INFORMATION ON THE PROCESSING OF PERSONAL DATA PURSUANT TO ARTICLES 13/14 OF REGULATION (EU) 2016/679

Tecnopool S.p.A., with registered office at San Giorgio in Bosco (PD), via M. Buonarroti 81 – 35010, tax code/VAT number 01822250286, as the Data Controller (hereinafter: Tecnopool or “Controller”, “company”), pursuant to EU Regulation 2016/679 (hereinafter: “Regulation”) – considers privacy and the protection of Personal Data an important focus within its activities. We therefore invite you, before transmitting any personal data to the Controller, to read this Information notice carefully: it contains important information on the processing of your Personal Data. “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.

This Information notice:

• is also intended for the websites https://www.tecnopool.it – https://tpfoodna.com/ – https://tpfoodgroup.com/it/
• constitutes an integral part of the Site and the services we offer;
• is provided pursuant to Article 13 of the Regulation, to those who interact with the web services of the Site and the Controller, both through simple consultation and through the use of specific services made available through the Site.

The Data Controller can be contacted at: marketing@tecnopool.it . The Controller has not, for the time being, formally appointed a Data Protection Officer pursuant to Article 37 of EU Regulation 2016/679, as it believes it does not fall within the mandatory cases.

This document has been drawn up pursuant to Article 13 of EU Regulation 2016/679 (hereinafter: “Regulation”) in order to allow you to know our privacy policy, understand how your personal information is processed when you use our sites and, if applicable, to give free and informed consent to the processing of your Personal Data. The information and data provided by you or otherwise acquired in the context of using Tecnopool services – such as participation in events or training courses – hereinafter “Services” – will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that inspire Tecnopool’s activities.

According to the rules of the Regulation, the processing carried out by the Company will be based on principles of lawfulness, fairness, transparency, purpose and storage limitations, data minimization, accuracy, integrity, and confidentiality.

INDEX

1. Data Controller
2. Personal Data subject to processing a. Browsing data b. Data voluntarily provided by the data subject
3. Purposes of processing
4. Legal basis and mandatory or optional nature of processing
5. Recipients of Personal Data
6. Storage of Personal Data
7. Transfer of data abroad
8. Rights of the data subject
9. Amendments
10. Cookies

1. Data Controller

The controller of personal data processing is Tecnopool S.p.A. with registered office in San Giorgio in Bosco 35010 (PD), Via M. Buonarroti 81 which can be reached at the email address marketing@tecnopool.it .

2. Personal Data subject to processing

Following navigation of the Site, we inform you that the company will process your Personal Data which may consist of an identifier such as a name, an identification number, an online identifier or one or more elements characteristic of your physical, economic, cultural or social identity suitable to make the data subject identified or identifiable.

Other Personal Data freely provided by you in the information request forms may also be processed. Any sensitive data, as per Article 9.1 Reg. 2016/679/EU will not be processed except with explicit consent given by the data subject, in any case Tecnopool does not process special categories of data.

a. Browsing data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of computers used by users connecting to the Site, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the computer environment of the user. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site or third parties: except for this possibility, the data on web contacts do not persist for more than seven days.

b. Data voluntarily provided by the data subject

We may process personal and/or contact data such as name, surname, email, and telephone. All data contained in the curriculum vitae (e.g., data relating to degrees of training and education, etc.) sent to us spontaneously or in response to our ongoing search. Data and meta-data relating to courses and training services, including test and exam results and related information on date, time, and methods of using training services and/or executing tests. Data relating to payments and other banking information.

If you communicate Personal Data of third parties to Tecnopool, you must guarantee – assuming all responsibility – that this particular case of processing is based on an appropriate legal basis pursuant to Article 6 of the Regulation, which legitimizes the communication to the company and the related processing of the information in question.

3. Purposes of processing

The data processing we intend to carry out may have the following purposes:

a. Allow the provision of Services requested by you such as:

• registration to the site;
• subscription to the email newsletter see, in this regard, the marketing information specifically drawn up and traceable at the link (da inserire link dopo la messa online del privacy policy di marketing);
• registration for training courses;
• sharing of content on the site;
• generic request for information;
• registration for events and initiatives organized by Tecnopool;
• collection and analysis of curricula vitae for collaboration or affiliation purposes with the company

b. respond to assistance or information requests;
c. fulfill any legal, accounting, and tax obligations;
d. enforce or defend rights in court, in case of abuse in the use of the Site and/or our Services or for contractual or non-contractual disputes;

4. Legal basis and mandatory or optional nature of processing

The legal basis for the processing of Personal Data for the purposes referred to in section 3(a-b) is Article 6.1.b) of the Regulation as the processing is necessary for the provision of the Services or for responding to requests from the data subject. The provision of Personal Data for these purposes is optional, but failure to provide it would make it impossible to activate the Services provided by the Site.

For processing falling within the statutory purposes of Tecnopool, included among those referred to in letter 3(a), data of members or subjects in regular contact with the controller may be processed. If you have purchased services or goods from Tecnopool, your data may be processed for the purpose of direct sending of advertising material in relation to Tecnopool products or services similar to those purchased by you, without your consent (so-called “soft spam”). The processing of your data for these purposes is the legitimate interest referred to in Article 6.1.f) of the Regulation and in Article 130 paragraph 4 of Legislative Decree 196/2003. In any case, pursuant to Article 21 of the Regulation, you have the possibility to object to such processing at any time, initially or on the occasion of subsequent communications, in an easy and free manner, also by writing to the Controller at the contacts indicated above, as well as to obtain an immediate response confirming the interruption of such processing (Article 15 of the Regulation).

The purpose referred to in section 3(c) represents processing of Personal Data carried out pursuant to Article 6.1.c) of the Regulation, for the fulfillment of a legal obligation. Once the Personal Data has been provided, the processing is necessary to fulfill a legal obligation to which Tecnopool is subject. The processing for the purposes referred to in section 3(d) would be carried out pursuant to Article 6.1.f) of the Regulation.

5. Recipients of Personal Data

Your Personal Data may be shared, for the purposes referred to in section 3 above, with:

a. subjects who typically act as data processors pursuant to Article 28 of the Regulation, namely: i) persons, companies, or professional firms that provide assistance and consulting to IIP in accounting, administrative, legal, tax, financial matters and debt recovery relating to the provision of Services; ii) subjects with whom it is necessary to interact for the provision of Services (for example hosting providers) iii) or subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks); (collectively “Recipients”); the list of data processors who process data can be requested from the Controller by sending an email to the references set out above.

b. subjects, entities, or authorities, independent data controllers, to whom it is mandatory to communicate your Personal Data by virtue of legal provisions or orders of the authorities;

c. persons authorized by Tecnopool to process Personal Data pursuant to Article 29 of the Regulation necessary to carry out activities strictly related to the provision of Services, who have committed themselves to confidentiality or have an adequate legal obligation of confidentiality (e.g., Tecnopool employees)

d. Affiliated Companies.

6. Data retention

Personal Data processed for the purposes referred to in section 3(a-d) will be kept for the time strictly necessary to achieve those same purposes in compliance with the principles of minimization and limitation of storage ex Article 5.1.e) of the Regulation. In any case, the Controller will process Personal Data for the time necessary to fulfill contractual and legal obligations. Data relating to curricula received by Tecnopool will be stored in the company database for a period equal to 36 months in order to be able to consult them over time giving the right priority compared to other possible applications, in case professional searches open within the Entity. Tecnopool will immediately delete the curricula at the expiry of the above timeline, in compliance with the principle of data retention. Of course, it is your right to contact Tecnopool if you do not agree with the data retention timelines described with respect to storage in company databases.

More information about the data retention period and the criteria used to determine this period can be requested by writing to the Controller.

7. Transfer of data abroad

In case of data transfer abroad (perhaps for the use of platforms based in the USA), Tecnopool refers as follows:

Article 45, paragraph 3, of the General Data Protection Regulation (GDPR) confers on the Commission the power to decide, by means of an implementing act, that a third country guarantees “an adequate level of protection” – a level of protection of personal data substantially equivalent to the level of protection within the EU. The effect of adequacy decisions is that personal data can flow freely from the EU (and Norway, Liechtenstein, and Iceland) to a third country without further obstacles.

In this regard, the adequacy decision adopted by the EU Commission determines the legal basis for the transfer of personal data to American companies that fall within the Data Privacy Framework:

The USA guarantees an adequate level of protection for the transfer of personal data of European citizens to overseas companies, comparable to that of the European Union: adequacy decision adopted on July 10 by the European Commission on the American Data Privacy Framework for EU-USA data transfer entered into force on the same day: https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en

The new Data Privacy Framework establishes new defense mechanisms to protect subjects whose data is transferred:

The agreement provides, for those European citizens who will consider the processing of their personal data by US companies illegitimate or incorrect, a series of recourse possibilities. EU citizens will be able to access an arbitration panel and free and independent mechanisms to which they can appeal.

Individuals will be able to lodge a complaint with their national data protection authority (for Italian citizens https://www.garanteprivacy.it), which will ensure that it is correctly transmitted and that any further information relating to the procedure, including the outcome, is provided to the individual.

8. Rights of data subjects

Pursuant to Articles 15 et seq. of the Regulation, you have the right to request at any time, access to your Personal Data, the rectification or erasure of the same, the restriction of processing in the cases provided for by Article 18 of the Regulation, to obtain in a structured, commonly used and machine-readable format the data concerning you, in the cases provided for by Article 20 of the Regulation. At any time, you can revoke ex Article 7 of the Regulation the consent given; lodge a complaint with the competent supervisory authority pursuant to Article 77 of the Regulation (Data Protection Authority WWW.GARANTEPRIVACY.IT) pursuant to Article 77 of the Regulation, if you believe that the processing of your data is contrary to the legislation in force.

You can formulate a request for opposition to the processing of your data ex Article 21 of the Regulation in which to give evidence of the reasons that justify the opposition: the Controller reserves the right to evaluate the request, which would not be accepted in case of the existence of compelling legitimate reasons to proceed with the processing that prevail over your interests, rights, and freedoms.

Requests should be addressed in writing to the Controller.

9. Amendments

This privacy policy is in force from May 25, 2018, updated on 11/03/2025. Tecnopool reserves the right to further modify or simply update its content, in part or completely, also due to variations in applicable legislation. Tecnopool will inform you of such variations as soon as they are introduced, and they will be binding as soon as they are published on the Site. The controller therefore invites you to regularly visit this section to take cognizance of the most recent and updated version of the privacy policy so as to always be informed about the data collected and the use made of it by the controller.