This page explains how Luxury Pharma Srl processes the personal data of people who use its website.

This notice is provided under Article 13 of Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR), applicable since 25 May 2018. It applies to people who use the web services of eligendaroma.com, accessible at https://eligendaroma.com.

This notice applies only to https://eligendaroma.com and not to other websites you may visit through links. It follows Recommendation 2/2001 on certain minimum requirements for collecting personal data online in the European Union, adopted by the Article 29 Working Party on 17 May 2001.

 

Data controller

Under Article 4(7) of Regulation (EU) 2016/679, the data controller is Luxury Pharma Srl, whose registered and operating address is Via del Caucaso 49, 00144 Rome, Italy.

 

Where data is processed

Data processing associated with this website’s services takes place at the premises of the controller and processor. No data arising from the web service is disclosed to third parties or made public. When third-party cookies are used, processing may also take place outside the European Union through Google and the companies that install those cookies. Please see the Cookie policy for details.

 

Types of data processed

Browsing data

During normal operation, the computer systems and software used to run this website acquire certain personal data whose transmission is inherent in internet communication protocols. This information is not collected to identify individuals, but its nature means that users could be identified by processing it or combining it with data held by third parties.

This data includes the IP addresses or domain names of computers used to access the website, the URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit it to the server, the size of the response file, the numerical code indicating the server’s response status (success, error and so on), and other details about the user’s operating system and computing environment.

This data is used solely to compile anonymous statistics about use of the website and to check that it works correctly, and is deleted immediately after processing. It may be used to establish responsibility in the event of suspected cybercrime against the website. Except in that situation, website contact data is currently retained for no longer than thirty days.

 

Data you provide voluntarily

If you choose to email an address listed on this website, we will receive your email address, which we need to reply, together with any other personal data included in your message. Please read this privacy policy when completing any data collection form on the website.

 

How data is processed

Personal data is processed using automated tools for as long as necessary to fulfil the purposes for which it was collected. Specific security measures are used to prevent data loss, unlawful or improper use and unauthorised access.

 

Purposes, legal basis and provision of data

eligendaroma.com will process the personal data you provide through the website for the following purposes:

  • To respond to requests submitted through the contact form. Consent is required. The legal basis cited is Article 6(1)(1) of Regulation (EU) 2016/679: the data subject has consented to the processing concerned;
  • To register the data subject for the association’s newsletter and send periodic information about its initiatives, fundraising and events. Consent is required. The legal basis cited is Article 6(1)(1) of Regulation (EU) 2016/679: the data subject has consented to the processing concerned;
  • To carry out activities supporting the management of online donations, such as preparing receipts and reports. Consent is required. The legal basis cited is Article 6(1)(1) of Regulation (EU) 2016/679: the data subject has consented to the processing concerned through the PayPal payment platform;
  • To assess job applications received by email or through online advertisements. Explicit consent is required. The legal basis is Article 111-bis of Italian Legislative Decree 196/2003 and Article 6(1)(a) of Regulation (EU) 2016/679;
  • To conduct research and statistical analysis using anonymous aggregated data, measuring website operation, traffic, usability and interest in order to improve its functionality and performance. Consent is not required because this does not involve processing personal data;
  • To comply with laws and regulations. Consent is not required. The legal basis is Article 6(1)(c) of Regulation (EU) 2016/679;
  • To establish, exercise or defend legal claims, or whenever courts act in their judicial capacity. Consent is not required. The legal basis is Article 6(1)(f) of Regulation (EU) 2016/679: processing is necessary for the controller’s legitimate interests.

 

Handling CVs

This notice, prepared under Article 13 of Regulation (EU) 2016/679, may also be used by eligendaroma.com for job advertisements on websites or platforms it does not manage directly. eligendaroma.com may assess CVs received by email or through online job advertisements in accordance with this privacy policy. CVs considered relevant are retained for 24 months and processed in accordance with the security requirements of Regulation (EU) 2016/679. After 24 months, they will be destroyed or the applicant may be contacted to ask permission to obtain an updated CV. CVs will not be disclosed to third parties. When submitting a CV electronically, please follow these guidelines:

  • use the European CV format;
  • send your CV as a PDF;
  • avoid including special-category data under Article 9 of Regulation (EU) 2016/679, particularly information about health or religious, philosophical or political beliefs, that is not relevant to the role;
  • provide consent for the processing of special-category data relevant to establishing an employment relationship, for example eligibility for protected employment categories under Italian Law 68/99.
  • The controller will provide an appropriate notice under Article 13 of Regulation (EU) 2016/679 during any interview. CVs are processed solely for assessment, recruitment or selection, including collaboration, fixed-term or permanent employment, internships, or enabling a successful applicant to prepare a degree dissertation at our premises.

 

Transfers to third countries or international organisations

The controller undertakes to restrict the movement and processing of personal data, including storage and retention on its servers, to European Union countries. Transfers to non-EU countries that do not ensure an adequate level of protection are prohibited unless safeguards under Chapter V of Regulation (EU) 2016/679 are in place, such as an adequacy decision, Standard Contractual Clauses or the data subject’s explicit consent.

 

Who may receive personal data

Personal data collected through this website may be disclosed to:

people authorised to process the data;
public bodies or offices where required by law or contract;
banks handling receipts and payments arising from online donations;
appointed consultants and external companies providing tax advice on our behalf;
Apple Inc., through the App Store platform, when apps are installed voluntarily;
third-party companies that install profiling cookies.
An up-to-date list of external processors appointed under Article 28 of Regulation (EU) 2016/679 is available from the controller.

 

Data retention

eligendaroma.com will process your personal data for as long as strictly necessary to fulfil the purposes set out in this notice and for the period permitted by Italian law to protect its interests (Article 2947(1) and (3) of the Italian Civil Code). You will remain subscribed to the newsletter until you unsubscribe using the link in an email you receive.

 

Automated processing

eligendaroma.com does not send emails based on profiling, but may use profiling cookies. Please see the Cookie policy for details of the cookies used and how they interact with social media tools.

 

Your rights

You may exercise the rights provided by Articles 15 onwards of Regulation (EU) 2016/679, including the right to:

  • withdraw consent at any time. You may withdraw consent previously given to the processing of your personal data;
  • object to processing. You may object when your data is processed on a legal basis other than consent;
  • access your data. You may obtain information about the data the controller processes and certain aspects of that processing, and receive a copy of the data;
  • check and request corrections. You may check the accuracy of your data and ask for it to be updated or corrected;
  • restrict processing. Under certain conditions, you may ask for processing to be restricted. In that case, the controller will process the data only for storage;
  • have your personal data erased or removed. Under certain conditions, you may ask the controller to erase your data;
  • receive your data or have it transferred to another controller. You may receive your data in a structured, commonly used, machine-readable format and, where technically feasible, have it transferred to another controller without hindrance. This applies when processing is automated and based on your consent, a contract to which you are a party, or related contractual measures;
  • lodge a complaint. You may complain to the competent data protection authority or bring a claim before a court.

 

How to exercise your rights

To exercise these rights, contact the data controller at info@eligendaroma.com.