1. Preamble – This Privacy Policy is intended for individuals (“Data Subjects”) who come into contact with [ORTENDE], namely: website visitors (“Visitors”); current and potential customers, natural persons or representatives of corporate customers who have a relationship with the data controller (“Customers”); current and potential suppliers, natural persons or representatives of corporate suppliers who have a relationship with the data controller (“Suppliers”); as well as suppliers’ staff; and job applicants who submit their resumes (“Applicants”).
  2. Data controllers, joint data controllers, and persons authorized to process data – The data controller for the data of the individuals mentioned above is [ORTENDE]. The data may be processed by persons authorized by the data controller and trained for this purpose.
  3. Personal Data Processed – The data processed varies depending on the data subjects to whom it relates, as specified below:
    CUSTOMERS AND SUPPLIERS: The data processed typically consists of general data; sensitive data such as health status, political, religious, or trade union affiliation may be processed if provided for in the mandate or contract.
    WEB USERS: For information on data processing, please refer to the Cookies page;
    JOB APPLICANTS: The data controller processes the data contained in the resumes received, which consist of general data. Applicants are asked not to include special categories of data as defined in Articles 9 and 10 of the Regulation (“Special Categories of Data”): please be advised that any Special Categories of Data will be immediately deleted.
  4. Purposes and legal basis of the processing. Consequences of failure to provide data – Data is processed solely for the following purposes: To enter into sales contracts or take pre-contractual measures; To comply with legal obligations;
    To respond to communications sent by browsers and/or third parties. The legal basis for processing and the consequences of failure to provide data vary depending on the status of the data subject:
    CUSTOMERS AND SUPPLIERS: data processing is necessary for the performance of the contractual relationship or pre-contractual measures and to fulfill legal obligations; failure to provide data will prevent the data controller from fully and/or partially carrying out the contractual relationship itself and/or fulfilling legal obligations.
    CANDIDATES: Data processing is necessary for the performance of candidate evaluation activities, with the potential aim of establishing a working relationship. Failure to provide data will prevent the review of the application and, in any case, the establishment of the working relationship and/or the fulfillment of legal obligations.
  5. Data Disclosure – Data may be disclosed to external processors who carry out processing activities in connection with agreements entered into with the data controller, as well as to the following categories of recipients: Suppliers of hardware/software and/or related support/maintenance services; Email and messaging service providers; Consultants, accountants, or other legal professionals; Banks and insurance companies. In addition, data may be disclosed to third parties acting as independent data controllers, such as entities to whom disclosure is required by law.
  6. Data Retention Period – Customer and supplier data is retained for the duration of the contractual relationship and for up to 2 years after the relationship ends, as well as for the time required to fulfill legal obligations and/or for defensive purposes, unless a dispute has arisen, in which case the data will be retained for the time necessary to exercise the right of defense and manage the dispute.
  7. Data Subject Rights – Data subjects may contact [ORTENDE] to exercise the rights provided for under applicable national data protection laws and the GDPR (Articles 15 et seq.) and, in particular, to access their personal data, request its correction, updating, or deletion, request restrictions, and request data portability, by sending an email to [info@ortende.it] with the subject line “Privacy.”
  8. Right to object – In accordance with the procedures set forth above, data subjects may object, in whole or in part, to the processing of their personal data, in accordance with and for the purposes set forth in Article 21 of the GDPR.
  9. Complaint – Any data subject who believes that the processing of their data violates the GDPR may, in accordance with Article 77 of the GDPR, lodge a complaint with a supervisory authority in the country where the data subject habitually resides or works, or with a supervisory authority in the country where the alleged data breach occurred.