Policy on protection of personal data

Moores Rowland Partners S.r.l. undertakes to respect the privacy of the user of the site, within the terms provided by the applicable regulations on the protection of personal data and, in particular, the Regulation (UE) 2016/679 (below “Regulation”, “GDPR”).
This document (“Privacy & Cookie Policy”) provides information on the processing of personal data collected through this website (below “Site”) and therefore constitutes information to interested parties, in accordance with the aforementioned regulations. In the sections of the Site where the personal data of the user are collected, a specific policy is normally published. This last is provided only for this Site and not for other websites, that may be consulted by the user through link.
So, in accordance with Article 13 of the Regulation, we provide you with the following information:
DATA CONTROLLER
The data controller is:
Moores Rowland Partners S.r.l., with registered office in Piazza Lorenzo Viani 11/a – 55049 Viareggio (LU).

E-Mail: info@mooresrowland.it

DATA PROCESSED
The following may be processed:

BROWSING DATA
The processing of personal data of users only visiting the Site (i.e. without sending communications or using restricted areas), is limited to browsing data, that is those for which the transmission to the Site is necessary for the operation of computer systems responsible for the management of the Site and Internet communication protocols. This category includes, for example, the IP addresses or the domain of the computer, used to visit the Site, and other parameters related to the operating system used by the user to connect to the Site. The Company collects these and other data (such as, for example, the number of visits and the time spent on the Site) only for statistical purposes and anonymously in order to control the operation of the Site and improve its functionality. This information is not collected in order to be associated with and identify other information about users; however, by its very nature, may allow the identification of users through processing and association with data held by third parties.
The legal basis for such processing is the contract resulting from the access to the site and the legitimate interest of the Data Controller in the technical management related to the functionality and security of the site, as defined by art. 6.1. (f) of the Regulation.

COOKIES
Cookies are small text files, which the website inserts into the devices in use, as computers or mobile devices, stored in the directories used by the user’s web browser. There are various types of cookies, some to make more effective the use of the site, others to enable certain features.
The site “mooresrowlandpartners.com” uses “technical” cookies, like navigation or session cookies, or tools aimed at making functional and optimize the navigation and use of the site.
There are no profiling cookies.
In particular, there is a cookie called “pll_language” lasting 1 year from the access, which is used to identify the user’s language and allow the user to access the site always with the language identified. This option can be modified through the functions on the site. In case of change, the duration of the technical cookie starts again from the date and time of the change with the same term of 1 year.

The User can choose to enable or disable cookies by acting on the settings of their browser navigation, according to the instructions made available by the relevant suppliers to the links below:

• Cookie settings in Internet Explorer:
http://windows.microsoft.com/it-it/windows7/how-to-manage-cookies-in-internet-explorer-9
• Cookie settings in Firefox:
https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
• Cookie settings in Chrome:
https://support.google.com/chrome/answer/95647?hl=it
• Cookie settings in Safari and iOS:
http://support.apple.com/kb/HT1677?viewlocale=it_IT
The legal basis for such processing for technical management purposes is the contract and the legitimate interest of the Data Controller.

DATA PROVIDED VOLUNTARILY BY THE USER IN THE “CONTACTS” SECTION
The sending of completely optional, explicit and voluntary messages, by form and e-mail to the addresses indicated on this site, involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data requested by the form or entered by the user in the message. The legal basis for such processing, which is necessary to comply with the specific requests of the user, is the art. 6.1. (b) of the Regulation, that is the execution of a contract of which the person concerned is a party or the execution of pre-contractual measures adopted at the request of the same.

DATA PROVIDED VOLUNTARILY BY THE USER IN THE “RECRUITMENT” SECTION
Your personal data will be processed to proceed with the verification of the skills necessary for the recruitment or for the beginning of a working collaboration with Moores Rowland Partners S.r.l. The applicant will have to indicate common personal data (personal data, qualifications, work experience, etc.) and will not have to indicate – except for any belonging to protected categories – personal data suitable to reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of religious, philosophical, political or trade-union parties, unions, associations or organisations, as well as any personal data that may reveal the state of health and sexual life. Any personal data suitable to reveal the state of health (relating, in particular, to belonging to protected categories) or other special data (as indicated by art. 9 of the Regulation) will be immediately deleted in the absence of a written declaration of consent of the data subject to their processing by our company. For common personal data (personal data, qualifications, work experience, etc.), the legal basis for processing is the execution of pre-contractual measures taken at the request of the interested party; in the specific case, the willingness of the interested party to participate in a selection procedure for the establishment of an employment relationship with Moores Rowland Partners S.r.l.
For the data suitable to reveal the state of health (relating, in particular, to the belonging to protected categories) or other particular data (as indicated by art. 9 of the Regulation), as well as for the time of storage of the data of this processing, the legal basis is the consent given by the data subject.

DATA USED FOR THE NEWSLETTER SERVICE
The personal and contact data (e-mail address), provided during the signing of the contract with the Data Controller, are used. During the provision of the service, functions, made available by the provider of the mailing service, may be used as information relating to e-mails sent, received and opened. The selection of the subjects of interest to you will happen through staff adequately authorized and trained, without the use of profiling systems.
The purpose of this processing is to send, by e-mail, communications of an informative nature in relation to matters of interest to you or which, according to the contract that you have with us, may interest you.
In this case, the legal basis for the processing is the contract of which the data subject is a party, both established by professional appointment and by subscription to the newsletter service.
The data processed for the above purposes will be kept for the entire duration of the contractual relationship until your request to unsubscribe from the service. After this period, these will be destroyed or made anonymous, in accordance with the technical procedures necessary for the execution of the request.

NECESSARY AND OPTIONAL TREATMENTS
The forms to be filled in on this site provide both data that are strictly necessary to manage the communications and requests of the user, marked by the symbol [*], whose failure to indicate doesn’t allow to respond to the requests themselves, both optional data conferencing that are not strictly necessary to follow up on the requests of interested parties. Failure to provide the latter will not result in any consequence.

DATA RETENTION AND DURATION
In accordance with the requirements of art. 5.1. (c) of the Regulation, the information systems and computer programs used by the Data Controller are configured to minimize the use of personal and identification data; the data will be kept for the period of time strictly necessary to achieve the purposes pursued in practice and in any case, the criterion used to establish the retention period is based in accordance with the terms allowed by the applicable laws and the principles of minimization of processing, limitation of conservation and rational management of archives. Technical cookies have the duration set for each specific cookie, as indicated above.
The navigation data are kept for any technical analysis related to the functionality and security of the site for a period of 60 days and then deleted. They may be kept for a longer period and made available to the judicial authority to ascertain and identify the authors of any computer crimes committed against the Site or through the Site.
The data obtained from analytical cookies are anonymized and don’t allow to trace the identity of the user. The data transmitted voluntarily by users (via forms or email) will be kept for the period of time strictly necessary to achieve the purposes underlying the request. In the case of simple request for appointment will be maintained until the same appointment. In the case of data relating to complaints, the maximum retention period shall be five years from the end of the procedure. In the case of communications of commercial or administrative value, the maximum period shall be 10 years. The personal data of the transmitted curricula will be kept for a period of time no more than 24 months.

HOW WE ENSURE THE SECURITY AND QUALITY OF PERSONAL DATA
The Data Controller undertakes to protect the security of the user’s personal data and respects the security provisions provided by the applicable legislation in order to avoid data loss, illegitimate or illicit use of data and unauthorized access to them, with particular, but not exclusive, reference to art. 25-32 of the Regulation.

RECIPIENTS OF PERSONAL DATA
Your personal data may be shared, when strictly necessary for the purposes indicated with:
• Persons assigned by the Data Controller to the specific processing of personal data necessary to carry out activities strictly related to the provision of the Services, appropriately trained, and engaged to confidentiality;
• Third parties that provide instrumental services to the Company, who typically act as data processors, such as communication services managers, e-mail, mail delivery, technical services for the management of the Site, IT service providers or, depending on the subject of requests, suggestions or complaints, to suppliers of products or services related to the nature of the complaint or suggestion;
• Persons, entities or authorities to whom it is obligatory to communicate your personal data pursuant to legal provisions or orders of the authorities.

These subjects will receive only the data necessary for the related functions and will engage to use them only for the purposes indicated above and to treat them in compliance with the applicable privacy regulations. The updated list of data processors is available by sending a written request to the Data Controller.

TRANSFERS OF PERSONAL DATA
Your data, according to the contract, are transferred to the newsletter platform called Mailchimp, owned by the company Rocket Science Group, LLC, which is based in the United States through the use of the standard contractual clauses incorporated in the Data Processing Addendum.
For a comprehensive review of data transfer outside the EU with respect to this mailing service provider, please visit the following link: https://mailchimp.com/help/mailchimp-european-data-transfers/

RIGHTS OF THE USERS
Users can exercise at any time the rights provided by CHAPTER III of the Regulation. In particular, they have the right to ask the Data Controller for access to data concerning them, their rectification or deletion, the integration of incomplete data, the restriction of processing; to receive the data provided in a structured format, of common use and readable by automatic device; to revoke any consent given with regard to the processing and to oppose in whole or in part the use of the data; and to exercise the other rights recognized by the applicable law. The interested parties, who consider that the processing of personal data relating to them takes place in violation of the provisions of the Regulation, have the right to lodge a complaint with the Guarantor, as expected from the art. 77 of the Regulation itself, or to refer to the appropriate courts (art. 79 of the Regulation).

HOW TO EXERCISE YOUR RIGHTS
If available for processing, it may exercise its rights through the automatic functions made available by the Data Controller. For example, your right to object or withdraw your consent to receive newsletters can be exercised by clicking on the link (“Unsubscribe”) at the bottom of the newsletter and following the instructions. The exercise of the right of objection doesn’t affect the use of your data for other purposes for which you have received specific information.

In case of problems, or in all other cases for the exercise of other rights, you can contact us by sending an email to the following e-mail address: info@mooresrowland.it

UPDATE OF THE INFORMATIVE
Moores Rowland Partners S.r.l. will keep this information constantly updated. The “LAST UPDATE” section at the bottom of the page indicates the date on which the information was updated.

LAST UPDATE
This informative was updated on 22 July 2021.

CONDITIONS OF THE NEWSLETTER SERVICE

• The present conditions (Conditions of Service) regulate the supply by Moores Rowland Partners S.r.l, based in Piazza Lorenzo Viani, 11/a – 55049 – Viareggio (LU) Italy (Company), the service consisting in the sending by e-mail of informative communications (Newsletter Service or Service) related to relevant technical and regulatory updates and based on the interests expressed by Users/Customers.

• The present Conditions of Service are made available to the User in the appropriate section “Conditions of the Service” to which the user can access from the homonymous link on the pages of the Site. They may be amended at any time. Any changes will be effective from the time of their publication on the Site in the section above indicated.

• The Newsletter Service is reserved for registered users of the Site or Company Customers, is free and can be activated through a specific request from the user.

• The user can activate the Service:

— > By providing your e-mail address and clicking on the appropriate button in the areas of the Site dedicated to subscription to the Service;
— > By signing a contract with Company.

• For users not yet registered, the request for activation of the Newsletter Service is subject to the Privacy Policy of the Service viewable at the following link. The user who has joined the Service, can, at any time, disable it by clicking on the “Unsubscribe” link at the bottom of each email or by writing an email to: info@mooresrowland.it .

• The Service will run from the date of its activation by the user until its deactivation by the user, according to the above procedure. For the duration of the Service (and, so, from the moment of its activation by the user until the moment of its deactivation by the user, in the manner indicated above), the Company undertakes to send a periodic Newsletter containing information of a fiscal, accounting and corporate nature.

The personal data collected as part of the subscription to the Newsletter Service will be processed by the Company, as the data controller, in accordance with the Privacy Policy of the Service, to which you are invited to refer. Without prejudice to and to a better clarification of what is indicated in the Privacy Policy of the Service, we inform the user that the respective personal data provided in relation to the Newsletter Service will be processed for the duration of the Service, as indicated in paragraph 5 above and, subsequently, for the period indicated in the Privacy Policy of the Service.

• The texts, information and all the Contents included or available through the Newsletter Service and/or through the Site may contain inaccuracies or errors. The Company makes no warranties with regard to the Site, the Newsletter and its Contents. To the extent permitted by law, the Company and/or its suppliers may not be held liable to the User and any third parties for direct or indirect damages or for damages of any kind – including, but not limited to, damages for non-use – arising from, or in some way related to the use of the Site, the Newsletter and its Contents, the delay or impossibility to use, view the Site, the Newsletter or the related Content, the supply or failure to supply the Content, or any information or content obtained through the Site or the Newsletter. Due to the characteristics and technical limitations related to the protection of electronic communications over the Internet, the Company doesn’t guarantee that the information or data displayed by the User through the Site aren’t accessible or viewable by unauthorized third parties.

In no case, the Company and its collaborators shall be liable for any loss, request, damage, direct or indirect of any kind or in any way connected with a use of the Site that doesn’t comply with these general conditions.

• “Moores Rowland Partners S.r.l.” and “Moores Rowland Partners” are names and/or distinctive signs of ownership of the Company, as well as the logos used on the Site and on the Newsletter. The use or reproduction in any form and manner of such names and/or distinctive signs and logos is prohibited, unless expressly authorised in writing by the Company.

• The User may use the Site and the Newsletter only for legitimate activities and shall not use the Site, the Newsletter and the related Contents for any activity that materializes in any violation of the rights of the Company or third parties. It is expressly forbidden to use any part or section of the Site, the Newsletter and its Contents for activities directly or indirectly commercial or advertising of any kind, unless expressly authorized in writing by the Company. Users who perform fraudulent or illegal acts will be prosecuted according to the law.

• The User acknowledges that any material present on the Site or on the Newsletter (without limitation: texts, data, software, photographs, graphics, videos, the graphic, music, sounds, images, illustrations, drawings, icons) is protected by copyright or other intellectual property provisions and it is the exclusive property of the Company and/or third parties.

Duplication, even partial reproduction, downloading, saving, communication to third parties, publication or dissemination by any means and, more generally, any act of disposition or use of the material contained in the Site or in the Newsletter, in all forms, through media and technologies existing or developed in the future, are prohibited, unless expressly stated otherwise contained in the Site or with the prior written permission of the Company and/or the respective rights holders.

• The Company reserves the right to make changes at any time to the periodicity of sending the Newsletter and to interrupt the Service on certain days and/or periods of the year, such as, for example, holiday and summer periods. The Company is granted the right of withdrawal ad nutum by the Service and, so, the right to definitively interrupt the sending of newsletters and/or the provision of the Service, even without any communication to the user and without the user himself being able to of such interruption grieve and/or impute to the Company any responsibility and/or any damage in relation to and/or connected to such interruption. The Company shall also not be held liable for any direct or indirect costs and damages of any nature, suffered by the user in the event of failure to receive the Newsletter, fulfilling its obligations under these Terms of Service by sending the newsletter itself.

• The User authorizes the Company to use other companies to provide the service, or even to send e-mail messages. The User agrees to receive e-mail messages through the use of the service provided by Mailchimp, belonging to the company Rocket Science Group, LLC, based in the United States. At the base of this service there are the documents reachable at these links:

o https://mailchimp.com/legal/
o https://mailchimp.com/legal/data-processing-addendum/
o https://mailchimp.com/legal/privacy/
o https://mailchimp.com/legal/cookies/

• The relationship arising from the activation of the Service is subject to Italian law. Without prejudice to the application to consumer users who do not have their habitual residence in Italy of any more favourable and binding provisions provided for by the law of the country in which they have their habitual residence.

• Please note that, in the case of consumer user for any dispute relating to the application, execution and interpretation of these Conditions of Service or the relationship arising from the activation of the Service, is the jurisdiction of the place where the user resides or has an address for service.

This document was updated on 22 July 2021.