We care about your privacy. This Privacy Policy explains what information we collect about you as a user of this website (“Website”), as a customer and/or the recipient of the services we offer or as a natural person contacting us for specific purposes. We will explain why we collect this information, what rights you have and with which parties we share your data. Your data is being processed by or on behalf of Aintro S.r.l., registered at the Italian Chamber of Commerce under number REA CA-354365.

1. What is the scope of this Privacy Policy?

This Privacy Policy covers the use of your personal data which is collected through your use of our website, our contract with you, your use of our services or personal data that you have provided to us. When you visit our Website we may place small text files called ‘cookies’ on your device to collect certain information about you and your device. This use is governed by our Cookie Statement. Our website may contain links to websites of third parties. Please note that this Privacy Policy and the Cookie Statement do not apply to the use of the websites of these third parties and the collection and processing of personal data by these third parties. We are not in any way responsible or liable for the practices of these third party websites.

2. What is personal data?

Personal data is all the information relating to a natural person or the personal and material circumstances of that person, such as names, addresses, telephone numbers, email addresses etc.

4. What are the purposes and the grounds of the processing?

The processing of your personal data by Aintro serves multiple purposes. The purpose of the processing include:

• In order to execute our contract with you. In this case the legal ground for the processing is to carry out obligations arising from any contracts to which you are a party (Art. 6(1)(b) GDPR);
• In order to provide our services to you. In this case the legal ground for the processing is to carry out obligations arising from any contracts to which you are a party (Art. 6(1)(b) GDPR);
• In order to respond to your queries. Depending on the query, the legal ground for the processing is either to carry out obligations arising from any contracts to which you are a party (Art. 6(1)(b) GDPR) or the legitimate interest of Aintro (Art. 6(1)(f) GDPR);
• In order to evaluate your job application. In this case, the legal ground for the processing is the legitimate interest of Aintro (Art. 6(1)(f) GDPR) to process and evaluate your application;
• In order to send you newsletters, offers and other relevant information. The legal ground for this processing is, depending on whether you are a customer, either the legitimate interest of Aintro (Art. 6(1)(f) GDPR) or is based on your consent (Art. 6(1)(a) GDPR);
• In order to improve our Website and other services and deliver a better service to you. The legal ground for this processing is either the legitimate interest of Aintro (Art. 6(1)(f) GDPR) or is based on your consent (Art. 6(1)(a) GDPR).

5. How long do we retain the data?

Your personal data will not be stored longer than strictly necessary for the purpose of the processing. Certain data may be stored for a period following the termination of the provision of products and services, but only when and for as long as this is necessary to comply with our obligations under applicable law. For example, by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for 7 years after they cease being customers for tax purposes. Please contact us for details of retention periods for different aspects of your personal data.

6. How will my data be protected?

Aintro will take all appropriate technical and organisational measures to prevent the loss, destruction, alteration, unauthorised disclosure or unauthorized access of personal data or unlawful processing and to comply with Article 32 of the GDPR (security of processing). Information is sent to and stored on our secure servers or in secure filing systems and your information is processed in accordance with European data protection laws. The security measures also include confidentiality agreements concluded with third parties. In addition, we limit access to your personal data to those employees, contractors, agents and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We also ensure that any processors and sub-processors we engage have taken the appropriate technical and organisational measures to prevent the loss of personal data or unlawful processing. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. With whom do we share the data?

Your personal information will be processed by third parties if it is necessary to comply with the obligation arising from a contract to which you are a party, for the supply of our services, for the provision of further information or if you consented into such transferring of data. We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above. Your personal data can in any case be shared with the parties listed below:

• providers of (supporting) software tools;
• accountants and other professional advisors;
• insurance companies;
• group companies;
• possible other third parties to the extent necessary for the processing purposes.

Such third parties’ places of business may be outside the European Economic Area (“EEA”). By way of example, this may happen if one or more of our servers are from time to time located in a country outside the EEA or one of our service providers or group companies is located in a country outside the EEA. Furthermore, we have implemented Social Plugins on our Website from social networks like LinkedIn Ireland Unlimited Company (“Linkedin”), Wilton Place, Dublin 2, Ireland, so that you can share anything of interest to you with your connections. If you use our services and provide us with your consent, your browser not only connects to our server but also to Linkedin’s servers. Thus, the content of the Plugin is transmitted to your browser which embeds content on the Website. Hence, Linkedin receives information that you used our services. In all these cases, we will take the necessary steps to ensure that your privacy rights continue to be adequately protected. In addition, we will process personal information in an appropriate manner if we are legally obliged or entitled to disclose such information. We will limit the transfer of personal data to the United States (“US”) as much as reasonably possible. In case we have to transfer personal data to the US, for example because of our use of Google Analytics, we will use Standard Contractual Clauses (“SCC”) to adequately safeguard your data. We will continuously monitor developments related to the transfer of personal data outside the EEA and will implement additional measures if and when required by applicable law to ensure that your personal data will be adequately protected outside the EEA as well as within the EEA.

8. What are your rights with regard to your data?

Under the data protection legislation, you have several rights regarding your personal data that is processed by Aintro:

• Right of access. You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and the purposes of such processing;
• Right to rectification. If we are processing inaccurate personal data, you have the right to obtain rectification of such inaccurate personal data;
• Right to erasure (‘right to be forgotten’). You have the right to request the erasure of your personal data, subject to certain conditions;
• Right to data portability. You have the right to request a copy of your personal data in order to transmit such data to another controller;
• Right to restriction of processing. You have the right to request restriction of processing your personal data;
• Right to object. You have the right to object, on grounds relating to your specific situation, to the processing of your personal data by Aintro which is based on art. 6(1)(e) (tasks in the public interest) or 6(1)(f) GDPR (our specified legitimate interests). You also have the right to object to the processing of personal data by Aintro where personal data is processed for direct marketing purposes, unless you want to object to the processing in part.
• Right to withdraw a consent: As far as the processing of your data is based on your consent, you may withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on the consent before its withdrawal.
• Right to file a complaint. You have the right to file a complaint with the Italian Data Protection Authority.

You may exercise any of the above rights as set out under paragraph 10 below. We will respond to a request for access to personal information within a reasonable period after the request is made, and give access to the personal information in the manner requested by you, if it is reasonable and practicable to do so.

9. Will this Privacy Policy change?

From time to time Aintro may change this Privacy Policy. If Aintro makes substantial changes to the way in which we process your personal data, we will post these changes on this page and we will give you the opportunity to adjust your preferences if necessary. Please check our Privacy Policy as published on our Website on a regular basis.

10. Whom should you contact if you have any questions or complaints?

In case of any questions, comments, requests or complaints regarding this Privacy Policy or the use of your personal data (in general), please contact Aintro by sending an email to the following email address: info@aintro.it. The supervisory authority in Italy is: GARANTE PER LA PROTEZIONE DEI DATI PERSONALI Piazza Venezia 11 - 00187 ROMA Phone number +39 06.696771 protocollo@gpdp.it https://www.garanteprivacy.it If you have any questions about our privacy practices or our implementation of the Privacy Shield Privacy Principles, please contact the Human Resources Director, Aintro S.r.l., Via Enrico Toti 108, 09134 Cagliari (CA) Italy.