PRIVACY INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA OF THE USERS VISITING THE ALTANOVA GROUP WEBSITE
according to art. 13 of the Regulation EU no. 2016/679

Altanova Group wishes to inform the users of its website www.altanova-group.com, www.isatest.com, www.techimp.com and www.intellisaw.com (hereinafter, collectively referred to as the “Websites” and individually the “Website”) that the personal data to them referred or referable are processed by the Companies belonging to its Group in compliance with the current regulations concerning the processing of personal data – and, specifically, with UE Regulation n. 2016/679 (hereinafter “GDPR”) and Legislative Decree n. 196/2003, as subsequently amended by Legislative Decree n. 101/2018 (“Privacy Code”) – and with the confidentiality obligations which have always inspired us.

By “Processing of personal data” we mean any operation or set of operations, carried out even without an electronic means support, related to data collection, record, organization, storage, consultation, elaboration, modification, selection, retrieval, alignment, use, combination, block, communication, disclosure, erasure and destruction, even if not recorded into a data base.

In particular, this privacy information notice on the processing of personal data (hereinafter, “Privacy Notice”) describes the purposes and means of the processing of the personal data that are collected through our Websites and that are referred or referable to the users who navigate and consult such Website (hereinafter, the “Users” or the “Data Subjects”) pursuant  to art. 13 of the GDPR. Furthermore, we hereby clarify that the websites www.isatest.com, www.techimp.com and www.intellisaw.com are showcase sites dedicated to each individual Altanova Group company, but are strictly connected to the main website www.altanova-group.com which they are part of. Therefore, by visiting such websites the User could be redirected to some pages and/or sections of the main website www.altanova-group.com. In any case, all Websites are managed by Altanova which processes the Users’ personal data collected during the navigation on the Websites as data controller. Such processing will, hence, be regulated by this privacy information notice, which applies indistinctively to all Websites, for the reasons above.

Data Controller

ISA Altanova Group Srl, with offices in Via Freguglia 2, 20100 Milan (Italy), is the data controller (“Data Controller” or “Altanova”) of the Website Users’ personal data that can be contacted at the following address: privacy@altanova-group.com.

Data processed

The Data Controller processes the following types of personal data relating to the Users:

• personal details, including name and surname, as well as the role held in the company/entity to which the Data Subject belongs;
• the contact details, including the address, telephone number and e-mail address;
• the company name, the principal and secondary (if any) office addresses, the VAT number and/or tax code, in the event that the latter is a natural person or a sole proprietorship;
• navigation data relating to the IP address, identification codes of the devices used by the User for the use of the pages or services, data relating to the characteristics of the browser and the access timing and information regarding the activity carried out on the Websites

(hereinafter jointly the “Personal Data”).

For further information on the navigation data collected by the Website, on the purposes and means of their processing, please consult the Website’s Cookie Policy available at the following link: Cookie Policy - Altanova Group (altanova-group.com)

Purposes of the processing

The Personal Data that the Data Subject provides during the navigation on the Website, as well as through its “Contact” pages are collected and processed for the following purposes:

• to create and manage a personal account on the Website;
• to enjoy the services on the Websites, including signing up to receive Altanova’s newsletter; and
• to respond to information requests from Users, including to send potential informative material as requested by Users themselves (hereinafter jointly referred to as “Contractual Purposes”);
• to comply with the applicable legislation, including tax legislation (hereinafter, the "Law Purposes");
• with the Data Subject’s prior consent, to send commercial communications, through traditional and remote means of communication including e-mail, SMS/MMS, instant message, mobile applications, banners, mail and telephone, relating to the Data Controller’s products and services, as well as to carry out statistical analysis and market surveys (hereinafter, “Marketing Purposes”);
• with the User’s prior consent, to send commercial communications as per the point above personalized on the basis of the User’s interests and preferences (“Profiling Purposes”); as well as
• to exercise or defend the Data Controller’s rights, also with regard to credit recovery procedures, against Users or third parties in any dispute; and
• to perform activities functional to completing a potential merger, sale of assets or business transfers or other transformations and to execute such operations (hereinafter jointly referred to as "Legitimate Interest Purposes").

Legal bases of the processing

The processing of Personal Data for the Contractual and Law Purposes is essential for registering on the Website, enjoying the services offered by Altanova and responding to Users’ requests; any refusal to provide such Personal Data for such purposes could result in the complete or partial failure to provide the requested services.

The processing of Personal Data for Marketing Purposes and for Profiling Purposes is not mandatory and is based on the Data Subject’s specific consent. However, in the event the User decides not to provide the Personal Data for Marketing Purposes and for Profiling Purposes, it will not be possible for the Data Subject to receive updates on Altanova’s services and products, also personalized on the basis of one’s preferences and interests. In any case, the User has the right, at any time, to withdraw the given consent, free of charge, as well as to object to the commercial communications received via e-mail by clicking on the dedicated link at the bottom of such e-mails or by notifying such intention by sending an e-mail to privacy@altanova-group.com.

The processing of the Personal Data for the Legitimate Interest Purposes is carried out pursuant to Article 6, letter f) of the GDPR, for the pursuit of the Data Controller’s legitimate interest, which is adequately balanced with the Data Subjects’ rights and freedoms since the processing of the Personal Data is performed within the limits strictly necessary to perform the required economic activities and the other activities described above. The processing for the Legitimate Interest Purposes is not mandatory and the User can object to the data processing at any time as set out in this Privacy Notice, but in such case no data processing will be carried out for the Legitimate Interest Purposes, without prejudice to an overriding interest of the Data Controller in continuing the processing.

Method of personal data processing

The processing of the Personal Data takes place according to the principles of correctness, lawfulness and transparency, through the use of tools and procedures suitable for guaranteeing their security and confidentiality and can be carried out both on paper and with the aid of electronic tools.

The processing is carried out with the use of appropriate security measures to minimize the risk of unauthorized access to Personal Data by third parties, their destruction and/or deterioration, and to ensure confidentiality, pursuant to art. 32 of the GDPR.

Retention of Personal Data

Personal Data will be stored only for the time necessary to achieve the purposes for which they are collected as set out above and, more specifically:

• with regards to Contractual Purposes, for the time necessary for the management of the Data Subject's request and for the following 10 years;
• with regards to Law Purposes, for the duration prescribed for each type of personal data by the relevant laws;
• with regards to Marketing Purposes, for 2 years from the last interaction with the User (e.g. signing up for the newsletter, opening of a commercial e-mail, etc.);
• with regards to Profiling Purposes, for 1 year from the Data collection; and
• with regards to Legitimate Interest Purposes, for the entire duration of the Data Subject’s request management and for the following 10 years, in the event the Personal Data are necessary to protect and enforce the Data Controller’s rights against the Data Subject and/or third parties in any legal disputes. In the event the processing is aimed at carrying out activities functional to the transfer of a company or business, acquisitions, mergers or other transformations, the retention periods above will apply with respect to the main processing

At the end of the retention periods above, Personal Data will be deleted or anonymized.

Communication of Personal Data

Personal data will not be disclosed in any way, while they may be communicated to the following subjects located both inside and outside the European Union:

• the personnel belonging to the Data Controller as well as other persons in charge of their processing which are duly appointed within the Companies of the Altanova Group;
• external subjects, appropriately appointed as external data processors, including providers of ancillary and support services to those carried out by the Data Controller, within the limits strictly necessary to carry out the tasks entrusted to them (in particular, software or systems maintenance company, companies operating in the marketing and communications sector, administrative and tax consultancy consultants);
• other companies belonging to the group the Data Controller is part of and/or subjects transferring a company or business, companies resulting from possible mergers or any other transformation involving the Data Controller, acting as autonomous data controllers;
• public bodies whose right to access the Personal Data is provided for by the applicable legislation, acting as independent data controllers.

The complete and updated list of the data processors is available upon request to the Data Controller’s contact details, by sending an e-mail to privacy@altanova-group.com.

Personal Data Transfer

The Personal Data may be transferred to countries outside the European Economic Area (EEA) and, in particular, in the USA. In case of data transfer outside of the EEA, Data Subjects’ Personal Data will be transferred in compliance with the appropriate and suitable safeguards to carry out such transfer, pursuant to articles 44 et seq. of the GDPR.

Data Subjects’ Rights
The User, as data subject, can, at any time, exercise the following rights pursuant to art. 15-22 of the GDPR:

• Receiving confirmation if there is any Personal Data processing taking place and, if so, obtaining access to such Personal Data, know the related origin, the purposes of the processing and its methods, as well as the logic applied to the processing carried out by electronic means;
• obtaining the update of the Personal Data, and the rectification of incorrect Personal Data without unjustified delay. Considering the purposes of the processing, data subjects have the right to obtain the integration of incomplete Personal Data, even by supplying a supplementary declaration;
• obtaining the erasure of Personal Data without unjustified delay;
• obtaining the limitation of the processing, provided that the conditions of art. 18 of the GDPR are met;
• obtaining the Personal Data portability, meaning receiving in a structured, common use, readable format from automatic device, the Personal Data to him/her referred that had been previously supplied to the Data Controller;
• objecting, on grounds relating to his or her particular situation, to the processing of the Personal Data according to art. 6, par. 1, letter e) or f) of the GDPR. In this case, the Data Controller will stop processing further the Personal Data, provided there are no compelling legitimate grounds for continuing the processing, which override the interests, rights and on freedoms of the Data Subject or for the establishment, exercise or defense of legal claims;
• not being subject to a decision based only on automatized processing, producing legal effects in your regards or similarly significantly affects your person, pursuant to art. 22 of the GDPR;
• addressing to the Garante per la Protezione dei Dati Personali to lodge a complaint, shall you consider your Personal Data to have been processed unlawfully.

In case of the Data Subject’s death, the aforesaid rights relating to his/her Personal Data may be exercised by anyone who has a personal interest, or acts to protect the Data Subject as its representative, or for family reasons worthy of protection pursuant to article 2-terdecies of the Privacy Code. Data Subjects may expressly prohibit the exercise by their assignees of some of the rights above by written notice to be sent to the Data Controller as indicated below, without prejudice to their right to withdraw or modify such expressed intention later on according to the same procedure. 

Requests for the exercise of rights may be made in writing to the Data Controller, who can be contacted at the following e-mail address privacy@altanova-group.com.

Changes and Updates

This Privacy Notice is valid from the date of update indicated below. However, Altanova may subsequently update and/or integrate this Privacy Notice, also as consequence of possible subsequent amendments and/or integrations of the applicable laws. Changes will be notified in advance and Users will be able to consult the constantly updated version of this Privacy Notice via the following link www.altanova-group.com.

Taino, 5th July 2021