PRIVACY NOTICE PURSUANT TO ART. 13 OF REGULATION (EU) 2016/679
In relation to the personal data processed through this website

We take personal data protection extremely seriously, this is why we wish to provide you with the following information on the ways in which your personal data are processed and on the rights that you have pursuant to the laws in force on personal data protection, with particular reference to Regulation (EU) 2016/679 (hereinafter also referred to as the: “GDPR”).

1. Who is the Data Controller? How can I contact the Data Controller?

Data Controller
Inxpect S.p.A.
Via Serpente 91,
25131 – Brescia – BS - Italy
E-mail address: privacy@inxpect.com

Data Protection Officer (DPO)
Avv. Matteo Alessandro Pagani
Via Turati 26,
20121 – Milano – MI - Italy
E-mail address: dpo@inxpect.com

2. Purposes and legal basis. Processing for the purpose of pursuing a legitimate interest (Art. 6 paragraph 1 (f) of the GDPR)

1. Sending newsletters and informative materials, requests for brochures, organising events, and other marketing activities carried out using automated contact (e.g., automated telephone calls, emails, text messages and other messaging systems including instant and internet messaging, as well as contact via mobile phone) and non-automated contact (sending hard copies by post and telephone calls with an operator), relating to products or services which are similar to those that are already part of existing legal relationships.

The retention period for the personal data in relation to the purposes referred to in this section is:
for purpose: a), for the duration of the legal relationship and up to 24 months after its termination, unless the data subject explicitly objects. In this regard, it is hereby specified that any denial or withdrawal of consent for marketing purposes other than the aforementioned purpose a) shall not be considered as an objection and will not bring about the termination of this purpose and the related activities.

3. Processing purposes for which the data subject has granted consent (Art. 6, paragraph 1(a) of the GDPR

Personal data may also be processed for certain purposes for which the data subject grants consent.

1. responding to requests or questions submitted via the contacts section of this website in order to receive information, including details of our products and services, as well as submitting quotes and requesting assistance;
2. running advertising, marketing or promotional campaigns, which may include sending newsletters and related informative material using automated contact methods (e.g., automated telephone calls, e-mail, text messages, various kinds of messaging systems, including instant messaging and internet messaging, as well as contact via mobile phone) and non-automated contact methods (sending hard copies by post, telephone calls with an operator);
3. communications with third parties belonging to the same Group as the Data Controller, for the purposes of marketing and promotional activities, which includes sending advertising materials, using automated contact methods (e.g., automated telephone calls, e-mail, text messages, various kinds of messaging systems, including instant messaging and internet messaging, as well as contact via mobile phone) and non-automated contact methods (sending hard copies by post, telephone calls with an operator);
4. possible profiling activities carried out to analyse or predict aspects of personal preference, interests, consumer behaviour and habits of the data subject, as well as surveys and market research in general

The retention period for the personal data in relation to the purposes referred to in this section is:
for purpose: a), until the request has been processed, unless any legal relationships stem from the request and are entered into by the data subject and the Data Controller (in which case, the storage period is established or determined on the basis of the data processing activities related to that legal relationship);
for purpose: b) with reference to newsletters and associated promotional activities, which the data subject has asked to receive or for which registration is voluntarily, until an “unsubscribe” request is sent in relation to the newsletter service or until consent to data processing is withdrawn.
for purpose: c), 24 months from when consent is granted
for purpose: d), 12 months from when consent is granted, unless it is withdrawn.

4. The categories of data which are processed

The data processed by the Data Controller are only those defined as “personal data” according to Art. 4.1 of the GDPR.
Specifically, the applicable categories of personal data may include, but are not limited to, the following examples:

• Biographical and personal identification data (by way of example, but not limited to: name, surname, etc.);
• Contact data (address, e-mail, IP address, telephone number, any social media accounts and similar information);
• Data relative to any services provided.

5. The recipients or categories of recipients of the personal data (Art. 13, paragraph 1(e) of the GDPR) *

In the framework of the aforementioned purposes, the Data Controller may transmit your data to:

• The Data Controller’s own offices and internal departments;
• Supervisory and control bodies;
• Companies which belong to the network and/or Group;
• Companies and professional experts (including any partner companies) that provide IT services, consisting of, inter alia, electronic data processing, software management, website management and IT consultancy;
• Agents and contractors;
• Advertising and communications companies and agencies;
• Mailing companies and hosting providers, courier companies and where applicable companies that deal with packaging and shipping the above-mentioned materials and communications, companies which provide document archiving services

* Further information on the Data Recipients (pursuant to art. 4.9 of the GDPR), is available from the Data Controller’s offices using the contact details provided above.

6. The recipients or categories of recipients of the personal data (Art. 13, paragraph 1(f) of the GDPR) * and the transfer of personal data to non-EU countries

You are hereby informed that the Data Controller does not intend to transfer your personal data to countries outside the EU and EEA for the purposes stated above.

7. The rights of 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’s right to access information on whether or not Personal Data concerning them are being processed and to obtain a copy if necessary);
• right to rectification of Personal Data [art. 16 of the EU Regulation] (the data subject has the right to obtain the rectification of Personal Data concerning them which are inaccurate;
• the right to erasure of Personal Data without undue delay (“the right to be forgotten”) [art. 17 of the EU Regulation] (the data subject shall have the right to obtain the erasure of their Personal Data);
• the right to the restriction of processing of Personal Data in the cases envisaged in article 18 of the EU Regulation, such as in the case of unlawful processing, or where the accuracy of the personal data is contested by the data subject [art. 18 of the EU Regulation];
• the right to data portability [art. 20 of the EU Regulation] (the data subject shall have the right to receive the Personal Data concerning them in a structured format in order to transmit those data to another controller in the cases envisaged in this same article);
• the right to object to the processing of Personal Data [art. 21 of the EU Regulation] (the data subject shall have the right to object to the processing of their personal data in the cases envisaged in and regulated by art. 22 of the EU Regulation);
• the right not to be subject to automated individual 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).

With regard to the processing purposes for which consent is required, the data subject may withdraw consent at any time and with immediate effect, subject to the terms established by law. In general terms, withdrawal of consent only produces effects for the future.
The aforementioned rights may be exercised in accordance with the provisions of the EU Regulation by sending an e-mail to the following address: privacy@inxpect.com or using any of the contact details provided in point 1.
In compliance with art. 19 of the EU Regulation, Inxpect S.p.A. shall inform the recipients to whom the personal data have been communicated of any requests to rectify, erase or restrict processing, where possible.
In order to receive a more rapid reply to your requests to exercise the aforementioned rights, any such requests can be addressed to the Data Controller using the addresses provided in point 1. For further information kindly refer to the paragraph “The exercise of the data subject’s rights”

8. The right to make a complaint (Art. 13, paragraph 2(d) of the GDPR)

Data subjects have the right to lodge a complaint with the Italian Supervisory Authority for the protection of personal data, if they consider that processing activities regarding their personal data have been carried out in breach of the applicable legislation. The data subjects’ rights and the procedures for lodging a complaint are described by the Supervisory Authority at the web address:
http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524 or a written communication can be sent to the Italian Supervisory Authority for the protection of personal data.

9. The possible consequences of failure to provide personal data and how personal data is to be provided (Art. 13 paragraph 2 (e) of the GDPR)

9.1 Compliance with legal or contractual requirements
In the cases in which the legal basis for the stated purpose of personal data processing activities is a legal or contractual (or pre-contractual) requirement, please be informed that the data subject is obliged to provide the data requested.
Failure to do so would make it impossible for the Data Controller to proceed with pursuing the specific processing purposes.

9.2 Pursuit of a legitimate interest
Similarly, for the purposes based on a legitimate interest which do not require consent, if the data subject objects then this would make it impossible to proceed with the achievement of the respective purposes and any related services, to which respectively the data subject has objected, without prejudice to the overriding, binding, legitimate reasons of the Data Controller or which are necessary to meet the objective of protecting its rights in court.

9.3 Cases in which the data subject grants consent
You are hereby informed that the legal basis for the above-mentioned purposes is consent, in relation to these purposes, the data subject can withdraw such consent at any time with immediate effect, subject to the terms established by law. In general terms, the withdrawal of consent shall only be effective for the future, therefore any processing that has been carried out before consent was withdrawn is not affected and shall remain legitimate.
Failure to grant consent, or partial consent (or withdrawal of consent), may mean that the full delivery of services or the performance of activities is not guaranteed, with reference to the individual purposes for which consent is denied, and shall not prejudice or impede other purposes (and activities related thereto) which are not explicitly included in or affected by the denial of consent or which do not have consent as their legal basis for data processing.

It should be noted that, with reference to requests for information, although consent to the processing of personal data is free and optional, such processing is necessary in order to respond to the request. Therefore, on sending a request or an equivalent indication of the data subject’s wishes, consent shall be deemed to have been granted, this consent is always revocable with the consequences described above.

When data are no longer necessary, they are routinely erased, if erasure is impossible or only possible by making a disproportionate effort due to the specific storage method, the data shall not be processed and must be stored in areas that are not accessible.

10. The existence of an automated decision-making process (including profiling)

The use of decision-making processes based solely on automated procedures, as detailed in article 22 of the GDPR is currently ruled out. Should it be decided in the future to begin using such processes for individual cases, the data subject will receive separate notification if this is required by law or an update to this privacy notice.

11. Data processing methods

The personal data will be processed in paper, electronic and digital format and will be entered into the relevant databases (candidates, etc.) which may be accessed by operators who would therefore become aware of the data; all such operators are specifically appointed by the Data Controller as Data Processors and Operators Authorised to process personal data, they may be required to carry out operations which include consultation, use, processing, comparison and any other appropriate operations that may also be automated, in compliance with the provisions of law, and which are necessary to ensure, inter alia, the confidentiality, security and accuracy of the data, as well as updating the data and ensuring relevance with respect to the stated purposes.

The processing of data for navigation purposes
The computer systems and software procedures used to operate this website acquire some personal data during normal operations, transmission of which is implicit in the use of Internet communication protocols.
These data are not collected for the purpose of associating them with identified data subjects, however by their very nature they could, by means of processing and association with data held by third parties, allow users to be identified.
The information that may be collected includes IP addresses, the type of browser or operating system used, URI addresses (uniform resource identifier), the domain name and addresses of the websites used for access or exit (referring/exit pages), the time at which the request was made to the server, the method used and information obtained on the response, further information on user navigation on the site (kindly also refer to the section on cookies) and other parameters relating to the user’s operating system and environment.
In the event of cybercrimes committed against the website, these same data could also be used to identify those responsible and call them to account

The use of cookies

For detailed information on the cookies used by the data controller on this site, reference should be made to this link: Cookie policy

Notice concerning children under 14 years of age
Children under the age of 14 may not provide personal data. Inxpect S.p.A shall not be liable in any way in the event that personal data, as well as false statements, are provided by children, moreover, should the use of such data be detected, Inxpect S.p.A shall facilitate the rights of access and erasure requested by the legal guardian or the person with parental responsibility.

The exercise of the data subject’s rights
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 data 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 expressly envisaged in this article, which includes but is not limited to: the purposes of processing, the categories of data and data recipients, the retention period, the existence of the right to request rectification or erasure of personal data or restriction of processing activities, the right to lodge a complaint, the existence of automated decision-making as referred to in Article 22 of the Regulation, as well as a copy of the data subject’s personal data.
• Right to rectification of Personal Data [art. 16 of the EU Regulation]: the data subject has the right to obtain the rectification/addition of Personal Data concerning him or her which are inaccurate, without undue delay;
• The right to erasure of Personal Data (“the right to be forgotten”) [art. 17 of the EU Regulation]: the data subject shall have the right to obtain the erasure of their Personal Data without undue delay, if one of the grounds expressly envisaged in that Article applies, including but not limited to: the personal data are no longer necessary in relation to the stated purposes, the data subject withdraws consent on which the processing is based, the data subject objects to the processing and there are no overriding legitimate grounds for the processing, the personal data have been unlawfully processed, the personal data have to be erased to comply with a legal obligation, data processing regards minors without the applicability conditions established in Article 8 of the Regulation;
• The right to the restriction of processing of Personal Data [art. 18 of the EU Regulation]: in the cases envisaged in article 18, such as in the event of unlawful processing, or where the accuracy of the personal data is contested by the data subject, in the event of objection by the data subject and when 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 and in the other cases expressly envisaged in the aforementioned article;
• The right to data portability [art. 20 of the EU Regulation]: in cases in which processing is based on consent and contract, and is carried out by automated means, the data subject shall have the right to receive the Personal Data concerning them in in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller;
• The right to object to the processing of Personal Data [art. 21 of the EU Regulation]: the data subject shall have the right to object to the processing of their personal data where there are no overriding legitimate grounds for the processing activities and when processing is carried out for direct marketing purposes;
• The right not to be subject to automated individual 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, (for example, decisions taken exclusively by means of computerized systems or programmes).

The descriptions provided herein do not replace the text of the articles cited, which can be consulted using this link and which should be read in full.

Amendments and updates
The date of the most recent update to this policy is in the header.
Inxpect S.p.A. may make changes and/or additions to this privacy policy as a consequence of any subsequent changes and/or amendments to the law.

References to the legislation governing data subject’s rights

Article 15 GDPR
Right of access by the data subject

1. 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 personal data and the following information:
   1. the purposes of the processing;
   2. the categories of personal data concerned;
   3. 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;
   4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
   5. 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;
   6. the right to lodge a complaint with a supervisory authority;
   7. where the personal data are not collected from the data subject, any available information as to their source;
   8. 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.
2. 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.
3. 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.
4. 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:
   1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
   2. 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;
   3. 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;
   4. the personal data have been unlawfully processed;
   5. 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;
   6. the personal data have been collected in relation to the offer of information society services referred to in Article 8 paragraph 1.
2. 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.
3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
   1. for exercising the right of freedom of expression and information;
   2. 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;
   3. 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;
   4. 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
   5. 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. 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. the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
   3. 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. 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.
2. 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.
3. 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:
   1. 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
   2. the processing is carried out by automated means.
2. 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.
3. 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.
4. 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. is necessary for entering into, or performance of, a contract between the data subject and a data controller;
   2. 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. is based on the data subject's explicit consent.
3. 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.
4. 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.