1. Data controller
The Data Controller is INTERCHEM ITALIA SRL, with registered office at Via
Spagna, 8 35010 Vigonza (PD), VAT No.: IT 01374650289, and can be contacted at the following numbers:
Phone +39 049/8932391, email: info@interchemitalia.it.
2. Nature of the data processed, purpose and legal basis of the processing
Nature of data processed. In relation to the purposes of the processing set out below, we inform you that
only “common personal data” will be processed, such as:
● identification data (company name, VAT number, tax code, type, address, telephone number, email address, etc.);
● personal details of the company contact and legal representative (name, surname, etc.);
● common personal data (such as personal details, contact details, data relating to
education and professional experience; other data typically contained in CVs)
● etc.
Purpose of processing. Your personal data will be processed for the following purposes:
A. respond to your requests: by voluntarily completing the appropriate form
form found in the contact area of our website;
B. respond to your request to subscribe to our newsletter: by
voluntary completion of the specific form found in the newsletter area of our website;
C. satisfy your request to register on our site and, therefore, for the creation
of your own personal account, by filling out the appropriate form on our website
site;
D. fulfill your request to register on our site in order to carry out your
order, by filling in the appropriate form and follow up with the invoicing of
as indicated in the order;
E. for the purposes of recruitment and selection of personnel or to propose other offers of
work consistent with the candidate’s professional profile;
F. Comply with legal obligations;
G. Marketing: to send you advertising materials, direct sales, conduct market research, and send you commercial and promotional communications;
H. Profiling: to analyze your preferences and receive personalized information and/or
commercial communications.
Legal basis for processing. Personal data, for the purposes referred to in points 2A to 2D and
2F, will be lawfully processed to fulfill pre-contractual and contractual obligations between
us and the user (Article 6, paragraph 1, letter b), and to fulfill our legal obligations (Article 6, paragraph 1, letter c).
Your personal data, for the purposes referred to in point 2E, will be lawfully processed to
pursue a legitimate interest of the Data Controller (Article 6, paragraph 1, letter f) and to fulfill
our legal obligations (Article 6, paragraph 1, letter c).
Finally, your personal data, for the purposes referred to in points 2G-2H of this privacy policy,
may be lawfully processed only with your consent (Article 6. Paragraph 1
letter a of the EU Regulation), specific, separate, express, documented, prior, and
entirely optional.
Your consent may be revoked at any time, without prejudice to
the lawfulness of processing based on consent before its revocation
(Article 7, paragraph 3 of the EU Regulation).
Furthermore, we inform the data subject that, pursuant to Article 21 of the EU Regulation, the data subject
has the right to object at any time to the processing of personal data concerning him or her
for direct marketing purposes (including profiling) and that,
if the data subject objects to the processing, the personal data can no longer be
processed for such purposes.
Clarification: In accordance with the principle of maximum transparency towards the Data Subject,
a hallmark of our Company, we wish to inform you that if you decide to give
your consent under point 2G (marketing), you must be informed in advance and
aware that the purposes of the processing pursued are of a specific nature
—commercial, advertising, promotional, and marketing in the broadest sense, such as:
3. Data Recipients and Processing Methods Existence of an Automated Decision-Making Process, Including Profiling
The processing of your personal data will be based on the principles of fairness, lawfulness, and
transparency and may be carried out using paper and electronic means both by
the undersigned Company’s personnel, authorized/appointed to process personal data,
and by external parties appointed to perform specific tasks on behalf of the Data Controller,
as Data Processors, pursuant to Article 28 of the Regulation.
EU, subject to our letter of engagement that imposes on them the duty of confidentiality and security of
the processing of personal data, and the adoption of appropriate security measures to prevent
data loss, illicit and improper use, and unauthorized access, in compliance with
current provisions on personal data protection.
For brevity, a detailed list of these figures is available at the Data Controller’s office
and is at your disposal.
Your personal data will not be disclosed or transferred to third countries or international
organizations. They will not be disclosed to third parties except for legal or contractual obligations (please note that contractual obligations also include the
communication of data to other companies directly associated with the undersigned, as their
activities are essential to the completion/execution of your request).
With reference to the provisions of Article 13 of the EU Regulation, paragraph 2, letter f) and Article
14 of the EU Regulation, paragraph 2, letter g), we hereby inform you that the Data Controller
does not currently use any automated decision-making systems or processes.
4. Data retention periods
Your personal data will be stored for a period of time not exceeding
achievement of the purposes for which they are processed, in compliance with the limitation principle
of the conservation required by the EU Regulation and/or for the time necessary for obligations
by law and by contract or until the specific consent is revoked by
part of the interested party and, therefore
● with reference to the purposes indicated in points 2A, 2B, 2C, 2D and 2F, the data will be
stored for a period not exceeding the achievement of the purposes for which they are
processed and/or for the time strictly necessary for the fulfillment of legal obligations and
of the contract;
● With reference to the purposes indicated in point 2E, personal data will be retained
for the period necessary to achieve the specific purposes for which they are processed
and in any case for a period no longer than 6 months from receipt of the CV,
after which time, they will be automatically deleted and no copies will be kept.
● With reference to the purposes indicated in point 2G, data processed for
Marketing purposes will be retained for no longer than 24 months from collection.
● With reference to the purposes indicated in point 2H, the data processed for
Profiling purposes will be retained for no longer than 12 months from collection.
To ensure the stated retention periods, a periodic review is performed
annually on the data processed and on the possibility of deleting it if
it is no longer necessary for the intended purposes.
5. Access to data (categories of recipients to whom the data may be communicated)
We also inform you that the data collected will never be disclosed or shared without your explicit consent, except for necessary communications.
may involve the transfer of data to public bodies, consultants, or other parties
for the fulfillment of tax and legal obligations or for the fulfillment of the purposes
(where authorized), subject to our letter of engagement imposing a duty of confidentiality and security on the processing of personal data.
With reference to Article 13, paragraph 1, letter e) of the EU Regulation, we hereby indicate
of the subjects or categories of subjects (duly identified and trained) who may
become aware of the user’s personal data in their capacity as data controllers or persons in charge, and
a specific list by category is provided below:
● Partners, employees, collaborators, and suppliers of the Data Controller in Italy and
abroad, in their capacity as data controllers/authorized persons and/or data processors (e.g.,
offices: commercial, technical, administrative, legal, press; system administrators,
external professionals, various service providers, etc.)
● Partner companies and/or companies directly associated with the undersigned, as their
activities are essential to the completion/execution of your requests.
● external consultants for recruitment, selection and evaluation of personnel
(for the data referred to in point 2E only);
● subjects for whom access to data is expressly recognised by law, by
regulations or provisions issued by the competent authorities (for the data referred to in the
point 2E)
Your personal data may also be disclosed to external parties who are recipients of the
practices concerning you, in the performance of activities, and to external parties who
interact with the undersigned, always and exclusively for activities functional to the purposes
described above. These parties are called upon to perform specific tasks on behalf of the
Data Controller, as Data Processors, pursuant to Article 28 of the
EU Regulation.
For brevity, a detailed list of these entities is available at our offices and is at your
disposal.
6. and 7. Communication and transfer of data
Without the need for express consent (Article 6, paragraph 1, letters b), c), and f) of the EU Regulation), the Data Controller may communicate your data for the purposes referred to in points
2A to 2F to supervisory bodies, judicial authorities, as well as to those entities to whom
communication is required by law for the fulfillment of the purposes indicated above.
These entities will process the data in their capacity as independent data controllers.
Personal data is stored on devices located at the Data Controller’s
headquarters or with providers within the European Union.
Your data will not be disclosed.
To ensure the security of such transfers, we only use parties that
offer the necessary guarantees to implement adequate technical and organizational
measures so that the processing complies with the provisions of EU Regulation 679/2016.
Both for the data stored on its own devices and for any data stored
with providers, the Data Controller has implemented adequate technical and
organizational measures to ensure an adequate level of security, in full compliance with
the provisions of the EU Regulation.
To the extent permitted by law, we may use the personal information
provided to conduct appropriate payment and anti-fraud checks. In this regard,
Ferrino e C. S.p.A. Through one or more data processors, as part of its
data processing activities pursuant to applicable legislation (Regulation (EU)
2016/679 “GDPR”: “It also constitutes a legitimate interest of the data controller to
process personal data strictly necessary for fraud prevention purposes”),
may request the User to provide their identification data, including, if applicable, a
copy of an identity document. The personal information provided by the User may be
subject to verification, including by third parties such as a credit reference or
fraud prevention agency, which may maintain a record of such information.
8. Consequences of failure to communicate data
The personal data referred to in points 2A-2B-2C-2D-2E-2F of this policy are
necessary; without such data, it would be impossible for us to proceed and fulfill our
contractual and legal obligations.
The personal data referred to in points 2G-2H, however, are optional. Refusal to provide them will
have no consequences and will not prejudice your request to proceed with
registration or fulfill our contractual and legal obligations. You may therefore decide at any time not to provide any data or to subsequently deny the possibility of
processing data already provided.
9. Rights of the interested party
In your capacity as interested party, you have the rights set out in articles no. 15 to no. 22 of the
EU Regulation reported below and specifically has the right to:
● obtain confirmation of the existence and processing of personal data concerning him
concern and, if so, obtain access to your data (so-called right of access);
● obtain information on the purposes of the processing, the categories of data in
question, the recipients or categories of recipients to whom the data have been or will be
communicated, in particular if recipients are from third countries or international organisations, the
expected data retention period or the criteria used to determine that period;
and if the data is not collected from the interested party, obtain all the information
available on their origin;
● obtain the rectification of data concerning him or her (so-called right to rectification);
● obtain the erasure of data concerning him or her (so-called right to be forgotten);
● obtain restrictions on processing (so-called right to restriction of processing);
● obtain data portability, i.e., receive data from a data controller in a
structured, commonly used, and machine-readable format and transmit it to
another data controller without hindrance (so-called right to data portability);
● object to processing at any time (so-called right to object). We inform you
specifically, as required by Article 21 of the EU Regulation, that if the data
personal data are processed for direct marketing purposes (including profiling),
The interested party has the right to object at any time to the processing of personal data
concerning him/her carried out for such purposes and that if the interested party objects to the
processing for direct marketing purposes, personal data may no longer be
subject to processing for these purposes;
● be made aware (with the possibility of objecting) of the existence of a
Automated individual decision-making, including profiling;
● withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
● lodge a complaint with a supervisory authority (Italian Data Protection Authority).
Please note that there may be conditions or limitations to the data subject’s rights.
Therefore, it is not certain that, for example, you have the right to data portability in all cases; this
depends on the specific circumstances of the processing activity.
Another example: if you decide to object to data processing, the Data Controller
has the right to evaluate your request, which may not be accepted if
there are compelling legitimate grounds for the processing that override
your interests, rights, and freedoms.
10. How to exercise your rights
You may exercise your rights at any time, without any formality, in a clear and explicit manner
by sending:
– a registered letter with acknowledgement of receipt to the undersigned;
– an email to interchemitalia@legalmail.it
Or by contacting the Data Controller directly at: +39 049/8932391
11. Minors
The services offered by the Data Controller and the subject of the existing relationship with you do not
involve the intentional acquisition of personal information relating to minors. In the event that
information on minors is inadvertently recorded, the Data Controller
will delete it promptly, upon request or notification by the data subject.
12. DPO (DPO) – Persons in charge/Authorized – Data Controllers
Below, we provide you with some information that is necessary for your attention,
not only to comply with legal obligations, but also because transparency and
fairness towards interested parties is a fundamental part of our business.
Data controller.
The Data Controller of your personal data is INTERCHEM ITALIA SRL, which is responsible
for the legitimate and correct use of your personal data. You can contact it
for any information or request at the following numbers: telephone +39 049/8932391 e-mail: info@interchemitalia.it.
Data controller.
The Data Controller has appointed CALICANTUS SRL as Data Processor. CALICANTUS SRL is also responsible for the legitimate and
correct use of your personal data. You can contact CALICANTUS SRL for any information or
requests at the following numbers: telephone +39 0422 782890, email: privacy@calicant.us.
Authorized Persons.
The updated list of authorized persons is kept at the Data Controller’s headquarters.
