Privacy policy

Privacy Policy

Updated 1 March 2012 

Publicitas International Spa has always paid particular attention to the processing and the protection of personal data of its Clients, Suppliers, Associates and all those with whom it enters into collaboration. For such purposes in respect of the privacy laws, Legislative Decree. 30 June 2003 n. 196, the Company has been confirmed as an organisation with an adequate Privacy Policy. 

Publicitas International Spa whose registered office in Via Borsieri 28, 22100 Como, thanks you for having provided your personal data, brings to your attention the purpose and method of the processing of the data provided, distributed among: 

  • Clients and Suppliers
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  • Job applicants: for those wishing to send a CV
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  • Website visitors: the people who visit our website and/or contact us for information
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Your rights and the Data Processing Manager

First and foremost, we remind you that, according to Art. 7 of Legislative Decree 196/2003, detailed below, it is your right, among others, to be aware of your personal data processed by us as well as to request its supplementation, verification or deletion.

In order to exercise such rights you may contact the Data Officer via email italy(at)publicitas.com or by post at our office address.

The complete list of all the Personal Data Processing Managers, appointed by us, is available by contacting our Data Officer.

Art. 7 (Right of access to personal data and other rights)

1. The data subject has the right to obtain confirmation, in a clear way, of whether or not personal data exists, even if not yet registered,

2. The data subject has the right to an indication as to: a) the source of the personal data; b) the purpose and method of the processing; c) the reasoning behind any use of electronic instruments for the processing; d) the identifying data of the owner, Managers and the delegated officers according to Art. 5, para 2; e) the subjects or the categories of subjects to whom the data may be communicated or who may have access to such data in their official capacity delegated by the State, Managers or Authorised Persons.

3. The data subject has the right to: a) updates, verification or, if interested, the supplementation of the data; b) the deletion, to request that such data be rendered anonymous or the block of data processed in violation of the law, including those that are not required for the purposes for which the data was collected or subsequently processed; c) confirmation that the operations stated in a) and b) are brought to the attention, and with regards to its contents, all those to whom the data have been communicated or distributed, except in the case that such a task is found to be impossible or requires disproportionate effort compared to the right being exercised.

4. The data subject has the right object, wholly or in part: a) for legitimate reasons to the processing of their personal data, even if processed in line with the purposes for which it was collected; b) to the processing of personal data for marketing or direct sales or for market research or commercial communication.

Client and supplier Information

The nature of the processed data

Publicitas International Spa only deals with your information, financial records and other personal data that is necessary for the performance of contractual relationships, existing or future, with our Company. In some cases, always and only for the performance of contractual relationships, Publicitas International Spa may collect its Clients ‘sensitive’ data (according to Art. 4, para 1 (d) of Legislative Decree 196/2003 which defines ‘sensitive’ personal data as that which can identify racial or ethnic origin, religious or philosophical belief, political opinion, party or union affiliation, as well as personal data which reveals state of health or sexual orientation): for the use of the latter we aim to obtain written consent.

Purpose of the Data Handling

Your data will be processed in relation to the contractual requirements, and to the deriving legal and fiscal obligations, as well as to allow an efficient management of financial and commercial relationships.

The data shall be processed for the duration of the contractual relationship and beyond, for the fulfilment of legal obligations and administrative and commercial purposes.

Objection to Data Processing for Commercial Reasons: opt-out.

Email and address details provided could be used by Publicitas International Spa in order to send advertising material, direct sales, perform market research and obtain commercial communication. Such promotional activity may only pertain to goods and services analogous with the contractual relationship. We inform you that, at the time of the collection of your data and upon every communication made for the abovementioned purposes, you may object to the processing, simply by contacting our Data Processing Manager, reachable via email italy@publicitas.com or by post at our office address.

The use of your data will be promptly ended.

Processing Procedures

Data is processed via the use of appropriate instruments and procedures which guarantee security and privacy and may be conducted both through the use of hardcopy and electronic formats.

Obligation or Option to Provide Data

Concerning data that we are required to own in order to comply with legal, regulatory and European Union obligations, or directives given by mandated Authorities and security and control Agencies, your failure to provide such data will result in it becoming impossible to enter into or continue the relationship, to the extent that such data is necessary for its continuation.

Concerning the data that we are not required to own, lack of such data will be evaluated from time to time and will determine ensuing decisions, in proportion to the importance of such data to our organisation of data requested and not provided.

Knowledge and communication of your data

Your data may come to the knowledge of Processing Managers or Delegates appointed by the company, always exclusively to directors, administrators, accountants, administrative staff, operational managers and external consultants. Your information may be communicated by us (communicated meaning rendering it known to one or more predefined parties) to parties that may access it in compliance with the law and regulatory European Union norms, as well as to parties who require access to the data in order to enter into collaboration in the relationship between you and our company, and using it strictly for the purposes of the collaboration.

The data may furthermore be communicated by us to regulatory agencies, regulated by or connected to Art. 2359 of the Italian Civil Code, that is, publicly regulated agencies, for the administrative accountability purposes as defined by Art. 34 para. 1-ter (Legislative Decree 196/2003), those being agencies connected to the performance of activities of an organizational, administrative, fiscal or accounting nature notwithstanding the nature of the data collected. In particular, in pursuing such organisational activities, such as those necessary for the fulfilment of contractual and pre-contractual obligations, to the management of the employment relationship in all of its phases, to bookkeeping and the application of the relative fiscal, union, state welfare, health and safety regulations.

Your rights and their respective procedures are stated in the introduction to this Privacy Policy.

Job applicant Information

Publicitas International Spa performs its selection of personnel abiding to the equality of men and women and without discriminating against either gender, in accordance with Law n. 903/77 and n. 125/91.

Your information will furthermore be collected and stored with the highest regard for privacy, care and diligence in accordance with Legislative Decree 196/2003 and according to the procedure detailed below.

Collection and nature of data

Information will be obtained through the receipt of CVs. CVs may be sent via email with the attachment of appropriate forms or via post.

Purposes of Data Handling

The processing of personal data is conducted exclusively for the performance of personnel research, selection and evaluation purposes.

Obligation or Option to Provide Data

The providing of personal data and of the Curriculum Vitae by the data subject is optional: without such data, in any case, we are not in a position to undertake personnel research, selection and evaluation.

Communication or distribution of the data

The data may come to the knowledge of the Data processing Managers or Agents designated by us. Your data may also be communicated to third parties who provide specific services or carry out activities that are in connection, are instrumental or are in support of the procedure and the purpose of which your data was provided. The data may furthermore be communicated by us to regulatory agencies, regulated by or connected to Art. 2359 of the Italian Civil Code, that is, publicly regulated agencies, for the administrative accountability purposes as defined by Art. 34 para. 1-ter (Legislative Decree 196/2003), those being agencies connected to the performance of activities of an organizational, administrative, fiscal or accounting nature notwithstanding the nature of the data collected. In particular, in pursuing such organisational activities, such as those necessary for the fulfilment of contractual and pre-contractual obligations, to the management of the employment relationship in all of its phases, to bookkeeping and the application of the relative fiscal, union, state welfare, health and safety regulations.

Data Processing and Storing Procedure

The data will be processed in accordance with Art. 11 of Legislative Decree n. 196/2003. The data will only be processed according to reasons strictly pertaining to the indicated purposes  and with procedures that guarantee the security and the confidentiality of such data, through the use of appropriate measures which impede its alteration, deletion, destruction, unauthorised access, prohibited handling or processing not compliant with the purposes of its collection.

The data will be stored in our database for a period not exceeding that which is necessary to manage and monitor the research and selection process.

Your rights and their respective procedures are stated in the introduction to this Privacy Policy.

Website Visitors

This page describes the way in which our website is managed with regards to the handling of the personal information of visitors to our website. The treatment of such data is based on the principles of lawfulness and compliance with all current regulations.

This Privacy Policy also acts as the Information required to be provided by Art. 13 of Legislative Decree 196/2003 (Italian regulation for the personal data processing in the enactment of Directive 95-46-CE) to those who interact with the services of this website, with the end of protecting personal data which is electronically accessible via www.publicitas.com/italy/ , that is the home page of the Publicitas International Spa official website. This Information is given for The Publicitas International Spa website only and is not valid for other websites that one may access via links. They are independent Owners of their processing and therefore the websites in question must be referenced.

The Information is also based on the Recommendation n.2/2001 given by European authorities for the protection of personal data, as part of the Group instituted by Art. 29 of Directive n. 95/46/CE enacted on 17th May 2001 to identify the minimum requirements for the collection of personal data online and, in particular, the procedures, duration and nature of the information that the data processing Owner must provide to the visitors of the website, regardless of their reasons for accessing the website.

The processing of the information which you have freely provided will be in accordance with the current regulations. In particular, the processing will be undertaken in line with the principles of fairness, lawfulness and transparency; pertinence, comprehensiveness and without excess; the data will be collected and recorded for the purposes listed below and stored for a period no longer than necessary.

Types of data processed, procedures, purposes for processing, optionality or lack thereof

Website navigation data

The software used for this site collects, during the course of its normal functioning, some personal data the communication of which is required by internet communication protocols.

This data is not collected for the purpose of being connected to identifiable users, but by its nature, could be used by third parties for the identification of individual users.

Under this category are the IP addresses and computer domain names of the visitors to this website, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to present the request to the server, the size of the file obtained in response, the numerical code indicating the status of the data response from the server (complete, error, etc.) and other parameters relating to the operating system and the computer of the user. 

This data is used for the sole purpose of obtaining anonymous statistical information concerning the use of the website and its correct operation, and will be deleted immediately after the elaboration of such statistics.

The data may be used to certify responsibility in case of hypothetical hacking crimes aimed at the website.

Data voluntarily provided by the website visitor

The optional, explicit and voluntary sending of emails to the addresses indicated on this site result in the collection of the sender’s address and the personal data necessary to respond to the request and/or to supply the services requested, as well as other personal data entered in the email or contained in its attachments.

Emails received are archived indefinitely on a server protected by adequate security measures. The data subject may exercise his or her rights under Art. 7 of Legislative Decree 196/2003 as summarized in the introduction to this Privacy Policy, in particular he or she has the right to know what information regarding him or her is archived and have it deleted by writing to the Data Manager via email italy@publicitas.com

The data will furthermore be digitally and/or electronically processed to respond to requests and/or to provide services requested. The provision of such data is always optional and the lack of provision may result in these requests not being carried out or answered.

Cookies

See: www.publicitas.com

Location of Data Processing and Circumstances of its Communication or Distribution 

The data connected to the services of this website will be communicated and stored on the Server of xentive, Avenue Mon-Repos 22 CH-1002 Lausanne, Switzerland, appointed the external Data Manager within the assigned duties of system administrator and of the processing of personal data collected from the Publicitas International Spa website.

None of the date deriving from our web services will be communicated or distributed. The personal data voluntarily provided by the website visitors via email or through completion of the specific forms, will be used solely for the provision of services or the responding to requests and will only be communicated to third parties if necessary for such matters.

Your rights and their respective procedures are stated in the introduction to this Privacy Policy.