Pursuant to the General Data Protection Regulation (“GDPR”)
Who we are
This Privacy Notice relates to the collection of personal data using online methods (including the NPE Group websites) and offline as specified below.
NPE S.r.l. (hereinafter “NPE” or the “Company”), with its registered office in in Zona industriale 6, 32013 Longarone (Belluno) in accordance with article 13 of Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as “GDPR”), as Data Controller of the personal data collected provides you with the following information.
Data that may be collected
The following categories of personal data (hereinafter “Personal Data”) relating to you may be collected:
- Contact data – information on your name, address, telephone number, mobile telephone number, email address;
- Other personal data – information you have provided regarding your date of birth, education, professional situation and household details;
How we collect your personal data
NPE collects and processes your personal data in the following circumstances:
- if you contact us to request pre-sales or after-sales assistance;
- if you respond to our marketing activities, for example when you complete a reply card or submit your data online on one of our websites;
- if you fill out paper forms of registration that are collected in various ways (during demonstrations, cooking classes, promotions or events);
- if you send your application and CV via NPE’s Linked-In social channels
Kindly help us to keep your personal data up-to-date by informing us of any changes. Any change in address should be promptly communicated to NPE in order to avoid problems in the use of our services.
For what purposes can your personal data be used
The processing of personal data must be justified by one of the legal basis established by existing data protection regulations, as described below.
a) Establishment and execution of contractual obligation and resulting obligations, including communications regarding services (for example to perform after-sales services including complaints and product repair).
NPE may process your Data in order to establish and execute a contractual relationship, to provide services requested or to respond to and process reports or complaints.
NPE may also use your contact details, particularly your email address, to provide you with information concerning the after-sales services
Legal bases for the processing: performance of a contract (ref. Article 6 paragraph 1 letter b of GDPR) or legal requirements which the Company is required to fulfill (ref. Article 6 paragraph 1 letter c of GDPR).
The provision of data is obligatory to enable us to manage the contractual relationship; in the absence of the data, we will be unable to put the contract into effect.
b) Customer Satisfaction and other surveys.
NPE may use your Contact data to carry out surveys aimed at measuring customer satisfaction in relation to the service provided.
Legal bases for the processing: legitimate interest of the Company to verify and improve the quality of their services (ref. Article 6 paragraph 1 letter f of GDPR).
c) Marketing to meet your needs or to inform you of promotions, also based on your preferences (we have also included profiled marketing).
NPE may processes your Contact data for marketing and advertising purposes, to inform you of promotional sales initiatives via automated means of contact (email, SMS and other mass communication tools, etc.) and traditional contact methods (e.g. by telephone), such as for market research and statistical surveys, if you give us your consent and within the limits of the consent declaration.
NPE may also processes your Data in order to send you advertising communication, based on a specific customer profile designed on your personal preferences and interests, if you give us a specific consent and within the limits of the consent.
Legal bases for the processing: consent, a failure to give consent in no way affects the contractual relationship (ref. Article 6 paragraph 1 letter a of GDPR).
The provision of these data is voluntary, in the absence of consent your personal data will not be processed for the purpose referred to above.
Your consent may be revoked at any time, see paragraph CONTACTS for more details. Revocation of consent will not affect the lawfulness of the processing of your personal data based on consent before its revocation.
d) Compliance with legally-binding requests by the legal authorities to discharge obligations of law, regulations or provisions or investigation or defense against claims.
NPE collects your personal data to comply with legal obligations or determine / assert claims or defend against them
Legal bases for the processing: legal obligations with which the Company must comply (ref. Article 6 paragraph 1 letter c of GDPR) or a legitimate interest of the Company consisting in the protection of its rights (ref. Article 6 paragraph 1 letter f of GDPR).
e) Personnel recruitment and selection
The Company collects your Data for research and selection purposes. In particular, the Data used for this purpose is represented by the information you provide in your application and curriculum vitae, as well as any other information that is relevant to the assessment of your professional aptitude or that constitutes an essential or determining requirement for the job.
Legal bases for the processing: The collection and processing of your Data is necessary for the performance of pre-contractual and contractual measures (ref. Article 6 Paragraph 1 letter b of the GDPR). Failure to provide this data may make it impossible to carry out the recruitment and selection process and to establish an employment relationship.
How we keep your personal data safe
The Company uses a wide range of security measures to improve protection and maintain the security, integrity and accessibility of your personal data.
All your personal data are stored on our secure servers (or on secure paper copies) or on those of our suppliers or commercial partners, and may be accessed and used based on our standards and our security policies (or equivalent standards for our suppliers or commercial partners).
The security measures we have adopted include:
- severe restrictions on access to your personal data, based on necessity and solely for the purposes communicated;
- perimeter security systems to prevent unauthorized external access;
- secure management of access to information systems in order to allow Data to be processed only by authorised personnel;
- using encrypted means via TLS technology for transactions on our website that require the entering of personal data.
Where we have provided you with (or you have chosen) a password to allow you to access our website, application or services, you are responsible for keeping this password secret and for complying with any other security procedure we inform you of. Please do not share your password with anyone.
Are we processing your personal data with profile?
NPE may also process your contact details, information about interests and other personal data in order to send advertising information according to your client profile determined on the basis of your personal preferences and interests, if you give us your explicit consent and to the extent provided for therein. Decisions in this respect can be made automatically. After determining whether the criteria have been met, the IT system automatically sends advertising information according to your client profile.
How long do we store your information for
We will keep your personal data only for the length of time necessary to achieve the purposes for which they were collected or for any other related and lawful purpose. Therefore, if your personal data is processed for two different purposes, we will keep the data until the lengthier purpose is achieved. However, we will cease to process the personal data collected for the purpose whose retention period has expired.
We limit access to your personal data to only those individuals who need to use them for the appropriate purposes.
When your personal data are no longer required, or when there is no longer any legal pre-condition for keeping them, they will be irreversibly anonymized (and in such a way may be stored) or securely destroyed.
The retention periods relating to the different purposes described above are indicated to follow:
a) Compliance with contractual obligations: data processed to comply with any contractual obligation may be kept for the duration of the contract and after the contract for duration of limitation period of claims specified under provisions of law; in order to verify any outstanding issues including accounting documents (e.g. invoices).
b) Customer Satisfaction and other surveys: data processed for these purposes may be kept for 5 years from the personal data collection date (except where you decline to receive further communications).
c) For marketing purposes, including profiled marketing: data processed for marketing purposes may be kept for 5 years from the date on which you provided your consent for this purpose (except where you decline to receive further communications).
d) To comply with legally binding requests from state authorities and to comply with legal obligations: data processed for this purpose may be stored for the duration of these obligations. In the event of disputes, personal data may be stored for the reasonably period necessary for such purpose.
e) Personnel recruitment and selection: your Data will be kept only for the time necessary for the purposes of personnel selection (for a specific position or for future positions of potential interest). The Company will periodically review your Data and may delete it if it is no longer needed for the purposes intended. The policy on retention of your Data may vary from country to country depending on specific local requirements established by local authorities. Unless otherwise required, your Data will be retained in the Company’s databases for no longer than 24 months from the date of acquisition. After this date, your Data will be deleted or anonymised.
Who we can share your personal data with
Your personal data may be accessed by duly-authorized employees and by external suppliers, appointed, if necessary, as data processors, who support us in providing services.
For the purposes of the performance of their activities and to follow up on the above mentioned purposes your personal data may also be accessed by other entities in the Group to which NPE belongs (H&T Intelligent Control International Co. Ltd and De’ Longhi Appliances S.r.l.) and may be transferred outside the European Economic Area (in such case, NPE will adopt appropriate safeguards of data subjects’ rights, as required by the GDPR)
The following are the contact details of NPE as data controller: NPE S.r.l., Zona industriale 6, 32013 Longarone (Belluno).
Should you have any questions regarding our processing of your personal data, contact us at the following address email@example.com.
Your personal data protection rights and your right to file complaints before the supervisory authorities
On certain conditions, you are entitled to:
- require information on your personal data processing in accordance with article 15 of GDPR;
- require a copy of the personal data you have provided to us or to transfer it to a third party, under the conditions of article 20 of GDPR;
- require correction and/or completion if the personal data processed concerning you is incorrect or incomplete according to article 16 of GDPR;
- require the erasure of your data in accordance with the principles of article 17 of GDPR;
- refuse to allow your data to be processed for direct marketing purposes;
- revoke your consent, in cases where the processing is based on consent;
- limit the way in which we process your personal data according to article 18 of GDPR;
- exercise your right of objection under the article 21 of GDPR.
The exercising of the above rights is subject to certain exceptions that are intended to safeguard the public interest (e.g. the prevention or identification of crimes) and our interests (e.g. maintaining professional secrecy). Should you wish to exercise any of the above rights, we will check that you are entitled to do so and will usually respond within one month.
We endeavor to respond to any complaints or reports concerning the methods used to process your Data. Nevertheless, should you wish, you may forward your complaints or reports to the authority responsible for data protection at www.garanteprivacy.it
Effective 25th of May 2018
Updated on: 22nd of November 2021