Privacy Policy

This Privacy Policy (and our data protection documents and internal policies we are updating in compliance with Regulation (EU) 2016/679 of 27 April 2016, the so-called General Data Protection Regulation (the “GDPR”) explains how Sada Partecipazioni S.r.l. (“Sada Partecipazioni”), holding of Sada Group, manages its website https://sadaspa.it and its services with regard to the collection and process of users’ personal data.

This privacy policy only concerns the website mentioned above and no other websites linked to it.it only provides a minimum set of information as required by the GDPR and explains how Sada Partecipazioni, as Data Controller under Article 24 of the GDPR, deals with users’ data. Please, note that we may change this Privacy Policy from time to time to be up-to-date and fully compliant with the GDPR and, in general, with data protection practice and rules. Therefore, check this page occasionally to be aware of any changes and to ensure that you agree with them.

  1. Data Controller

Sada Partecipazioni is the Data Controller. Sada Partecipazioni’s registered office is in Pontecagnano Faiano (SA), at via Pacinotti, snc – 84098, tel.: +39 089. 3866611, fax: +39 089. 3866674, e-mail gruppo.sada@sadaspa.it, PEC sada.partecipazioni@telecompost.it.

  1. Data Protection Officer (DPO)

Sada Partecipazioni’s DPO can be reached at: +39 081.5747282 e-mail privacy.grupposada@sadaspa.it, PEC: privacy.grupposada@pec.it.

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  1. Data Processor

Sada Partecipazioni has appointed the company proving hosting service as the Data Processor.

The updated list of data processors can be asked to the DPO.

  1. Purposes of the processing

Users’ data are used by Sada Partecipazioni to manage its website and offer its services.

In line with Article 32 of the GDPR, Sada Partecipazioni adopts adequate means to prevent loss, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

  1. Types of data subject to the processing
  2. Navigation data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This category of data includes IP addresses or domain names of the computers used by the Users who connect to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters related to the operating system and the user’s IT environment.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning and are deleted immediately after processing.

The data could be used to ascertain responsibility in case of hypothetical computer crimes to the detriment of the Site. Without prejudice to this possibility, the data on web contacts do not persist for more than 7 days.

  1. Data provided voluntarily by the user
  • e-mail: the optional, explicit and voluntary sending of e-mails to the addresses indicated on the 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. In any case, Sada Partecipazioni, in order to comply with the new legal provisions introduced by the GDPR, has introduced a system requesting the User to provide or refuse consent to the processing of his data, in order to ensure that consent is been lent in a conscious way;
  • collection of personal data off-line: in the event that Sada Partecipazioni collects personal data off-line (eg: paper forms), Sada Partecipazioni provides contextual information on the processing of data pursuant to art. 13 of the GDPR and obtain, if necessary, the consent of the data subjects (this also applies if the data are collected on forms that can be downloaded from the Website);
  • collection of personal data online: in relation to data collections made directly on the Site (eg contacts, sending cv), information on the treatment is provided in the context of data collection. However, it is always possible to access this page to review the Privacy Policy.
  1. Cookies

Cookies are small text files that the Internet sites visited by users send to their terminals, where they are stored before being re-transmitted to the same Internet sites on the next visit.

Cookies of the c.d. “Third parties” are, however, set by an Internet site other than the one the user is visiting. This is because on each site there may be elements (images, maps, sounds, specific links to web pages of other domains, etc.) that reside on servers other than that of the visited Internet site.

  1. Technical cookies

Sada Partecipazioni uses technical cookies, that is to say cokies that are used to allow browsing and to improve the functioning of the service requested by the User. They are not used for other purposes and are installed directly by Sada Partecipazioni as owner of the Site.

Without the use of these cookies, some navigation operations could not be completed or would be more complex and / or less secure. These cookies that allow you to maintain the identification of the User during the session, are essential.

  1. Analytical cookies

Sada Partecipazioni uses analytical cookies from third parties, ie created and made available by Google Analytics.

In the use of these cookies, Sada Partecipazioni adopts the measures required by the Authority for the protection of personal data (the “Garante”) in terms of cookies, adopting appropriate tools to reduce the identifying power of analytical cookies (for example, through the masking of significant portions of the IP address).

Below is the link to receive information on the processing of data by Google Analytics with instructions on how to use the browser add-on to disable Google Analytics (https://tools.google.com/dlpage/gaoptout?hl = en).

  1. Navigation without registration

Navigation on the Site is free, free of costs and does not require registration of the User.

Navigation is not monitored neither with reference to the sites of origin nor with reference to the pages visited.

  1. Rights of the data subject

Users, as subjects to whom the personal data held by Sada Partecipazioni refer, are qualified as data subjects under the GDPR.

As such, the data subjects have the right to know, at any moment, the data concerning them, to know how they were acquired, to verify if they are accurate, complete, up-to-date and well guarded, and to enforce the rights established by articles. 12 and ss of the GDPR (for example, request the integration and deletion of their Data or oppose for legitimate reasons to their use), by sending a request to the Data Controller or to the DPO.

In case of failure or unsuitable feedback to the advanced requests, the data subjects have the right to file a claim against the Garante (Piazza di Monte Citorio n. 121 00186 Rome, tel.: +39 06696771, fax +39 06696773785, e-mail garante@gpdp.it, PEC: protocollo@pec.gpdp.it).

  1. Conservation and access to data

As Data Controller, Sada Partecipazioni proceeds, directly or through any persons indicated on the Site, to save the personal data of the Users in special servers and to carry out all other processing operations through the personnel – of the Controller or Processor – for this purpose authorized pursuant to Article 29 of the GDPR, or through any external subjects during maintenance operations, specifically designated as data processors.

The database is accessible only by authorized parties using methods that guarantee its protection and confidentiality, thanks to the adoption of technical measures and organizational measures pursuant to art. 32 of the GDPR, designed to prevent data loss, illicit or incorrect use and unauthorized access to data.

The data are kept for the time strictly necessary to carry out those processing operations carried out in relation to the data of each User, according to his choices, preferences and indications.

  1. Communication and dissemination

Unless explicitly indicated in the information relating to individual processing, the personal data collected will not be disclosed to third parties or disseminated, nor will they be transferred to a third country (not belonging to the European Union) or an international organization that has not guaranteed a high level of personal data protection similar to that ensured in the European Union.

  1. Amendments to the present notice

Notwithstanding that Sada Partecipazioni does not proceed with processing operations other than those expressly authorized and / or requested by each User, the Privacy Policy may be amended to comply with new legal provisions or with the changed data processing policies of Sada Investments.

Each updated version of this Privacy Policy will be made available on the Website in the dedicated section.

Sada Partecipazioni therefore invites all Users to periodically consult the Site to be always informed of the latest version uploaded.