PRIVACY AND COOKIES POLICY

Version 2.0

Knowage suite and the related Website belongs to Engineering Ingegneria Informatica S.p.A.

Engineering Ingegneria Informatica S.p.a. with registered offices in Rome, Piazzale dell’Agricoltura, 24 (hereinafter “Engineering”) is committed to protecting the online privacy of its websites’ users. As such, this Privacy Policy has been drafted pursuant to art. 13 of EU Regulation 2016/679 (hereinafter: the “Regulation“) in order to allow you to understand Engineering’s policy regarding your privacy, and to understand how your personal information is handled when you are using our website (www.knowage-suite.com, hereinafter “Website” ). This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.

The information and data you may provide or which may otherwise be collected in the context of your use of Engineering’s services, – e.g., access to reserved areas in the Website, Contact Us form and Newsletter subscription, etc. (hereinafter the “Services”) – will be used by Engineering in compliance with the Regulation. This means, in particular, that any personal data processing carried out by Engineering will respect the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.

1. Data Controller

The Data Controller regarding all Personal Data processing operations carried out through the Website is Engineering as identified above. For any information regarding the processing of Personal Data by Engineering, including the list of Engineering’s data processors, please contact: knowage.privacy@eng.it

2. Personal Data processed

As you use Website, we inform you that Engineering may collect and process information related to you as an individual and which allows you to be identified (either directly, or together with additional information), or which is related to other individuals, such as your name, an identification number, an online ID or one or more characteristic elements of your physical, physiological, mental, economic, cultural or social identity (“Personal Data”).

Personal Data which may be processed by Engineering through the website are as follows:

1. • a) Browsing Data

The Website’s operation, as is standard with any website on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Engineering does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information is also considered Personal Data.

This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.

These data are used exclusively to compile anonymous, statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website – the data is deleted immediately after processing, unless it must be used to identify responsible parties in the event of cybercrime committed which harms the Website or third parties, in which case information on web contacts may be kept for a period of 3 (three) months.

1. • b) Data provided voluntarily by the data subject

When using some of the Website’s Services (e.g.,Contact Us Form), you are allowed to submit Personal Data related to other persons.

In any situation where you decide to share Personal Data related to other persons through the Website, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means that you must also make sure that you have these third parties’ consent to their Personal Data being used in this manner before providing them to Engineering, or another appropriate legal basis pursuant to article 6 of the Regulation which may allow for lawful processing of this information.

To this end, you must fully indemnify Engineering against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, initiated by the third parties whose information is processed via the Website by your initiative.

1. • c) Cookie

Definitions, characteristics and application of the legislation
Cookies are small text files that may be sent to and registered on your computer or mobile device by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.

Cookies are, therefore, used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.

When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e. “third-party cookies”).

There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer or mobile device for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.

Under Italian law, your express consent is not always required for the use of cookies. In particular, “technical cookies” – i.e., cookies used exclusively to transmit messages over an electronic communications network, or otherwise strictly necessary to provide a service explicitly requested by you – do not require your consent. In other words, cookies which are indispensable for the operation of the Website or required to perform activities you request may be used without your consent. The Italian Data Protection Authority (as defined in its “Determination of simplified procedures for information and collection of consent for the use of cookies”, 8 May 2014, and subsequent clarifications), has established that, among cookies which can be used without consent, the following are included:

1. 1. • Analytics cookies, when used directly by a website operator to collect information, in an aggregate form, on the number of users and how they use a website;
      • Browsing or session cookies, to identify and authenticate users of a website;
      • Function cookies, which allow users to browse a website according to a series of selected criteria (e.g., a certain language, products selected for purchase, etc.), in order to improve the services provided to those users.

On the other hand, “profiling cookies” – i.e., cookies used to create profiles on users and used to send advertising messages in line with the preferences revealed by users while browsing websites – require users’ prior consent.

Types of cookies used by the Website and the possibility of (de-) selection
The Website uses the following types of cookies:

1. 1. • Technical cookies, which are strictly necessary for the Website’s operation and/or to allow you to use the Website’s content and services;
      • Browsing or session cookies, which are necessary to identify and authenticate users of the Website;
      • Function cookies, which are used to activate specific Website functions and to configure the Website according to your choices (e.g., language), in order to improve your experience.

Engineering also uses third-party cookies – i.e. cookies from websites / web servers other than the Website, and which are used for specific purposes of the third parties owning those websites / webservers (including profiling of users). These third parties will either act as independent data controllers regarding their cookies, and therefore you must refer to their privacy policies, information notices or other materials to obtain more information on them – however, in such circumstances Engineering cannot control or ascertain the use which may be made, by these third parties, of third-party cookies, nor their exact characteristics or purpose – or as joint controllers together with Engineering. In such cases, the relationship between Engineering and the third party will be regulated by a joint controllership agreement.

The Website contains also “social plugins” for Facebook, Twitter, Linkedin. These are parts of the page visited directly generated by these sites and integrated into the page of the host site. The most common use of social plugins is aimed at sharing content on social networks.

The presence of these plugins involves the transmission of cookies to and from all sites managed by third parties. The management of the information collected by “third parties” is governed by the relevant information to which please refer. To ensure greater transparency  and convenience, below are the web addresses of the different information of third – party cookies

The following section lists the links to information on third – party cookies:

1. 1. • Matomo: https://matomo.org/privacy-policy/
      • Twitter: https://twitter.com/en/privacy
      • Google: http://www.google.co.uk/intl/en/policies/privacy/
      • Linkedin: https://www.linkedin.com/legal/privacy-policy
      • Mailchimp: https://www.intuit.com/privacy/statement/

Cookies on the Website

Cookie settings

You can authorize, block or delete all or some of the cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, refer to the following instructions:

1. 1. • Internet Explorer
      • Firefox
      • Chrome
      • Safari

To delete all cookies, please click here: Delete Cookies.

CAUTION: If you block or delete technical and/or function cookies used by the Website, the Website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur, in which case you will have to modify or manually enter some information or preferences every time you visit the Website.

3. Purpose of the processing

Engineering intends to use your Personal Data, collected through the Website, for the following purposes:

1. 1. To provide Services you request, such as: i) granting access to reserved areas of the Website; ii) subscription to newsletters; iii) registration for webinars, iv) to respond to any of your requests for assistance or information etc. (“Service Provision”);
   2. For compliance with laws which impose upon Engineering the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
   3. To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”).
   4. “For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, SMS, mms, over the phone, as well as for marketing activities in the broad sense. (“Marketing”).
   5. “Sending you direct e-mail marketing communication regarding products and services identical or similar to those you have previously purchased or requested via the Website (“Soft Marketing”).”
   6. Data Controller may receive reports in anonymous and aggregate form from some social media providers (eg LinkedIn, Facebook, Google, etc.) regarding, for example, the performance of Company products advertisements on the social media providers or users who view these advertisements or also demographic / professional data. No personal information (eg name, last name or e-mail address) that allows, even indirectly, to trace the user’s identity is transmitted to the Data Controller by the aforementioned social media providers (“Targeting of social media users”)

4. Legal basis and mandatory/discretionary nature of the processing

Engineering’s legal bases to process your personal data, according to the purposes identified in Section 3, are as follows:

1. 1. • Service Provision: processing for these purposes is necessary to provide the Services and, therefore, the applicable legal basis is the necessity of the processing for the performance of a contract with you, as well as to take steps at your request prior to entering into a contract with you – Art. 6(1)(b) of the Regulation. It is not mandatory for you to give Engineering your Personal Data for these purposes; however, if you do not, Engineering will not be able to provide any Services to you, nor will be able to answer any requests.
      • Compliance: processing for this purpose is necessary for Engineering to comply with its legal obligations and, therefore, the applicable legal basis is the necessity of the processing for compliance with the data controller’s legal obligations – Art. 6(1)(c) of the Regulation. When you provide any Personal Data to Engineering, it must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
      • Misuse/Fraud: information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potential criminal purposes. Th applicable legal basis is Engineering’s legitimate interest pursuant to art. 6(1)(f) of the Regulation.
      •  Marketing: processing for these purposes is based on your consent pursuant to art. 6(1)(a) of the Regulation. It is not mandatory for you to give consent for this purpose and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from Engineering). Any consent given may also be withdrawn at a later stage”.
      • Soft Marketing: processing for these purposes is based on Engineering’s legitimate interest in accordance with art. 6(1)(f) of the Regulation in sending you direct e-mail marketing communications regarding products and services which are identical or similar to those you have previously purchased through the Website. You can block these communications by objecting through the link provided at the bottom of all such communications and you will suffer no consequence if you do so (aside from not being able to receive further communications)”.
      • Targeting of social media users:processing of this purposes is based on  Engineering’s legitimate interest in accordance with art. 6(1)(f) of the Regulation

5. Recipients of Personal Data

Your Personal Data may be shared, for the purposes listed in Section 3, with different persons/entities (hereinafter and collectively, “Recipients”):

1. 1. • Entities acting as data processors on Engineering’s behalf, in particular:
        • Persons, companies or professional firms providing Engineering with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services;
        • Entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers); and
        • Persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks).
      • Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
      • Persons authorised by Engineering to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Engineering).

6. Transfers of Personal Data

Some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. The Company ensures that your Personal Data are processed by these Recipients in accordance with the Regulation. Under the Regulation, these transfers can be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission. Further information is available at Engineering by writing to the following address knowage.privacy@eng.it.

7. Retention of Personal Data

Personal Data processed for Service Provision will be kept by Engineering for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, Engineering will keep them for as long as the statute of limitations on liability related to the provision of the Services (as determined by the applicable law) lasts, so as to protect its interests.

Personal Data processed for Compliance will be kept by Engineering for the period required by specific legal obligation or by the applicable law.

Personal Data processed for preventing Misuse/Fraud will be kept for as long as deemed strictly necessary to fulfil the purposes for which it was collected.

Personal Data processed for Marketing will be delete after 24 months from its provision or until it is withdrawn. Where it is not withdrawn, consent will be renewed at fixed intervals. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be, in particular as may be necessary to protect Engineering’s interests related to potential liability connected to this processing.”

Engineering may retain some data even after the termination of the contractual relationship, for the time necessary to fulfil contractual and legal obligations.

Personal Data processed for Soft Marketing will be kept until you object to this processing via the link you can find at the bottom of every e-mail”.

Further information on Personal Data retention periods and the criteria adopted in determining these periods, please contact the DPO at the following address: knowage.privacy@eng.it

8. Data subject rights

Pursuant to Articles 15 and following of the Regulation, you, as a data subject, are entitled to request from Engineering, at any time, access to your Personal Data, the correction and erasure of your Personal Data, as well as to object to its processing. You are also entitled to request the restriction of the processing of your Personal Data in the cases set out in Article 18 of the Regulation, as well as to obtain the Personal Data you have provided to Engineering in a structured, commonly used and machine-readable format, in the cases set out in Article 20 of the Regulation.

In addition, if you have given your consent for marketing communications by ticking the relevant boxes, you can opt out of receiving such communications at any time by using this link (link to unsubscribe form). In this case Engineering will retain your data only the extent necessary to record your request to stop receiving such communications.

Requests should be addressed in writing to Engineering or to the DPO at the following address: knowage.privacy@eng.it.

In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through this Website violates applicable law.

9. Amendments

This privacy policy is effective from 20^th March 2020. Engineering reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Engineering will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. Engineering therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how Engineering collects and uses Personal Data.