, you will be given before the collection of your Personal Data or within the time limits set out in article 14, paragraph 3, of the Regulation.
The contact methods for direct or indirect marketing and profiling may include the use of automated means (email, SMS, mms, fax, automated calls with a recorded message) or conventional means (live calls, material sent by post). At any rate, and as specified in Section H below, you have the right to withdraw your consent, even partially, for example by only agreeing to conventional contact methods.
As regards contact methods which involve the use of your telephone contacts, please note that direct marketing will be carried out after checking whether you are registered in the Robinson List, established pursuant to Presidential Decree no. 178 of 7 September 2010, as amended.
Your Personal Data may be disclosed to specific parties regarded as recipients of such Personal Data; a recipient is understood as a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.
In this context, in order to properly carry out all of processing activities necessary to fulfil the purposes set out in this Policy, the following recipients may find themselves in a position where they need to process your Personal Data:
- third parties which perform part of the Processing and/or activities connected with or instrumental to the processing on behalf of the Controller. These parties have been appointed as processors, i.e. a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller;
- individuals employed by and/or contracted by the Controller, who have been assigned one or more activities relating to the processing of your Personal Data. These individuals have been given specific instructions concerning the security and correct use of Personal Data and are defined as persons who, under the direct authority of the Controller or Processor, are authorised to process Personal Data.
- where required by law or to prevent or suppress the commission of an offence, your Personal Data may be disclosed to public bodies or to the courts without them being regarded as Recipients. According to the regulation, public authorities which may receive personal data in the framework of a particular inquiry in accordance with the Union or Member State law shall not be regarded as recipients.
One of the principles that applies to the processing of your Personal Data concerns limited storage periods, regulated by article 5, paragraph 1, point (e) of the Regulation which states “Personal Data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject”.
In the light of this principle, your Personal Data will be processed by the Controller for no longer than is needed for the purposes set out in Section D of this Policy. Specifically, the period for which your personal data will be limited to the strict minimum, as indicated in Recital 39 of the Regulation, i.e., until termination of the contractual relationship between you and the Controller, although further retention may be required by law, as provided for in Recital 65 of the Regulation.
As regards the processing carried out for the purposes laid down in this Policy for which a consent has been sought, then Controllers may lawfully process your Personal Data until you communicate, using one of the methods provided for in this Policy, your wish to withdraw consent to one or all the purposes for which it was requested. Should you withdraw your consent, the Controller companies will be required to immediately stop processing your Personal Data for such purposes.
In accordance with the Regulation, if you have given your consent to the processing of your Personal Data for one or more of the purposes for which it was sought, you may, at any time, withdraw it, in whole or in part, without affecting the lawfulness of Processing based on consent given before its withdrawal.
The procedure to withdraw consent is very simple and straightforward: you only have to contact the Controller by means of the contact channels provided in this Policy and in sections I herein.
In addition to the above and to keep things simple, if you happen to receive advertising emails from the Controller that are no longer of interest to you, simply click on the unsubscribe button at the bottom to longer receive no further communication or, if there is no button, via the additional contact channels made available by the Controller.
In accordance with the Regulation, you may access your Personal Data, request for rectification or updating, if incomplete or incorrect, request erasure if it was collected in violation of a law or regulation, as well as object to the processing on legitimate and specific grounds.
Specifically, you are entitled to exercise the following rights at any time, vis-à-vis the Controller :
Right of access: pursuant to article 15 of the Regulation, you have the right to obtain from the Controller confirmation as to whether or not your Personal Data are being processed, and, where that is the case, obtain access to the Personal Data and the following information: a) the purposes of the processing; b) the categories of Personal Data concerned; 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; 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; 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; f) the right to lodge a complaint with a supervisory authority; g) where the Personal Data are not collected from the data subject, any available information as to their source; h) the existence of automated decision-making, including profiling 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 . All this information can be found in this Policy that will always be available in the Privacy section of each of the websites.
Right to rectification: you have the right to obtain, pursuant to article 16 of the Regulation, the rectification of your inaccurate Personal Data. Taking into account the purposes of the Processing, you also have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
Right to erasure: you have the right to obtain, pursuant to Article 17 of the Regulation, the erasure of your personal data without undue delay and the Controller shall have the obligation to erase your Personal Data where one of the following grounds applies: a) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; b) you have withdrawn consent on which the Processing of your Personal Data is based, and where there is no other legal ground for the Processing; c) you have objected to the Processing pursuant to Article 21(1) or (2) of the Regulation and there are no overriding legitimate grounds for the Processing of your Personal Data; d) your Personal Data have been unlawfully processed; e) your personal data have to be erased for compliance with a legal obligation in the Union or Member State law to which the controller is subject. In certain cases, as provided for in Article 17(3) of the Regulation, the Controller is entitled not to erase your Personal Data if their Processing is necessary, for instance, for exercising the right of freedom of expression and information; for compliance with a legal obligation; for reasons of public interest; for archiving, scientific or historical research purposes in the public interest; or for the establishment, exercise or defence of legal claims.
Right to restriction of processing: you have the right to obtain, under Article 18 of the Regulation, from the controller restriction of Processing where one of the following applies: a) you have contested the accuracy of your Personal Data (the restriction will be for a period enabling the Controller to verify the accuracy of the Personal Data); b) the Processing is unlawful but you oppose the erasure of your Personal Data and request that their use be restricted instead; c) although the Controller no longer needs them for the purposes of the Processing, your Personal Data are required for the establishment, exercise or defence of legal claims; d) you have objected to the Processing under Article 21(1) of the Regulation pending verification whether the legitimate grounds of the Controller override your own. If the Processing is restricted your Personal Data will, with the exception of storage, only be processed with your 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 important reasons of public interest. We will in any case inform you before the restriction of processing has been lifted.
Right to data portability: under Article 20(1) of the Regulation you have the right at any time to ask for and receive all your Personal Data processed by the Controller and/or by the Joint Controllers in a structured, commonly used and machine-readable format or to ask for it to be transmitted to another Controller without hindrance. In this case you will need to provide us with full and accurate details of the new Controller to which you would like your Personal Data transferred, and to give us your authorization in writing.
Right to object: under Article 21(2) of the Regulation and also as stated in Recital 70, you have the right to object at any time to the Processing of your Personal Data if they are processed for purposes of direct marketing, including profiling to the extent that it is related to such direct marketing.
Right to lodge a complaint with a supervisory authority: without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the competent Data Protection Authority if you believe that the processing of your personal data by the Controller is in violation of the Regulation and/or applicable law.
To exercise any of the above rights, simply contact the Controller in one of the following ways :
- by writing to Praesidium International, via al Sesto Miglio, 38 – 00189 ROMA ITALY;
- by sending an e-mail to firstname.lastname@example.org to the attention of the Praesidium International Privacy Office;
Your Personal Data will be processed by the Controller inside the European Union.
If for issues of a technical and/or operational nature make it necessary to rely on entities outside the European Union, those entities will be appointed Processors pursuant to Article 28 of the Regulation and the transfer of your Personal Data to those entities, which will be limited to the performance of specific Processing activities, will be governed in accordance with the provisions of Chapter V of the Regulation. All necessary precautions will be taken to guarantee the highest degree of protection of your Personal Data, since the transfer will be based on: (a) adequacy decisions by the European Commission with regard to the third country; (b) appropriate safeguards provided by the third-party recipient in accordance with Article 46 of the Regulation; (c) the adoption of binding corporate rules.
In any case, you can ask the Controller for further details whenever your Personal Data have been processed outside the European Union, by asking for evidence of the specific safeguards in place.
Personal Data (or Data)
Any information regarding a natural person identified or identifiable, even indirectly, by reference to any other information, including a personal identification number, is personal data. Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
These are the personal data automatically collected by this Space (or by third party applications it uses), including: the IP addresses or domain names of the computers that the User uses to connect to the Web Space, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used in submitting the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc.), the Country of origin, the characteristics of the browser and operating system used by the visitor, the various time connotations of the visit (e.g. the time spent on each page) and the details on the itinerary followed within the Web Space, with particular reference to the sequence of the pages consulted, the parameters regarding the operating system and the User’s computer environment.
Usage Data is data collected automatically either generated by the use of the website or from the webiste infrastructure itself (for example, the duration of a page visit).
The individual who uses this Web Space, who must coincide with the Data Subject or be authorised by the same and whose Personal Data are processed.
The natural person or legal entity to which the Personal Data refer.
Data Subject is any living individual who is the subject of Personal Data.
Data Processor (or Processor)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Controller (or Controller)
The natural person, legal entity, public administration or any other entity, association or body responsible for – also together with another controller – the decisions on the purpose and methods of processing personal data and the tools used, including the security aspect in connection with the operation and use of this Web Space.
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
Small portion of data stored inside the User’s device.
Notice to European Users: this privacy disclaimer is drawn up in compliance with the obligations set forth in Art. 10 of Directive no. 95/46/EC, and the provisions of Directive 2002/58/EC, as updated by Directive 2009/136/EC on the subject of Cookies.