PRIVACY POLICY STATEMENT FOR VISITORS OF LATI WEBSITES

Pursuant to art. 13 GDPR EU 2016/679

(Re. PRV2021070601R3-EN)

LATI Industria Termoplastici S.p.A. (hereinafter, LATI) herewith informs you about the purpose and method for the processing of your personal data and about your rights according to the Regulation of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of personal data (“GDPR”) collected while browsing the websites managed by LATI.

1.   Types of data

The data referred to in this statement is personal data collected automatically while browsing the www.lati.com website and other related websites, or the data provided voluntarily by the Data Subject.

We inform you that "personal data" means "any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person." 

The data collected can be grouped into the following categories:

A) “Common” personal data

The website collects data provided voluntarily by the visitor such as, depending on the situation, the personal information and contact details (name, family name, address, telephone number, date of birth, e-mail address,...) necessary to accept applications for participation in events and promotional initiatives organised by the Data Controller or to send promotional communications such as, by way of example, newsletters, invitations to events, invitations to webinars, emails containing articles related to our engineering materials and their applications, email containing documents relating to the products and services in which the visitor has shown interest or relating to the visitor’s business.

The website also allows visitors to submit their CVs for personnel recruitment purposes. The processing will not involve sensitive data, pursuant to art. 9 par. 1 ("special categories of personal data").

The candidate, therefore, will not be required to provide data pertaining to "special categories", according to art. 9 GDPR, i.e. "sensitive data" revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation. This data, if any, contained in the CV or in other documents sent to us (including data revealing, by way of example, one’s state of health, or pertaining to protected categories) will be immediately erased.

Persons belonging to a protected category are therefore invited to send their CVs only by ordinary mail to the address of the Data Controller, together with the following signed declaration of consent: "Pursuant to art. 9 of Reg. 2016/679, I authorise LATI Industria Termoplastici S.p.A. to process my sensitive data for the purposes specified in this statement."

B) Navigation data

Like all websites, this site also makes use of log files storing information that is collected in an automated manner from the website visitors. The information collected may be the following:

•   IP address;

•   type of browser and operating system of the device used for connecting to the website;

•   date and time of visit;

•   website pages visited;

•   visitor’s referral and exit page.

C) Cookie policy

This site uses cookies, i.e. text files recorded on the user's device or allowing access to information therein. Cookies are used for storing information on the visitors’ preferences, verifying the correct operation of the site and improving its functionality by customising the content of the pages based on the type of browser used, or simplifying browsing by automating the procedures (e.g. login, site language) and finally analysing the way the website is used by visitors.

For more details, please refer to the specific “Cookie Policy” statement.

2.   Legal basis for the processing

The legal basis of the processing is the legitimate interest of the Data Controller to promote relations and business relationships with its business contacts as well as the consent of the Data Subject, if given.

3.   Data processing purpose

•   The navigation data is processed in an automated manner and collected in an exclusively aggregated form in order to check the performance of the site, to undertake anonymous statistical surveys on its use as well as for security reasons in order to prevent any damage or illegal conduct.

•   The personal data collected by the Data Controller – or by third parties designated by the Data Controller for personnel recruitment procedures – is processed and used to meet the requests of the Data Subjects and, more precisely, to verify the conditions for recruitment and/or the start of a working relationship.

•   The personal data collected in relation to applications for participation in events and promotional initiatives organised by the Data Controller is processed and used exclusively to meet the requests of the Data Subjects.

•   The data collected in order to answer questions or to have access to documents will be used for the provision of the requested service or for contacting the applicant in order to gain further insight into the related issues.

•   The data provided for sending e-mails is intended as voluntarily provided by the user at the time of the request for the delivery of the service and will be used exclusively for the provision of the service requested.

•   The contact details may be used for marketing purposes related to the promotion and sale of Lati products and services. The lawfulness of the processing is based, therefore, on the consent manifestly expressed by the Data Subject by flagging the relevant form. In particular, the activities in question are carried out using the "Inbound Marketing" method which consists of a set of digital strategies aimed at stimulating the commercial interest of the subjects contacted by showing and sending content about products and services that may meet their specific interest. To this end, promotional communications may be made, such as, for example, newsletters, invitations to events, invitations to webinars, emails containing articles related to our engineering materials and their applications, email containing documents relating to the products and services in which the visitor has shown interest or relating to the visitor’s business. All this with the simultaneous storage of the pages visited, for statistical purposes.

If the processing of personal data is intended for a purpose other than that for which they were collected, the Data Controller will provide the data subject with information regarding this different purpose and any other relevant information before such further processing.

4.   Data processing method

The processing will take place using IT and / or telematic tools, with organisational methods and principles strictly related to the aforementioned purpose.

In particular, for the marketing activity carried out according to the aforementioned "Inbound Marketing" method, the "Hubspot" digital platform will be used, consisting of an all-in-one marketing automation software.

5.   Data processing location

The navigation data collected from the website is processed at the company hosting the website itself, located in Italy. The personal data provided voluntarily by the visitor is processed at the Data Controller's head office or hosted on the Data Processor "Hubspot, Inc." infrastructure in the European Union. CV data is hosted on the Data Processor "Intervieweb S.r.l." infrastructure in the European Union.

6.   Mandatory or optional provision of personal data - consequences of denial

The voluntary provision of common personal data related to services that require such data is optional, yet necessary for the delivery of these services. Therefore, the denial to provide this data results in the impossibility of obtaining the desired services.

7.   Disclosure of personal data

The navigation data collected from the website will not be disclosed to third parties for any reason, unless it is requested by a judicial authority and only in the cases provided for by law.

The data relating to the organisation of events might be communicated to the subjects involved in the management of the same.

In addition to the Data Controller, certain categories of persons involved in the organisation of the site may have access to personal data (administrative, commercial and marketing staff, legal advisors, system administrators) or external entities (such as technical service providers, mail services, hosting service providers, IT companies, communication agencies). If necessary, these entities are appointed as Data Processors. The updated list of Data Processors can be requested from the Data Controller at any time.

8.   Transfer of data abroad

This site does not provide for the sharing of personal data outside the European Union.

9.   Data storage period

•   The log files for access to the website are kept for 2 weeks.

•   The data collected in order to assess the conditions for recruitment and/or the start of a working relationship will be stored by the Data Controller for a maximum of two years after their collection unless a working or employment relationship is established.

•   The personal data collected in relation to applications for participation in events and promotional initiatives organised by the Data Controller will be retained for the period strictly necessary to achieve the purposes for which they were collected and in any case for a maximum period of one year.

•   The data provided for the purposes of sending e-mails is considered as provided voluntarily by the user at the time of the request for service and will only be used for the time necessary to deliver the service requested and in any case for a maximum period of one year from the last contact.

•   Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until the satisfaction of this interest. The ser can obtain further information regarding the legitimate interest pursued by the Owner by consulting the relevant sections of this statement or by contacting the Data Controller.

10.   Rights of the Data Subject

In relation to his personal data, the Data Subject may exercise the rights guaranteed under art. 15 GDPR EU 2016/679 on the protection of personal data processing. The Data Subject has the right to obtain confirmation of the existence of personal data concerning him and its communication in an intelligible form.

The Data Subject also has the right to obtain information on the origin of the data, on the data processing purpose and method, on the Data Controller and its Representative, on the entities to which the data may be disclosed.

The Data Subject has the right to have his personal data rectified, supplemented, updated, as well as to obtain their erasure or transformation into anonymous form.

The Data Subject can obtain at any time the termination of any information communications using the "Unsubscribe" function on the e-mails received.

The Data Subject can request the termination of any communication at any time by contacting the Data Controller through an e-mail message.

11.   Data Controller and Data Protection Officer

The Data Controller is LATI Industria Termoplastici S.p.A., with registered office in Vedano Olona (VA) via F. Baracca 7. We inform you that pursuant to art. 37 GDPR, the Data Controller has designated a Data Protection Officer.

Data Processors

•   Hubspot Inc. is designated as Data Processor, processing data on the behalf of the Data Controller as the manager of the digital platform hosting the data collected for marketing purposes.

•   Intervieweb S.r.l. is designated as Data Processor, processing data on the behalf of the Data Controller as the manager of the digital platform hosting the CV data.

For any further information, please contact: [email protected].

Vedano Olona, 21 March 2023

Terms and conditions of use – Rights and responsibilities of the LATI Industria Termoplastici S.p.A. portal user

1. Scope of the agreement

This page, to be read carefully, sets out the "terms and conditions" governing the use of the LATI Industria Termoplastici S.p.A. portal (hereinafter, the "Portal") by LATI Industria Termoplastici S.p.A. (hereinafter, the "Company"). To be able to use the services offered on our Portal, you must first accept these terms and conditions by clicking on the relevant button. If you do not accept these terms and conditions, you will not be able to use this Portal or the services offered. The Company reserves the right to amend these terms and conditions at any time, without notice. The terms "you" and "user", used herein, refer to the natural and legal persons that, for any reason, access this Portal.

1. Permitted use of the Portal

General rules: Users may not use the Portal to transmit, distribute, store or destroy material (a) in a way that violates any applicable laws or regulations, (b) in a way that infringes or violates copyrights, trademarks, trade secrets or other intellectual property rights, or that violates the privacy or personal rights of third parties, (c) in a way that is defamatory, obscene, or offends common decency and undermines public order.

Security rules: Users must not violate or attempt to violate the security system of the Portal. Equally, users are prohibited from (a) accessing data not intended for their user type, or entering the server or an account that users are not permitted to access, (b) attempting to analyse, establish or test the vulnerability of the system or network, or breach security or authentication measures without specific authorisation, (c) trying to interfere with the service supplied to any other user, such interference including but not limited to that caused by introducing a virus into the Portal, overloading the system, or using flooding, spamming, mailbombing or crashing techniques, (d) sending unsolicited e-mails, concerning, for example, promotions and/or advertising of products or services, and (e) spoofing any TCP/IP packet header or any other information relating to the headers of e-mail messages, either individual or addressed to groups of people (newsgroups). Any violation of system or network security may expose you to civil and/or criminal liability. The Company will therefore investigate any behaviours that could result in violation of criminal or civil laws, and may involve, or cooperate with, the competent authorities in pursuing users involved in such violations.

1. Specific prohibited uses

The Portal may be used only for legally permitted purposes by individuals looking for work or for information about future job opportunities, and by employers looking for personnel. The Company prohibits the below listed uses of the Portal (and all users agree not to use it for these purposes). It is prohibited:

(a) to enter incomplete, false or inaccurate personal data or, in any case, information not corresponding to the user’s true personal profile;

(b) to cancel or modify content inserted by another user;

(c) to use any device, software or computer programming routine liable to interfere with the operation of the Portal or with any activity on the Portal;

(d) to take any action that imposes an unreasonable or disproportionately large load on the Portal's infrastructure;

(e) to disclose or share your password with third parties or use your password for any unauthorised purpose that may result in access to the Portal’s reserved areas;

(f) to use or attempt to use search engines, software or other devices or mechanisms (including but not limited to browsers, spiders, robots, avatars and intelligent agents) to browse or explore this Portal, except as otherwise envisaged in these terms and conditions, or unless these are devices or search engines made available by the Company on the Portal itself or browsers available to the general public (e.g. Netscape Navigator, Microsoft Internet Explorer);

(g) to attempt to decipher, decompile, disassemble or rebuild the content of software used for structuring the Portal.

1. User’s personal data

When registering on our Portal you will need to provide us with some personal data (hereinafter "personal data"). With regard to the processing of this personal data by the Company, we invite you to read the terms of our ‘personal data protection policy’ which can be found on our website. You are reminded that consent to the processing of your personal data is a requisite for registering on the LATI Industria Termoplastici S.p.A. Portal and for accessing the services provided thereon.

1. User’s obligations

The user is responsible for the consequences that may ensue from entering data, information and content of any kind in the Portal. The user is prohibited from: (a) entering copyrighted content, unless the user is the holder of the relative copyright or has received authorisation from the copyright holder; (b) entering content that discloses trade secrets, unless the user has ownership of the same or has or received authorisation from the owner; (c) entering content that infringes the intellectual property rights of others, the privacy of others, or rights relating to advertising contracts; (d) uploading, publishing, entering or otherwise transmitting content that is unlawful, threatening, obscene, defamatory, racist or that offends common decency and undermines public order; (e) entering sexually explicit images or text; (f) uploading, publishing, e-mailing or otherwise transmitting or distributing promotional material, junk mail, spam or any other form of unauthorised or unsolicited request; (g) posting chain or pyramid messages; (h) falsifying one’s identity and (i) uploading, e-mailing, otherwise transmitting any material containing viruses, Trojan horses, worms, time bombs, cancelbots or other codes, files or programs designed to interrupt, destroy, or limit the operation of third-party software, hardware or telecommunications installations. The Company in no way guarantees the truthfulness, accuracy and reliability of statements submitted by users and accepts no responsibility for the opinions expressed by users. Users must be aware that the Company does not guarantee the truthfulness of content entered by other users, and that they therefore use this content at their own risk.

The Company operates merely as an interface for the online publication of information and data entered by individual users, and is under no obligation to assess, in advance, the uploaded messages, data and information. Should a user draw the Company’s attention to any messages, data and information on the Portal that might be considered non-compliant with the present terms and conditions, the Company will duly investigate and decide, in good faith and at its sole discretion, whether to remove or request removal of the content in question. Furthermore, the Company reserves the right to expel users who violate the terms of the agreement or break the law, and prohibit them from accessing the Portal in the future. The Company also reserves the right to remove content that is threatening, obscene, defamatory racist or that offends common decency and undermines public order. The Company may, at its own discretion, take all the measures it deems necessary and opportune in relation to content provided by users, if it believes that the said content could expose the Company to liability or in any case result in the Company suffering a loss of or reduction in the services it receives from its ISPs or other suppliers.

Without prejudice to the provisions of applicable legislation, in uploading content (with the exclusion of personal data) on the Portal (including the spaces for messages, forums, competitions and chat rooms), the user grants the Company a perpetual, irrevocable right (which may, in turn, be sublicensed non-exclusively) and licence to use, copy, modify, adapt, publish, translate, create derivative works from, distribute, publicly communicate, display and use the said content (in full or in part) throughout the world and/or to incorporate it in other works of any form, using any means of technology, already known or yet to be developed.

The user guarantees that any rights to content he/she uploads have been completely relinquished by the holder of the same, who has irrevocably and legitimately transferred, to the user, the right to grant the above licences. The user grants all other users registered on the Portal the right to access, display, examine, store and copy this content for their personal use.

Without prejudice to the above provisions, the holder retains all rights to the content entered in the Portal.

1. Account and Password

When you reach the end of the registration procedure, you will be assigned an account and a password. It is your sole and exclusive responsibility to keep your account and password details secret; therefore, you alone will be held responsible for any activity resulting from use of your account or password by third parties to whom you have disclosed the aforementioned details, or who have obtained the same through your negligence. You undertake to promptly notify the Company of any unauthorised use of your password.

1. Liability of the Company

The Company allows employers, independently, to offer new job opportunities, and job seekers to insert their profiles in the Portal. The Company does not carry out any kind of monitoring or checking of content entered in the Portal. The Company has absolutely no involvement in negotiations between employers, other partner organisations, clients and candidates: therefore, the Company has no control over the quality, safety or legality of the job opportunities offered or profiles entered, the truthfulness or accuracy of the data entered, the capacity of employers to offer jobs, or the skills and working capacity of the candidates. Furthermore, it must be borne in mind that online contact with strangers, foreigners, minors or persons who may be using a false identity carries risks of various kinds, including the risk of physical harm. Anyone consulting the Portal therefore assumes all the risks that may derive from establishing contact with other users through the Portal.

Given the difficulty establishing, through the Internet, the identity of other users, the Company cannot offer any assurances regarding the true identity of users with whom you come into contact. The Company is not involved, and cannot get involved, in user-to-user relationships or control the behaviour of users on the Portal; therefore, in the event of disputes arising between users, you hereby agree to indemnify the Company (including its agents/collaborators and employees) and hold it harmless from any and all damage you may incur as a result of such disputes.

The Company has no legal obligation in this regard, and in general does not check the information, or content provided by users and entered in the Portal database. It should also be borne in mind that information entered by other users could be offensive, inaccurate and, in certain cases, deliberately misleading. The Company expects you to exercise great caution and common sense in using the Portal. You are also informed that content may contain inaccuracies or typographical errors. The Company does not guarantee the accuracy, reliability, completeness or timeliness of information contained in the Portal or in its content. You therefore use our Portal and its content entirely at your own risk. Also be aware that our Portal is modified from time to time, and may be modified at any time. In any case, you hereby acknowledge that you are solely responsible for the form, content and accuracy of the material that you enter in the Portal. Prospective employers have sole responsibility for the information and job offers they enter in the Portal.

The Company must not be regarded as an employer with regard to the services offered on the Portal. Furthermore, the Company bears no responsibility at all for hiring decisions taken by employers who use the Portal. The Company does not guarantee that the Portal is error-free or that the Portal or server is free of viruses or technical defects of any other kind. Should use of the Portal or material it contains result in damage to your IT tools or data, the Company is absolutely not liable for costs related to maintenance services, repairs or replacements. The Portal services and content are offered by the Company on an “as is” basis, without any type of guarantee. The Company, in conformity with legal provisions, offers no warranties, express or implied. Accordingly, the Company makes no guarantees regarding the accuracy, reliability and completeness of the content, services, software, texts, graphics and links. The User acknowledges the neither the Company, nor any other party involved in the creation, production and supply of the services provided by Intervieweb.it can he held responsible for any damage of any kind, arising, in contract or in tort, from the activation or use of the services offered on the Portal and/or from Portal malfunctions. Under no circumstances will the Company be held responsible for service malfunctions resulting from telephone line or power failures or from breakdowns or overloading of national, global and international networks.

1. Indemnity

The user hereby states that it indemnifies and holds harmless the Company (including all subjects connected with or controlled by it, its representatives, collaborators and employees) from any claims for damage (including reasonable legal fees) incurred through use of the Portal and its content, or as a result of violation of these terms and conditions. 

1. Links to other websites

The Portal may contain links to other websites; the Company bears absolutely no responsibility for the content of these sites, and therefore makes no guarantees regarding the content and accuracy of the material present on them. Should you access sites linked to Intervieweb.it, you do so entirely at your own risk.

1. Prohibition of sale or unauthorised commercial use

You hereby undertake not to sell or transfer your rights or obligations under the present terms and conditions of use of the Portal. You also undertake not to make unauthorised commercial use of the Portal.

1. Termination

The user acknowledges that the Company may, at its own discretion, disable the user's password and account or interrupt the use of the service at any time, after giving the user at least 5 days’ prior written notice by e-mail. The Company reserves the right to declare this contract terminated, under the terms of Art. 1456 of the Italian Civil Code, giving the user written notification by e-mail, should the latter be in breach of any of the obligations set out in points 2, 3, 4, 5, and 9 of these terms and conditions.

1. General provisions

Should any provision of these terms and conditions be deemed invalid by the competent judicial authority, the invalidity of the said provision will not affect the validity of the other provisions, which will remain in force. Except as expressly provided for in further conditions of use of the Portal, in legal notices or the software licence, or on certain other web pages, the present terms and conditions contain all the provisions governing the agreement between you and the Company in relation to your use of the Portal.

1. Further conditions of use of the Portal

Other areas that can be accessed from this Portal are subject to further and different terms and conditions of use of the relative services. In using these other areas of the Portal, you agree to comply with the further conditions applicable to the said areas.

1. Jurisdiction and arbitration

These terms and conditions and the relationship between the Company and the user are governed by Italian law. Any disputes that may arise in relation to the present agreement shall be settled by arbitration at the Court of Turin, Italy.