Privacy Policy

INFORMATION ON THE PROCESSING OF PERSONAL DATA

Dear User,

This web platform circes.eu is managed by Romagna Tech (romagnatech.eu), therefore it is regulated by the company’s privacy policy, pursuant to Articles 13 and 14 of the European Regulation 2016/679 on the protection of personal data. This Information page is made available to support you in understanding how and for what purposes your personal data are collected and processed when using the website circes.eu. The information provided below pertains to the website circes.eu (hereinafter, the “Site”) and does not concern other websites and/or applications that may be accessed via links to third-party external pages.

Any personal data you choose to provide to Romagna Tech, directly or otherwise, through the Site, including as part of the services offered (hereinafter “Services”), will be processed in compliance with the fundamental principles of personal data protection, such as transparency, minimization, lawfulness, and fairness.

This Privacy Policy is divided into the sections listed below in the Index, each dedicated to a specific area to facilitate your consultation of the topics.

1. Data Controller

The Data Controller of the personal data processed through the Site for the purposes described below is Romagna Tech S.C.p.a., located at Corso Giuseppe Garibaldi no. 49 – Forlì (FC); VAT Number: 02327720401, Email address: privacy@romagnatech.eu (hereinafter “Romagna Tech” or “Controller”).

2. Processed Personal Data

While browsing the Site and using the offered Services, the Controller will process information concerning you, which may be collected automatically during your navigation or provided directly by you (e.g., when using the contact form on the Contact page, subscribing to the newsletter, or requesting to use the Services available through the Site).

In particular, the Personal Data processed through the Site includes:

a) Name, Contact Details, and Other Personal Data

In certain sections of the Site, such as the Contact page, you may be required to enter some personal data, such as your name, surname, and email address, as well as any additional information you choose to provide in the designated message space.

In sections with free-text fields, we strongly advise against sending personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health-related data, or sexual orientation. If you choose to share such data, please note that explicit consent is required.

If you provide Personal Data of third parties, you act as an independent data controller, assuming all obligations and responsibilities under applicable regulations, including verifying the lawfulness of processing. In such cases, you fully indemnify and hold Romagna Tech harmless from any claims or disputes arising from the processing of the Personal Data you have provided or transmitted.

b) Personal Data Required to Access Services

Through the Site, you may access the Services provided by Romagna Tech, such as registering to access the platform’s features. In this case, you are asked to provide personal data such as your name, surname, email, and professional information. Data necessary for using the Service is marked with an asterisk (*).

When using the Services, the Personal Data you provide will be collected and processed to manage activities related to the provision of the requested Service.

Further Personal Data may be collected during subsequent interactions with Romagna Tech following your initial Service request, such as data voluntarily provided when contacting us via the contact details listed on the Site.

c) Browsing Data and Cookies

The computer systems and software procedures that ensure the Site’s functionality acquire certain Personal Data during normal operation, as is inherent in Internet communication protocols. This data category includes:

  • IP addresses or domain names of the users’ devices,
  • URI/URL addresses (Uniform Resource Identifier/Locator) of requested resources,
  • Request timestamps,
  • Method used to submit requests to the server,
  • Size of the response file,
  • Numerical codes indicating the server response status (success, error, etc.),
  • Other technical parameters related to the user’s operating system and IT environment.

This data is also processed to gather statistical information on Site usage and to ensure its proper functionality.

For more details on the use of cookies on the Site, please refer to the Cookie Policy, which we encourage you to read carefully.

The Data Controller will process your Personal Data for the purposes described below.

Provision of Services: Your Data will be processed to perform all activities necessary to provide the Services you have requested, in order to access the platform’s features and use its contents. In particular, your Data will be processed to assist you, verify your identity, grant you access to the Service, and, in general, to provide any other Service you request.
The voluntary, explicit, and optional sending of messages to the contact addresses provided on the Website, for example through the Contact page, involves the acquisition of the necessary Data to respond to your requests, as well as any Personal Data you include in your communications.
The legal basis for processing is the performance of a contract to which you are a party or the implementation of pre-contractual measures adopted at your request. This processing is necessary to correctly provide the Services you have requested;

Profiling: Only if you have given specific consent through a designated checkbox, your Data will be processed to understand and/or predict your preferences and interests, in order to send you commercial communications and offer Services aligned with your interests.
Furthermore, through certain types of cookies present on the Website, the Data Controller may carry out profiling activities, always subject to your consent for the use of profiling cookies or similar technologies. This purpose includes, for example, the analysis of how the Website is used and the effectiveness of advertisements and promotions, including those on third-party platforms. For details on the activities related to cookies and similar technologies, please refer to the Cookie Policy and the list of cookies, including third-party ones, available from the cookie banner or the “Cookie Policy” link in the Website footer.
This processing is based on your explicit consent. You are not obligated to provide such consent, and if you do, you are always free to revoke it at any time without any consequences other than no longer receiving personalized and targeted communications. You can revoke your consent by following the instructions in the “Rights of the data subject” section and, regarding cookies, through the “Cookie Policy” link in the footer of the Website, following the instructions in section 3 “How to manage or delete cookies”;

Legal Obligations: Your Data may be processed to allow Romagna Tech to comply with obligations provided by laws, regulations, and national, EU, or international norms, or mandatory orders from competent authorities. The legal basis for processing is compliance with legal obligations by the Data Controller. Providing Personal Data for this purpose is necessary to allow the Data Controller to comply with the legal obligations to which it is subject;

Security: Your Data may be processed to prevent and/or detect potential anomalies, fraudulent activities, and/or abuse in the use of the Website or Services. The legal basis for processing is the legitimate interest of the Data Controller in preventing or detecting activities or abuses that may have criminal relevance.

4. Recipients

Your Personal Data may be shared with the subjects listed below:

  • Authorized to process by the Data Controller, duly designated, and who have committed to confidentiality or have otherwise received an adequate legal obligation of confidentiality (e.g., Romagna Tech employees);
  • Third parties designated as Data Processors, tasked with processing Data on behalf of the Data Controller, such as entities with whom it is necessary to interact for the provision of services, such as hosting providers, email platform providers, entities delegated to carry out maintenance of network devices and electronic communication networks;
  • Subjects, entities, or authorities to whom it is mandatory to communicate your Data for compliance with legal obligations, or for Security purposes.

Your Personal Data is not intended for publication or dissemination.

Some of your Personal Data may be shared with recipients in countries outside the European Union or the European Economic Area. The Data Controller ensures that, in such cases, the processing of your Personal Data will be carried out in compliance with applicable laws. Therefore, transfers will be made with appropriate safeguards, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission, or other safeguards deemed adequate.

5. Retention Period and Criteria

Personal Data processed for the purpose of “Provision of Services” will be kept for the time strictly necessary to properly fulfill your requests and the ongoing pre-contractual or contractual relationship with you, unless there are legal requirements that mandate a longer retention period.

Personal Data processed for the purposes of “Profiling” will be retained until you revoke your consent or object to the processing and may be kept for up to 24 months.

Personal Data processed for the purpose of “Legal Obligations” will be kept for the period required by specific legal obligations or applicable regulations.

Personal Data processed for the purpose of “Security” will be kept for the time strictly necessary for the aforementioned purpose, also considering the time needed for legal protection and/or for communicating such Data to the competent authorities.

6. Rights of the Data Subject

As a data subject, you have the right to obtain from Romagna Tech, in the cases provided, access to your Personal Data and the rectification or deletion of the same.

You also have the right to request the restriction of processing of your Data and to object to processing (Articles 15 et seq. of the Regulation.

You can object to the use of profiling cookies when using the Website by referring to the instructions contained in the Cookie Policy.

The relevant request can preferably be submitted via email to privacy@romagnatech.eu, or to the contact details of the Data Controller indicated in the first paragraph of this Notice.

Data subjects who believe that the processing of their Personal Data through this Website occurs in violation of the provisions of the Regulation have the right to file a complaint with the Data Protection Authority, as provided by Article 77 of the Regulation, or to seek appropriate judicial remedies (Article 79 of the Regulation).

7. Updates and Changes

The Data Controller reserves the right to periodically modify, integrate, or update this Privacy Notice in compliance with applicable laws or measures adopted by the Data Protection Authority.