Privacy Policy and Legal Notices

This document concerns the privacy policies of Kube Partners Italy s.r.l. (the „Data Controller“), and aims to describe the methods for managing the processing of personal data of users and visitors to the company website, Kube Partners Italy srl ®.www.kubepartners,com

For the purposes of current legislation on data protection (i.e. the EU General Data Protection Regulation 2016/679 – hereinafter referred to as „GDPR“, and the applicable Italian legislation, Legislative Decree 196/03 as amended by Legislative Decree 101/2018, hereinafter referred to as the “Privacy Code”), we inform you that the Data Controller (pursuant to Art. 4 and 24 of the GDPR) of your personal data is KUBE PARTNERS ITALY S.r.l., with Registered Office in Via Monti e Tognetti no. 7 – 20900 Monza and operational headquarters in Via Bartolomeo Zucchi no. 7 – 20900 Monza – C.F.: 01937170031 (hereinafter referred to as “Kube”) which operates as Data Controller (pursuant to Art. 4, paragraph 7 of the GDPR). It is possible to get in touch with the Data Controller by showing up, by appointment, at the headquarters or using the following institutional address: tel. 039.388965 and e-mail administration@kubepartners.com

The Data Controller has appointed its own Data Protection Officer – DPO (hereinafter the acronym for Data Protection Officer), Avv. Laura Marretta, who can be contacted by the Data Controller and at the e-mail address  privacy@kubepartners.com.

The Data Controller adopts, as required by Art. 12 of the GDPR, the following information as a measure to provide the data subject with the information referred to in Art. 13 of the GDPR and the communications referred to in Art. 15 to 22 and 34 of the GDPR relating to the processing of the data provided. This information is to be considered general, provided to all those who interact with the site, and accessible electronically by using the address www.kubepartners.com.

The policy describes how we collect, use, store and process your personal data, and how, in doing so, we provide the services you request whilst complying with our legal obligations. Privacy is of utmost importance to us and we are committed to protecting it and to safeguarding the protection rights of users‘ personal data in compliance with the principles of lawfulness, fairness and transparency.

This information is valid only for the Data Controller’s website and is not valid for other websites that may be consulted through our links, for which the Data Controller is in no way responsible. In addition, our site uses social plug-ins (for example, in relation to social networks such as Linkedin) for which the Data Controller is in no way responsible. Therefore, please refer to the privacy policy of the owners of such plug-ins.

It is our policy to constantly update the site and adapt it to new legislation. Therefore, we may change this document and/or the privacy policy accordingly. For updates, please visit this page, where we will post any changes. If you have any questions or concerns about this privacy policy, you can contact the Data Controller at any time. The Data Controller undertakes to respond to users who send formal written complaints to the DPO to investigate the reported problem, as well as to cooperate with the competent authorities, to resolve any complaints regarding the processing of personal data that are not resolved directly between the Data Controller and the individual concerned.

In order to clarify further, here are some definitions of the terms used in this document:

• Personal data: any information relating to an identified or identifiable natural person […];
• Processing: any operation or set of operations […] applied to personal data or set of personal data;
• Profiling: any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a person […];
• Data subject: the person to whom the personal data refers;
• Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes of the processing […];
• Processor: the natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller;
• Consent of the data subject: any freely given, specific, unambiguously informed indication by the data subject that he or she gives his or her assent, by an  unequivocal statement or affirmative action, that his or her personal data will be processed.

Information on Data Processing

The Data Controller would also like to inform you that the Personal Data provided by you by contacting the Data Controller, data that does not fall within the special categories of personal data as listed in Art. 9 of the GDPR, concerning the same user (also in the case of a subject operating as a sole proprietorship, small entrepreneur, professional) (the „Data“), will be processed in accordance with the provisions of the GDPR. The processing is carried out on the basis of the legal conditions provided for in Art. 6 of the GDPR, for the purposes inherent to the relationship established with the Data Controller, therefore, its legal basis as required in Art. 13 letter c of the GDPR is justified by the reasons for which the relationship with the Data Controller is established, i.e. access as a visitor or user to the Data Controller’s website or the response to requests received from us.

We collect a limited amount of data from visitors to our website, which we mainly use to improve the user experience of our website, and to manage the services we provide at the request of users/visitors (e.g. different  language versions available).

We also remind you that, while browsing the website, you will be given the opportunity to contact the Data Controller and that the data released in this way will also be processed in accordance with the dictates of the GDPR and the Privacy Code.

With regard to the information that may be requested or that will be spontaneously provided, we wish to inform you that the provision of data may be optional in some cases and in others, mandatory, given that failure to provide the data would make it impossible to provide the service and therefore to browse the site.

Please also note that the processing of data related to the web services offered by this site, physically hosted by Nord Est Systems srl, is carried out at the operational headquarters of the Data Controller in Monza, Via Zucchi 7, and is handled only by employees, authorised collaborators or authorised third parties, in the case of occasional maintenance operations.

The processing of data will be carried out in paper and/or electronic form. The provision of data is optional, except for those acquired automatically by the system, so it is understood that by continuing to browse, consent will still be considered given pursuant to Art. 4 paragraph 11. The Data Controller does not carry out any processing based on automated decision-making processes. The data will be kept for 1 year and in any case for the time necessary to satisfy the purely technical purpose of the collection.

The Data Controller has adopted appropriate technical and organisational measures to safeguard the security of its services on the Kube Partners Italy srl ® website, the integrity of data relating to traffic and electronic communications with respect to forms of use or knowledge that are not permitted, also in order to avoid risks of dispersion, destruction and/or loss of data and confidential and non-confidential information, relating to its users, present on the site, or unauthorized access, or not compliant with the law, to the data and information themselves.

The Data Controller hereby informs you that you are guaranteed the right to rectification pursuant to Art. 16 of the GDPR, the right to be forgotten pursuant to Art. 17 of the GDPR, the right to restriction of processing pursuant to Art. 18 of the GDPR, as well as the right of access to the personal data provided and to all consequential information as listed under Art. 15 of the GDPR.

We would also like to inform you that you have the right to:

1) ask the data controller for access to personal data and the correction or deletion of the same or the limitation of the processing concerning him/her or to object to the processing;

2) data portability pursuant to Article 20 of the GDPR;

3) where the processing is based on Art. 6(1)(a) or Art. 9(2)(a) to withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given before its withdrawal;

4) lodge a complaint with a supervisory authority;

To exercise the rights listed above or to obtain more information, simply send an e-mail to the address: privacy@kubepartners.com, indicating in the subject „exercise of rights pursuant to GDPR“ and inserting in the body of the e-mail the right you wish to exercise. Once the Data Controller has processed what has been received, it will send a response within the terms indicated by Art.12 of the GDPR.

We have the right to refuse to comply with your request only for one of the following reasons:

• to exercise the right to freedom of expression and information;
• to comply with legal obligations or to carry out a task performed in the public interest or to exercise official authority;
• for reasons of public health in the public interest;
• for archiving, research or statistical purposes, or to exercise or defend legal claims.

In complying with a valid request for deletion of data, we will take all reasonably practicable steps to erase the data in question.

The Data Controller advises that if it intends to further process personal data for a purpose other than that for which it was collected, before any further processing it will provide the data subject with information about this different purpose and any further relevant information, collecting, if necessary, specific consent. In particular situations (e.g. you work with us), the Data Controller adopts specific information notices contained in this document. Please note that the sending by visitors of e-mails to the addresses indicated on this site, for the purposes specified from time to time, involves the acquisition and subsequent processing of the sender’s address and any other personal data included in the message in the manner and for the purposes already indicated in the above information. This will also automatically imply the knowledge and acceptance of the privacy policy notice.

In accordance with the aforementioned legislation and principles, the processing that we will carry out of the data provided to us will be based on the principles of lawfulness, fairness and transparency and will be carried out in compliance with the principle of necessity for data processing, configuring our systems and computer programs so that the use of personal and identification data is reduced to a minimum, so as to exclude its processing when the purposes pursued, in individual cases, can be achieved through, respectively, anonymous data and appropriate methods that allow it to be identified only in case of need.

Navigation Data

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing.

Cookies Policy

A Cookie is a small text file that is placed by a website on the user’s hard drive. Cookies thus uniquely identify the browser’s browser. Cookies do not damage your computer and do not contain viruses. Cookies have the function of streamlining the analysis of web traffic or signaling when a specific site is visited and allow web applications to send information to individual users. The Cookies on our Internet pages are only technical, they do not reveal data about the user, they do not allow the transmission of personal information. Furthermore, it should be noted that the use of technical-functional Cookies does not involve any tracking of the user.

We therefore reiterate that on our site there are only technical and functional Cookies that support only the optimal navigation of the site itself and for this reason it is not necessary to give any prior consent.

Minor

In the communication of your personal data, you guarantee that you are at least 18 years old. The Data Controller does not intend to collect any personal data from individuals under eighteen years of age.

Applications through our website 

On our website there is a special section „Work with us“ – Kube Partners Italy srl ® dedicated to the possibility for any interested parties to send their Curriculum Vitae and thus apply to join our team. In this case, we inform you that you will find specific information on the web page indicated above.

Unsolicited applications

In the event that you decide to send us your application, regardless of our searches, we remind you that in compliance with the current privacy legislation, the candidate who spontaneously sends his/her Curriculum Vitae will receive appropriate information on the processing of personal data at the time of the first useful contact following receipt of the CV that has been sent spontaneously. During the recruitment process, the employer may examine the candidate’s „social profiles“ on a non-generalised basis, if the profiles of the candidate in question have non-private purposes. The collection and subsequent processing of the data acquired from these profiles will only be carried out to the extent that the collection is necessary and relevant for the performance of the work for which the application has been submitted, therefore the data collected during the recruitment, selection or internship process will be deleted as soon as it is clear that no job offer will be made, in the event that the proposed offer will not be accepted by the candidate or at the end of the internship period.

Legal

The information and materials published on the site are created and provided free of charge, however the Data Controller assumes no responsibility for possible errors or inaccuracies. This is without prejudice to your right to modify, add, remove any or all of the contents, as well as to suspend, interrupt or limit access to the site or the contents at any time and without prior notice and at your sole discretion.

The site and with it all its contents, even partial, the documents, the databases found and used there and the related consultation systems, are protected by current regulations on copyright, are the exclusive property of Kube Partners Italy srl and represent corporate assets protected by sector regulations.

As a result of the above, it is therefore recalled that the visitor to the site has no right to appropriate, reproduce, modify, translate, distribute, republish, in any form, even partially, or in any case to use the contents of the site except for strictly personal purposes.

The trademark, documentation, images, solutions, ideas proposed such as, characters, graphics, and any other trademarks and/or distinctive signs present on the site are the property of Kube Partners Italy srl or are granted for use to the latter, therefore cannot be used by any user of the internet without written permission.

Furthermore, the Data Controller cannot guarantee users that the website will operate continuously, without interruptions and in the absence of errors or malfunctions due to the connection to the Internet. If you have any problems with the use of our website, please contact/report any disruption to the following email address administration@kubepartners.com. Although the Owner will try to do everything possible to ensure continuous access to its website, the dynamic nature of the Internet and its contents may not allow Kube Partners Italy srl® to operate without suspensions, interruptions or discontinuity due to the need to update the website. The owner assumes no responsibility for damages resulting from the inaccessibility of the services on the website, the interruption of the service, the deletion of content, problems related to networks, suppliers or telephone and/or Internet connections, unauthorized access, alteration of data, failure and/or malfunction of electronic equipment. It will be the user’s responsibility to protect and use their personal data correctly, and to be responsible for any harmful consequences or detriment that may arise to the Data Controller or third parties from the incorrect use, loss or theft of data.

Links to other websites

Our website contains hypertext links (e.g. here Clients – Kube Partners Italy®)  to other websites that have no connection with our company. The Data Controller does not control or monitor these websites and their contents. The Data Controller, therefore, cannot be held responsible for the contents of these sites and the rules adopted by them, also with regard to their privacy and the processing of their personal data during browsing operations. We therefore ask you to be careful when connecting to these websites through links on our site and to carefully read their terms of use and privacy policies. In fact, we remind you that our Privacy Policy and our legal notes do not apply to websites managed by parties other than the Data Controller. Kube Partners Italy s.r.l. provides links to other websites solely to facilitate its users in search and navigation and to facilitate hypertext links on the Internet to other websites. The activation of the links does not imply any recommendation or recommendation by the Data Controller for access to and navigation of these websites, nor any guarantee regarding their contents, services or goods provided by them to Internet users.

Link to Kube Partners Italy srl ®

Anyone interested in activating links to the Home page and other web pages of Kube Partners Italy®, which are publicly accessible, is kindly requested to contact us at the following e-mail address: administration@kubepartners.com. The contact is necessary to activate the request for consent to the hyperlink to our company site.

The activation of links is granted by the Data Controller to the applicant, free of charge and on a non-exclusive basis. We remind you that the Data Controller has the right to object to the activation of direct links to its website. In any case, it is forbidden to activate deep hypertext links (such as deep frames or deep links) to Kube Partners Italy srl® or the unauthorized use of meta-tags, without the consent of the Manager. Any unauthorized activation of links will result in the right of the owner to take any action for the immediate deactivation of illicit links and for the recognition of unfair commercial practice, unfair competition or action that ruins the good name and popularity of the company and/or the website and/or its services.

By accessing the site and browsing its web pages, the user declares that he/she accepts the legislation in force in Italy. Furthermore, this Privacy Policy and the Legal Notes are written and interpreted in Italian, therefore the Italian version will prevail for all purposes, including disputes or claims that can be resolved through any legal proceeding, over any other translation offered by the site as a courtesy of the documents (Privacy Policy and Legal Notes) mentioned above.