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Sensitive Data Processing
Access to certain sections of the site and/or eventual requests for information or services by site users may be subordinate to the insertion of sensitive date whose processing by SACE, as the titular of the said processing, will be effected in compliance with Legislative Decree No. 196/2003 “Code on Matters of Sensitive Data Processing” (hereinafter the “Code”).
This information notice, provided as required by Article 13 of the Code, has the purposes of permitting users to be aware, even before they access the diverse sections of the site, and insert their data, of how SACE processes user’s personal data, and it is, in any case, that the user reads the same before inserting personal data by compiling the forms in the various sections of the site.
Scope of Sensitive Data Processing
On the basis of the needs expressed, from time to time, by the user as they access the various sections of the site, the scope of processing the personal data provided directly by the users when compiling the on-line forms may be the following:
- the performance of activities connected directly with and instrumental to the provision and management of services offer by the SACE Business School, by the research Office and by the Human resources Division.
- to permit registration on the portals related to the site, necessary to access the same to use the diverse services provided.
personnel recruitment and selection.
- to forward information material on SACE publications, training and seminar activities.
- the collection of business information and performance of market research, service quality and customer satisfaction monitoring, effected both directly and with the collaboration of specialist companies. Surveys of a statistical nature and the creation of statistical profiles of operators interested in the services provided by the SACE Group in order to create products which increasingly adapt to their needs. Transmission of information and advertising material on SACE Group products and services.
- transmission of information and advertising material on the products and services of advertisers.
Sensitive data will be processed in a prevalently automated mode, with logics strictly correlated with the purposes cited above.
Nature of Provision of User’s Personal Data
The provision of personal data is optional, but it is partially necessary (that is for the data where the fields are marked with an asterisk) so that SACE can meet the user’s needs in the sphere of site functionalities. Refusal to provide personal data or partial or imprecise provision of the data marked with an asterisk, necessary to performance of the service requested, does not render that performance possible, while the refusal to provide optional personal data or partial or imprecise provision thereof has no consequences.
The IT systems and software procedures used to operate this web site acquire, during normal operation, certain personal data whose transmission is implicit in the use of Internet, which is based on the TCP/IP protocol.
This is information which is not collected for association with identified interests but which may, through processing and association with data held by third parties, enable the identification of browser users.
This data category includes the "IP addresses" or computer dominion names employed by the users connecting to the site, addresses in URI (Uniform Resource Identifier) notation of the resources requested, the request time, the method used to place the request to the web server, the dimension of the file obtained in response, the numerical code indicating the state of the response from the web server (completed correctly, error, etc.) and other parameters relative to the user’s operating system and IT environment. This data is used for the sole purpose of gaining anonymous information about site use and to control the correct function of the SACE web site.
Please note that the aforementioned data may be used to ascertain responsibility in cases of IT crime against the SACE web site or other sites related thereto: except for this eventuality, to date web contact data is not maintained for more than a few days.
Cookies are not used to transmit information of a personal nature, nor are so called persistent cookies used to trace users.
The use of so called session cookies (which are not memorised in persistent mode on the user’s computer and are normally deleted at the closure of the browser) is strictly linked to the transmission of session identifiers (consisting of random numbers generated by the SACE web server) necessary to enable secure, efficient browsing on the site. The aforementioned session cookies used on this SACE web site do not make use of high information technologies potentially prejudicial to the confidentiality of user browsing nor do they acquire any personal data for the users.
Categories of actors who may come into possession of the user’s personal data
The personal data may come into the possession of the legal representative of the juridical person in the name and on behalf of whom the user has requested information/registrations and to whom the data furnished refers, other SACE group companies, also outside Italy, both in European Union member states and elsewhere, so long as those companies adopt equivalent security and confidentiality criteria, consultants and other third parties, appointed to execute activities connected directly with or instrumental due the delivery and distribution of the services furnished by SACE, as well as – for the purposes of which at Items 5 and 6 (Scope of Processing paragraph) only – other companies with which SACE has business or partnership agreements.
The titular for processing is SACE S.p.A., with registered offices at Rome, Piazza Poli, 37.
How to exercise the rights of which at Article 7
Any user may, at any time, exercise the rights of which at Article 7 of the Code, and be furnished a full list of the Processing Managers, by simply sending an e-mail message to the Titular’s address [e-mail] or by writing to: SACE S.p.A. Piazza Poli, 37/42, 00198 ROME. In particular, those to whom the sensitive data refers have the right, at any time, to obtain confirmation of the existence or otherwise of the said data and to know the content and origin, verify the exactness, require integration or update, or rectification. They also have the right to request the deletion, the transformation to an anonymous format or the block of data process in breach of the law and to oppose, in any case, for legitimate reasons, their processing.
A user may, further, having given consent, oppose processing for the purposes of which at Items 5 and 6 (Scope of Processing paragraph) effected via the e-mail address of the user, by clicking on a specific “link” present in each e-mail message.
How to modify the user “profile”
A user may, at any time, modify the data furnished or delete their profile by sending an e-mail message to the Titular’s address firstname.lastname@example.org or by writing to:SACE S.p.A. Piazza Poli, 37/42, 00198 ROMA.