Privacy Policy

Privacy Policy

This privacy policy describes the processing of personal data relating to users and visitors (collectively, the "Users") of the Crealis S.p.A. website (enoplastic.com: the "Website").

Crealis S.p.A may amend this Privacy Policy in accordance with future improvements or changes to the Website. In the event of substantial changes, Crealis S.p.A will post a notice on the Website to draw Users' attention to the changes and collect, if necessary, any requests to exercise rights in accordance with applicable data protection regulations.

1. DATA CONTROLLER

The data controller is Crealis S.p.A., with registered office in Bodio Lomnago (Varese), Via Galvani n.1 - 21020, C.F. and P.IVA 13400560150 (hereinafter "Crealis" or the "Data Controller").

1. DATA COLLECTED.

2.1 Personal data provided by Users

Personal data collected through the Website are provided by Users through any communications or e-mails sent directly to the Data Controller, by means of the contact details made available within the "Contacts" and "Careers" sections of the Website.

The content of communications received, including any personal data contained therein, will be processed to answer any questions and follow up on requests received.

Users are encouraged to provide Crealis with up-to-date and relevant data, limited to what is necessary in relation to the purposes for which it is shared.

2.2 Browsing data and cookies

The Data Controller may collect personal data from users of the Website in the following ways:

• (i) Through Users' browsing of the Website;
• (ii) Through cookies installed on the Website, for the purposes and in the manner specified in the cookie policy found at the following link: https://enoplastic.com/cookie-policy/

Personal data acquired through browsing are, in particular, information about the devices with which Users connect to the Website, IP address, log data, etc. (the "Browsing Data")

The personal data acquired by cookies are those strictly necessary to achieve the purposes set forth in the cookie policy in the link indicated in roman (ii) above (the "Cookie Data")

1. PURPOSE OF PROCESSING

The personal data of Users mentioned in paragraphs 2.1 and 2.2 (jointly the "Data") will be processed for the following purposes.

3.1 Follow-up on Users' Requests

The Data will be processed to respond and follow up on requests that Users send to Crealis through the email address and contact information within the various sections of the Website.

The legal basis for this processing is the legitimate interest of the Data Controller in pursuing its business activities to follow up on Users' requests.

This legitimate interest has been duly balanced against the reasonable expectations of the data subjects and, since it does not affect the rights of the data subjects involved and the data processing is carried out based on the User’s request, it has been deemed to prevail.

The provision of Data for the above purposes is necessary for the proper handling and execution of the User's requests. Any partial or total refusal to provide Data for these purposes will result in the inability of the Data Controller to fulfill these requests.

3.2 Proper operation and maintenance of the Website

The Data will also be processed in order to monitor the proper functioning of the Website and to allow the Data Controller to make changes and improvements to it, as well as to resolve any malfunctions.

The provision of Data is done automatically by connecting to the Website and any partial or total refusal to provide Data for such purposes will result in the inability of the Data Controller to properly manage the operation and maintenance of the Website.

3.3 Exercising Crealis' rights (judicial protection)

The Data will be processed to exercise the rights of the Data Controller, such as the right to defense in court, on the basis of the legitimate interest of the Data Controller. This legitimate interest is to be considered overriding because it corresponds to a constitutionally guaranteed right and, as such, is socially recognized as overriding the interests of the data subject.

The provision of Data for this purpose is necessary to enable the Data Controller to defend itself in court.

1. PROCESSING METHODS AND RECIPIENTS OF DATA

The Data will be processed by means of manual and computerized tools and will be communicated and may be known to (i) employees and collaborators of the Data Controller, duly instructed and designated to the processing and to whom Crealis has given detailed instructions, with particular regard to the implementation of appropriate technical and organizational security measures; (ii) third parties who provide ancillary or instrumental services to the activities of the Data Controller, in relation, for example, to the development, supply and operational maintenance of the Website;  and (iii) external parties operating as autonomous data controllers such as, by way of example, Authorities and supervisory and control bodies and, in general, to parties - including private parties - entitled to request such Data (such as, for example, accounting consultants, legal consultants), Public Authorities that make an express request for administrative or institutional purposes, in accordance with the provisions of current national and European regulations.

The full list of recipients of the Data is available upon request, to be sent to the contact details given in Section 7 below.

1. RETENTION PERIOD

The Data collected and processed by Crealis, for the purpose mentioned in point 3 above, may be kept for the period necessary to achieve the purposes of the processing and, in particular:

3. Purpose 3.1: In the case of sharing information through the contacts made available by the Data Controller on the Website, for a period of 12 months from the last contact made and, where applicable, for the entire duration of any contractual relationship established with the Data Controller, as well as for the time necessary to (i) comply with regulatory and/or legal obligations provided for and (ii) ensure the judicial protection of the rights of the Data Controller, in compliance with the applicable statute of limitations. More information will be provided, based on the relationships established between the parties, in the appropriate privacy notices submitted by the Controller to the various categories of subjects involved (e.g. addressed to candidates, customers, suppliers, etc.);
4. Purpose 3.2: In the case of processing of Data for the proper maintenance and operation of the Website, for the time necessary to resolve any problems or make any changes to the Website, and in any case a period not exceeding 12 months;

• Purpose 3.3: In the case of judicial protection of the Data Controller, and particularly in the case of legal disputes, for a period equal to the duration of such disputes, until the time limits for appeals are reached.

1. PLACE OF DATA PROCESSING AND TRANSFER

The Data will be processed at the Data Controller's premises and the Data will be stored at servers and/or archives both within the European Union and in third countries in respect of which an adequacy decision has been adopted by the European Commission and which therefore provide adequate guarantees of personal data protection.

However, in the case of subscribing to the newsletter service and/or accepting third-party cookies, such transfers may occur. Please refer to the specific newsletter and cookie policies on the Website.

In the case of transfers of Data outside the European Union to countries in respect of which no adequacy decision has been adopted by the European Commission, the Data Controller will adopt the appropriate safeguards set forth in Article 46 of the GDPR, and, specifically, the Standard Contractual Clauses prepared by the European Commission.  

1. USER RIGHTS AND CONTACT DETAILS

Users, as data subjects (i.e., individuals to whom the Data refer), are entitled to the rights conferred by the GDPR. In particular, pursuant to Articles 15-22 of the GDPR, Data Subjects have the right to request and obtain, at any time, access to their personal data, information about the processing carried out, rectification and/or updating of personal data, erasure and restriction of processing. They also have the right to object to the processing and to request data portability (i.e., to receive personal data in a commonly used, machine-readable, structured format). Finally, data subjects always have the right to revoke their consent at any time (this, in any case, will not affect the lawfulness of the processing carried out on the basis of the consent given before revocation) and to lodge a complaint with a supervisory authority (in Italy: the Garante per la Protezione dei Dati Personali).

Requests regarding the exercise of the above rights should be addressed to the following addresses:

• by mail, to the address via Luigi Galvani 1, 21020 Bodio Lomnago (VA), to the attention of the Human Resources Manager; or
• to the e-mail address privacyenoplastic@crealisgroup.com

To the same addresses indicated above, Users may also send inquiries regarding the recipients of the Data, as well as requests for clarification regarding this privacy policy.

1. LINKS TO OTHER WEBSITES

This privacy policy regarding the processing of personal data relates exclusively to the Data collected through the Website and with reference to the purposes identified in paragraph 3 and, therefore, is not and will not be deemed applicable to other websites consulted and/or consultable through links and/or widgets (e.g. social networks): these additional websites will process any Data collected as autonomous data controllers and in accordance with their respective privacy policies, the consultation of which by Users is expressly recommended.

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• I have read the privacy policy on the processing of personal data, pursuant to Article 13 of the General Data Protection Regulation (GDPR) (mandatory)

Information updated on [01.01.2023]