European General Data Protection Regulation (“GDPR”)
As of 25 May 2018, the EU Regulation 2016/679, known as the GDPR (General Data Protection Regulation) – on the protection of natural persons with regard to the processing of personal data and on the free movement of such data – is directly applicable in all Member States.
As claimed by the EU Commission, the GDPR is the result of the clear need for legal certainty, harmonization and simpler rules on the transfer of personal data from the EU to other parts of the world.
Through the General Data Protection Regulation (GDPR – EU Regulation 2016/679), the European Commission aims to strengthen and harmonize the protection of personal data of EU citizens and EU-based residents, both inside and outside the borders of the European Union (EU). The text, which was adopted on 27 April 2016 and published in the European Official Journal on 4 May 2016, entered into force on 25 May of the same year, and is going to be effective as of 25 May 2018.
Through the GDPR, the EU Commission aims primarily to give control back to citizens over their personal data and to simplify the regulatory environment for international business by unifying the privacy regulation within the EU.
In performing its activity, Energy Consulting Services processes the personal data of various categories of stakeholders (healthcare professionals, researchers, employees, etc.). This data is managed in compliance with the laws and rules that protect this data, and with the right to privacy of each individual.
In order to fulfil its obligations under the GDPR, Energy Consulting Services has adopted policies that vary according to the type of data subject whose personal data are being processed by the group, to be submitted to all relevant stakeholders.
Data subjects may exercise their rights at any time as specified in the information received.
In this section you can find the documents on personal data protection.
Data Protection Officer
The Data Protection Officer (or “DPO”) is designated by Energy Consulting Services Data Controller to fulfil the tasks referred to in the European General Data Protection Regulation.
You can contact the DPO for all matters relating to processing of personal data and exercising of the data subject’s rights via the e-mail address info@e-c-s.it or by sending a letter to 3, rue Alessandro Volta – 64121 – Montardon – France.
Privacy Policy on the use of the Website
Introduction
This document (hereinafter “Privacy Policy”) provides information about the processing of the data collected by the company Energy Consulting Services (hereinafter “Company” or “Controller”) through this website (hereinafter “Website”) and it is therefore the policy intended for the concerned parties in compliance with the applicable regulations and the provisions in Article 13 of the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter “Regulation”).
Data Controller identity and contact information
The Data Controller is Energy Consulting Services, with registered office at 3, rue Alessandro Volta – 64121 – Montardon – France.
DPO contact details
You can contact the DPO designated by the Company at:
– e-mail: info@e-c-s.it
Which data we process
Processing may involve any ordinary personal data provided by you when you are interacting with the Website features including browsing data, or when you request the Website services (registration to any reserved areas/contests and other initiatives, use of any Apps, requests for information or reports including through contact forms, and more), as well as the data collected through the cookies as specified in the Cookie Policy.
Why we process your personal data and how
With you consent the Company may process your ordinary personal data to allow the use of Website services and functions and optimize its functioning, to run statistical analyses on the visits, to manage requests and reports received through the Website, to register to any reserved areas or initiatives such as contests and the like, as set out in Article 6.1.(a) of the Regulation. The Company may also process your personal data to comply with the legal obligations required by laws, regulations, EU legislation: the lawful basis for processing data for these purposes is set out by Article 6.1.(c) of the Regulation.
With your optional consent, ordinary personal data may also be used to send institutional communications (newsletters included) or perform promotional activities (marketing), meaning sending promotional materials and/or commercial communications regarding the services provided by the Company to the addresses specified, both via traditional methods and/or means of contact (such as paper mail, phone calls with operators, etc.) and automatic ones (such as communications over the Internet, fax, e-mails, sms, applications for mobile devices such as smartphones and tablets – so-called APPS – social media accounts, such as via Facebook – etc.). The lawful basis for processing for this purpose is Article 6.1.(a) of the Regulation.
Personal data is processed using both automatic and non-automatic tools according to the very purpose of the processing and, in any case, with methods and procedures that guarantee the safety and confidentiality of the data.
Compulsory and optional processing
The forms to be filled in on this Website may contain data that is essential to handle your communications and requests – marked with a [*] – which, if not entered, will prevent your requests from being processed, as well as optional data, which is not essential to process the request by the person concerned. Failing to enter this data will have no consequences.
Browsing data
The processing of personal data of users who visit the Website only (meaning those who do not send communications or use any of the services/functions available) will be limited to browsing data, which means personal data which need to be transferred to the Website in order for the IT systems that manage the Website and the Internet communication protocols to work. For example, this category includes IP addresses, or the domain of the computer used to browse the Website and other parameters related to the operating system used by the user to access the Website. The Company collects this and other data (such as the number of visits and time spent on the Website) for statistical purposes only and anonymously in order to check the Website operation and improve its features. This information is not collected to be combined with other information about the users and to identify them; however, given its nature, this information may allow for the identification of users by processing and combining it with data controlled by third parties. Browsing data is normally erased after anonymous processing but may be stored and used by the Company to investigate on and identify the perpetrators of any cybercrimes committed against the Website or through the Website. Without prejudice to this circumstance and the provisions in the Cookie Policy section, the browsing data above is temporarily kept in compliance with the applicable regulations.
Links to other websites
The Website may contain links to other websites (so-called third-party websites). The Company has no access to and has no control over the cookies, web beacons and other user tracking technologies used by third-party websites which you can access to from the Website; the Company has no control over the contents and materials published by or obtained through third-party websites, or the way they process your personal data, and expressly does not accept any responsibilities on this. You must check out the privacy policy of the third-party websites you visit through the Website and to get information about the conditions applicable to the processing of your personal data. This Privacy Policy applies to the Website as defined above only.
How we store data and for how long
In compliance with the provisions set out by Article 5.1.(c) of the Regulation, the way the IT systems and programs used by the Company are set up allows to minimize the use of personal and identification data; this data is processed only to the extent necessary to achieve the purposes specified in this Policy; the data will be stored for as long as necessary to fulfil the purposes that are actually pursued and, in any case, the criteria used to determine the storage duration comply with the terms allowed for by the applicable laws and the principles of data minimization, storage limitation and rational records management. In order to determine the right retention period for the personal data stored by the Website upon your consent, the controller also considers the following criteria: the specific purposes described in the policy for which the website stores the personal data; the type of current relationship with you (how frequently you log in to your account; if you submit requests using the contact form; how regularly you browse the website, etc.); any specific request to erase your data or consent withdrawal by you; the data controller’s legitimate business interest.
How we guarantee safety and the quality of personal data
The Company commits to protect the safety of your personal data and complies with the applicable safety provisions to prevent data loss, unlawful or illegal use of and any unauthorized access to the data, with special but not exclusive reference to Articles 25-32 of the Regulation. The Company uses multiple advanced safety technologies and procedures to protect the personal data of users; for example, personal data is stored in safe servers located in places with access control and protection measures in place. You can help the Company update and keep your personal data correct by communicating any change to your address, qualification, contact information, etc.
Who can access the data
Personal data will only be made available to those who may need it because of their tasks or positions held in the Company and any parent, subsidiary and affiliated companies of Energy Consulting Services. These subjects, whose number will be as low as possible, will be trained appropriately in order to prevent losses, destruction, unauthorized access to or unauthorized use of the data.
Additionally, the data may be communicated to: (i) institutions, authorities, public entities for their institutional purposes; (ii) professionals, self-employed workers, even if associated; third parties and vendors hired by the Company to receive commercial, professional and technical services aimed at managing the Website and its functions (for example IT service and Cloud Computing providers), pursuing the purposes specified above and providing the services to you; (iii) third parties in case of mergers, acquisitions, company or branch transfers, audits or other extraordinary operations; (iv) the company’s Supervising Board, which is located at the Controller’s premises, to supervise on and implement Energy Consulting Services Code of Conduct. These subjects will only receive the data necessary for their functions and will commit to use it for the purposes above only, and to process it in compliance with the applicable privacy regulations. The data may also be communicated to legitimate recipients pursuant to the applicable laws. Exception made for the above, data is not shared with third parties, either physical or legal persons, who do not perform any commercial, professional or technical functions for the Controller and will not be disclosed. The subjects who receive the data will process it as Controllers, Processors or people authorized to process personal data, as the case may be, for the purposes specified above and in compliance with the applicable privacy laws.
Transferring data to non-EU Countries
About the transfer of data to a third Country, including Countries that may not guarantee the same level of protection set out by the applicable regulations, the Controller informs that the processing will still occur in compliance with one of the methods allowed for by the Regulation, such as the user’s consent, the adoption of Standard Clauses approved by the European Commission, the selection of subjects which have joined international frameworks for the free movement of data (e.g. EU-USA Privacy Shield) or operate in Countries the European Commission considers safe.
Rights of users
The users to whom the data refers have the right to obtain the confirmation as to whether or not their personal data exist or not and to know its content and the source, check that it is correct or ask for it to be integrated or updated, or rectified, erased or restricted, or to oppose against its processing, to lodge a complaint with a supervisory authority pursuant to Article 15 of the Regulation. Additionally, pursuant to articles 7, 15, 16, 17,18, 19, 20, 21, 22 and 77 of the same Regulation, each user has the right to ask for information about the collection and use of their personal data, to access it, have it rectified, erase it (right to be forgotten), restricted processing, the notification obligation regarding rectification or erasure of personal data or restriction of processing, data portability, the anonymous transformation or the block of data processed against the law, as well as the right, in the cases set out by the law, to oppose to its processing, to lodge complaints regarding the collection and processing of personal data with the competent Supervisory Authority, to withdraw the consent to the processing of personal data at any times, without prejudice to the legitimate processing performed until then based on the consent withdrawn.
If you have any requests about personal data processing by the Company, to exercise the rights recognized by the applicable regulations, as well as to know about the updated list of subjects who can access the data, you can contact the Controller and/or the DPO using the contact details above.
Changes to this Privacy Policy
If any changes are made to this Privacy Policy, the updated version will be published on this Website. The Company will inform you about those changes as soon as they are made and will be enforceable as soon as they are published on the Website. So, the Company invites you to check out this section regularly to learn about the latest and most recently updated version of the Privacy Policy.
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