PRIVACY POLICY

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INFORMATION RELATING TO THE WEBSITE’S PRIVACY POLICY

1. This section contains information on Humanware’s management methods with reference to the processing of Humanware users’ data.

2. This information note is also valid for the purposes of Article 13 of Regulation (EU) no 2016/679, concerning the protection of individuals with regard to the processing of personal data as well as the free circulation of such data, for those subjects who interact with Humanware and it can be accessed at the address corresponding to the home page:

www.hmw.it/en

3. The information note is provided for Humanware only and not for other websites which the user might consult through links contained therein.

4. The purpose of this document is to provide knowledge on the methods, timing and nature of the information which data controllers must provide to users when connecting to the Humanware web pages, regardless of the purpose of the connection itself, according to Italian and European legislation.

5. The information note may be subject to changes due to the introduction of new rules and regulations in this regard, the user is therefore invited to periodically check this page.

6. Should the user be under the age of 14, pursuant to Article 8, paragraph 1 of Regulation (EU) 2016/679, and Art. 2 – fifth section of L. Decree 196/2003, as amended by Legislative Decree 181/18, he/she must legitimise his/her consent by means of the authorisation of his/her parents or guardians.

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DATA PROCESING

1 – Data Controller

1. The data controller is the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data. It also deals with security profiles.

2. With regard to this website, the data controller is: Andrea Scoglio, and for any clarification or in order to exercise the data subject’s rights, he can be contacted at the following email address: a.scoglio@hmw.it.

2 – Data Processor

1. The data processor is the natural or legal person, public authority, service or other body which processes personal data on behalf of the data controller.

2. Pursuant to Article 28 of Regulation (EU) no. 2016/679, by appointment of the data controller, the data processor of the Humanware website is: Humanware S.r.l.

3 – Place of data processing

1. The processing of data generated by the use of Humanware takes place at via Garofani, 1 – 56125 – Pisa.

2. In case of need, the data connected to the newsletter service can be processed by the data processor or by subjects it appoints for this purpose at the relevant office.

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COOKIES

1 – Type of Cookies

1. The Humanware website uses cookies to make the user’s browsing experience easier and more intuitive: cookies are small text strings used to store some information which may concern the user, his/her preferences or the Internet access device (computer, tablet or mobile phone) and are mainly used to adapt the operation of the website to the user’s expectations, offering a more personalised browsing experience and memorising the choices made previously.

2. A cookie consists of a reduced set of data transferred to the user’s browser from a web server and can only be read by the server that made the transfer. It is not executable code and it does not transmit viruses.

3. Cookies do not record any personal information and any identifiable data will not be stored. If you wish, you can prevent some or all cookies from being saved. However, in this case, the use of the website and of the services offered could be compromised. To proceed without changing the options relating to cookies, simply continue browsing.

The following are the types of cookies that the website uses:

2 – Technical cookies

1. There are numerous technologies used to store information on the user’s computer, which are then collected by the websites. Among these, the best known and used is that of HTML cookies. They are used for navigation and to facilitate the access and use of the website by the user. They are necessary for transmitting communications on the internet or for the supplier to provide the service requested by the customer.

2. The settings to manage or disable cookies may vary depending on the internet browser used. In any case, the user can manage or request the general deactivation or cancellation of cookies by changing the settings of his/her internet browser. This deactivation can slow down or prevent access to some parts of the website.

3. The use of technical cookies allows the safe and efficient use of the website.

4. The cookies that are placed in the browser and retransmitted through Google Analytics or through the blogger statistics service or similar are technical only if used for the purpose of optimising the website directly by the controller of the website, who can collect information in aggregate form concerning the number of users and how they visit the website. Under these conditions, the same rules envisaged for technical cookies, in terms of information and consent, apply to analytics cookies.

5. From the point of view of duration, we distinguish between temporary session cookies, which are automatically deleted at the end of the browsing session and are used to identify the user and therefore to avoid logging in to each page viewed, and permanent ones that remain active on the PC until they expire or are cancelled by the user.

6. Session cookies may be installed in order to allow access and staying in the reserved area of the portal as an authenticated user.

7. They are not stored permanently but only for the duration of the navigation until the browser is closed and they disappear when the browser is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server; these are necessary to allow the safe and efficient exploration of the website.

3 – Third party cookies

1. In relation to the origin we distinguish the cookies sent to the browser directly from the website you are visiting and those of third parties sent to the computer from other websites and not from the one you are visiting.

2. Permanent cookies are often third-party cookies.

3. Most third-party cookies consist of tracking cookies used to identify online behaviour, understand the interests and therefore customise advertising proposals for users.

4. Analytical third-party cookies may be installed. They are sent from the domains of the aforementioned third parties external to the website.

5. Third-party analytical cookies are used to detect information on user behaviour on Humanware. The detection takes place anonymously, in order to monitor performance and improve the usability of the website. Third-party profiling cookies are used to create profiles relating to users, in order to offer advertising messages in line with the choices made by the users themselves.

6. The use of these cookies is governed by the rules set up by the third parties themselves, therefore, users are invited to read the privacy policies and instructions for managing or disabling the cookies published on the relevant web pages.

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DATA PROCESSED

1 – Data processing methods

1. Like all websites, this one also makes use of log files in which the information collected in an automated manner is stored during user visits. The information collected could be the following:

– internet protocol (IP) address;
– type of browser and device parameters used to connect to the website;
– name of the internet service provider (ISP);
– date and time of visit;
– visitor’s web page of origin (referral) and of exit;
– possibly the number of clicks.

2. This information is processed in an automated form and collected in an exclusively aggregated form in order to verify the correct functioning of the website, and for security reasons. This information will be processed on the basis of the legitimate interests of the controller.

3. For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may possibly also include personal data such as the IP address, which could be used, in accordance with applicable laws, in order to block attempts to damage the website itself or to cause damage to other users, or in any case harmful activities or those constituting a crime. These data are never used for identifying or profiling the user, but only for the purpose of protecting the website and its users; such information will be processed according to the legitimate interests of the controller.

4. Should the website allow the insertion of comments, or in the case of specific services requested by the user, including the possibility of sending his/her Curriculum Vitae for a possible working relationship, the website automatically detects and records some identification data of the user, including the email address. These data are voluntarily provided by the user at the time of the service provision request. By entering a comment or other information, the user expressly accepts the privacy policy, and in particular agrees that the contents entered should be freely disseminated to third parties. The data received will be used exclusively for providing the requested service and only for the time necessary for the provision of the service.

5. The information that users of the website will deem to make public through the services and tools made available to them, are provided by the user knowingly and voluntarily, thus exempting this website from any liability for any violation of the law. The user is responsible for verifying that they have permission to enter the personal data of third parties or content protected by national and international standards.

2 – Purpose of data processing

1. The data collected by the website during its operation are used exclusively for the purposes indicated above and kept for the time strictly necessary to carry out the specified activities.

2. The data used for security purposes (blocking attempts to damage the website) are kept for the time strictly necessary to achieve the previously indicated purpose.

3 – Data provided by the user

1. As indicated above, the optional, explicit and voluntary sending of emails to the addresses indicated on this website entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message.

2. Specific summary information notes will be progressively reported or displayed on the pages of the website set up for particular on-demand services.

4 – Support in configuring your browser

1. The user can also manage cookies through the settings of his/her browser. However, deleting the cookies from the browser could remove the preferences set for the website.

2. For further information and support, you can also visit the specific help page of the web browser you are using:

– Internet Explorer: https://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

– Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences

– Safari: https://www.apple.com/legal/privacy/it/

– Chrome: https://support.google.com/accounts/answer/61416?hl=it

– Opera: https://www.opera.com/help/tutorials/security/cookies/

5 – Social Network Plugins

1. This website also incorporates plugins and/or buttons for social networks, in order to allow easy sharing of the content on your favourite social networks. These plugins are programmed so as not to set any cookies when accessing the page, to safeguard user privacy. Cookies may possibly be set, if so provided for by the social networks, only when the user makes an effective and voluntary use of the plugin. Please note that if the user browses while logged into the social network then he/she has already consented to the use of cookies conveyed through this website at the time of registration to the social network.

2. The collection and use of information obtained through the plugin are governed by the respective privacy policies of the social networks, to which you should refer:

Facebook: https://www.facebook.com/help/cookies

Twitter: https://help.twitter.com/it/rules-and-policies/twitter-cookies

Google+:https://www.google.com/policies/technologies/cookies

Pinterest: https://about.pinterest.com/en/privacy-policy

AddThis: https://www.addthis.com/privacy/privacy-policy

Linkedin: https://www.linkedin.com/legal/cookie-policy

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RIGHTS OF THE DATA SUBJECT

1. Art. 13, sect. 2 of Regulation (EU) 2016/679 lists the data subject’s rights.

2. The Humanware website therefore intends to inform the user in relation to the existence of the data subject’s rights, based on the following articles of Regulation (EU) 2016/679:

a) Based on art. 15, the data subject has the right to ask the controller for access to his/her personal data, based on art. 16 the possibility of rectifying the data provided, based on Article 18, the possibility of supplementing or limiting the processing which concerns him/her, or to object, for legitimate reasons, to their processing based on art. 21, in addition to the right to data portability based on art. 20 of the Regulation (EU);

b) the right to request their erasure based on Article 17, of transformation into anonymous form or of blocking data processed in violation of the law, including those which do not need to be kept for the purposes for which the data were collected or subsequently processed.

c) the right to obtain the notification that the updating, rectification, integration of data, cancellation, data blocking, transformation operations have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfilment proves impossible or involves the use of means manifestly disproportionate to the protected right.

3. Requests can be addressed to the data controller, without formalities or, alternatively, by using the template provided by the Italian Authority for the protection of personal data, or by sending an email to: a.scoglio@hmw.it

4. Should the processing be based on art. 6, section 1, letter a) – express consent to use – or on art. 9, section 2 letter a) – express consent to the use of genetic, biometric, health-related data, revealing religious or philosophical beliefs or trade union membership, revealing racial or ethnic origin, political opinions – the user has the right to revoke consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.

5. Likewise, in case of violation of the law, the user has the right to lodge a complaint with the Italian Authority for the protection of personal data, in its capacity as the authority responsible for monitoring processing in the Italian State.

6. For a more in-depth examination of your rights, see articles 15-22 of Regulation (EU) 2016/679.

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DATA TRANSFER TO EXTRA UE COUNTRIES

1. This website may share some of the data collected with services located outside the European Union area. In particular with Google, Facebook and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorised and strictly regulated by Article 45, section 1 of Regulation (EU) 2016/679, for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.

2. Data will never be transferred to third countries which do not comply with the conditions set out in Article 45 et seq., of the (EU) Regulation.

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SECURITY OF DATA PROVIDED

1. This website processes user data in a lawful and correct manner, adopting the appropriate security measures to prevent unauthorised access, disclosure, modification or unauthorised destruction of data. The processing is carried out using IT and/or computer-based tools, with organisational methods and with logic strictly related to the purposes indicated.

2. In some cases, categories of employees involved in the organisation of the website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as suppliers of third-party technical services, postal carriers, hosting providers, IT companies, communication agencies) may have access to the data in addition to the controller

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CHANGES TO THIS DOCUMENT

1. This document, which constitutes the privacy policy of this website, is published at:

hmw.it/en/privacy-policy/

2. It may be subject to changes or updates. In the case of significant changes and updates, these will be pointed out to users through specific notifications.

3. Le versioni precedenti del documento saranno comunque consultabili a questa pagina.

4. The document was updated on 26/03/2020 to comply with the relevant regulatory provisions, and in particular in compliance with Regulation (EU) 2016/679.