PRIVACY, COOKIES, ANTI-BRIBERY, CODE OF ETHICS
www.italyrelocation.com collects some Personal Data from its Users.
Owner and Data Controller
ITALY RELOCATION & SERVICES via Sismondi, 11 – 20133 Milano (MI)
Owner contact email: email@example.com
Types of Data collected
Among the types of Personal Data that www.italyrelocation.com/ collects, by itself or through third parties, there are: Cookies; Usage Data; first name; phone number; company name; email address.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using www.italyrelocation.com/.
Unless specified otherwise, all Data requested by www.italyrelocation.com/ is mandatory and failure to provide this Data may make it impossible for www.italyrelocation.com/ to provide its services. In cases where www.italyrelocation.com/ specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through www.italyrelocation.com/ and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of www.italyrelocation.com/ (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics and Contacting the User.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of www.italyrelocation.com/, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies; Usage Data.
Contacting the User
Contact form (www.italyrelocation.com/)
By filling in the contact form with their Data, the User authorizes www.italyrelocation.com/ to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: company name; email address; first name; phone number.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of www.italyrelocation.com/ or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, www.italyrelocation.com/ and any third-party services may collect files that record interaction with www.italyrelocation.com/ (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
Www.italyrelocation.com/ does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through www.italyrelocation.com/ (or third-party services employed in www.italyrelocation.com/), which can include: the IP addresses or domain names of the computers utilized by the Users who use www.italyrelocation.com/, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using www.italyrelocation.com/ who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
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, including the security measures concerning the operation and use of www.italyrelocation.com/. The Data Controller, unless otherwise specified, is the Owner of www.italyrelocation.com/.
www.italyrelocation.com/ (or this Application)
The means by which the Personal Data of the User is collected and processed.
The service provided by www.italyrelocation.com/ as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Latest update: May 15, 2018
CODE OF CONDUCT – POLICY
Italy Relocation & Services conducts its business in an ethical manner following all the international and local laws and statutes related to privacy, anti-bribery and anti-corruption. The policy follows the general concepts of: Social responsibility Commercial Policy Environmental respect Data security Anti-Bribery and anti-corruption Through the Code of Conduct, Italy Relocation & Services confirms its position of “NO tolerance” to bribery, corruption and the giving and receiving of bribes; the same approach is requested and applies to:
Italy Relocation & Services employees
Associates Local Consultants, Temporary Workers Destination agents Suppliers Third parties involved in the services and in contact with our organization. As member of the FIDI GLOBAL ALLIANCE, we formally accept and agree to abide by the rules and conditions outlined in the FIDI Anti-Bribery and Anti-Corruption Charter (FIDI ABC Charter) available on the FIDI website: https://www.fidi.org/about-fidi/fidis-commitments/anti-bribery-and-anti-corruption-charter
Every employee is responsible for security at his workplace. Environmental protection, industrial hygiene and occupational safety regulations must be strictly applied. A major problem related to potential sources of danger is that people tend to become less careful with the passage of time, since compliance with safety rules is perceived as a nuisance and potential danger is considered under control. Nonetheless, every employee must commit himself to observing the safety rules exactly and consistently at all times. It is very important for superiors to give the example of this. Italy Relocation is against any discrimination and does not tolerate child exploitation in the labor field. Industrial plants and equipment require careful planning and regular inspections and maintenance, as per existing company procedures. Employees must be fully trained, informed in detail about the instructions to be followed and appropriately supervised. The implementation of such measures is essential to prevent malfunctions, accidents, or greater dangers and to allow the Company to defend plant or equipment managers in case of accidents from criminal charges.
Italy Relocation is unconditionally committed to observe the principle of free competition and to ensure that contracts with its business partners are stipulated on the right terms. We expect others to show a similar commitment. The illegal anti-competitive conduct itself includes: agreeing with competitors the prices to be practiced (joint price fixing), agreements on market shares, agreements on production capacities, market subdivisions and agreements to impose or control the resale prices of the customer. Suppliers must be chosen only on the basis of price, quality, reliability, technological standards, product convenience, the existence of a consolidated business relationship without contrasts, ISO certifications or ecological audits and the existence of a quality management system. Under no circumstances can personal relationships and interests affect the awarding of a contract. Opinions or advice given by one employee to another do not have to be motivated by the prospect of personal or material benefits.
Italy Relocation has voluntarily assumed the commitment to continuously improve its performance in terms of environmental protection. Operating a plant without the necessary permits, licenses or public authorizations, deliberately or incautiously exceeding the limits imposed on its operation by the clauses of the aforementioned permits, licenses or public authorizations, or dumping substances in surface waters without a permit, can make those responsible liable of criminal proceedings.
Documents and data storage media used at work stations must not be held by unauthorized persons and must therefore be kept locked up. The data entered on the computer must be protected through the use and frequent exchange of passwords. Third party access to documents must be effectively prevented in any case, even during prolonged absences of employees from the workplace. No employee can make copies of documents or computer files except for work purposes. No employee has the right to access information that is not related to his or her field of work, unless it is a superior or a colleague. The intentional reading of messages addressed to others is prohibited, except when it is justified by reasons of work. All messages specifically addressed to a person must be considered confidential. All documents and files must be kept in such a way that substitute colleagues can always retrieve them if necessary. The files must therefore be complete, ordered and readily comprehensible. When completing documents – including e-mails – it must always be kept in mind that the sheets may possibly be in possession of a competitor or an adversary in a case legal and used against the Company. The data, programs or documents can never be copied, nor released or removed from the Company’s premises without permission. All the confidential datas will be deleted at the termination of the service.
Anti-Bribery and Anti-Corruption
Each employee must understand that his conduct will be attributed to the Company and will influence the internal and external reputation of the Company. The Company therefore expects its employees to be courteous, fair, objective and loyal in their relationships with colleagues and third parties.
No one can be unfairly disadvantaged, favored, harassed and opposed due to race, color, nationality, descent, religion, gender, age, physical characteristics or presence. Any ongoing controversy related to this must be referred to a superior in order to find an acceptable solution to the problem. No employee or associate or consultant, can directly or indirectly: request, accept, offer or guarantee a personal advantage associated with the business activity – in particular the negotiation, awarding and execution of a contract – regardless of whether the other party to the transaction is an individual , a company or a public body. No personal gift or favor can be offered or made to national or foreign public officials. This prohibition applies to any type of gift or other incentive with the exception of modest customary gifts that are of inherently derisory value or consist of advertising or promotional material, however in compliance with existing procedures.
The prohibition also applies if the transaction with the designated partner was terminated, even without such payment. Even the appearance of any irregularity must be avoided in all cases. If such an offer is made to an employee, he must immediately report the matter to a superior. Noting that third parties and / or competitors behave in this way, never justifies a violation of these rules by an Italy Relocation employee. The assets of the Company can not be used for private purposes. No employee may use the Company’s assets (such as equipment, goods, vehicles, office supplies, documents, files, data storage media) or profit from the services of Company employees for private purposes, without the explicit permission of the division in question. The Company’s assets must not be removed from the Company’s premises without written permission from the employee’s superior.
CORRUPTION, BRIBERY OR ATTEMPTED BRIBERY IS UNACCEPTABLE. THIS APPLIES WHETHER OFFERING A BRIBE OR ACCEPTING A BRIBE.
All offers of bribes, requests for bribes or facilitation payments, including those not accepted, should be reported as soon as possible by sending an email to the following address for reporting any violations: firstname.lastname@example.org