Palladio Industries, Inc (“Palladio”) is committed to protecting the privacy of users (the “Users”) of the website https://www.palladioinc.com/ (the “Website”) and will do everything in its power to ensure that users’ Personal Data is treated with respect to their fundamental rights and freedoms as well as personal dignity, with particular reference to confidentiality.
We may require users to provide certain personal information and details in order to provide our services, and we would therefore like to explain the procedures and ways in which we handle data supplied to us.
In general, any information and data which you provide, or which is otherwise gathered by us in the context of the Website, will be used by Palladio in compliance with Regulation (EU) 2016/679 (“GDPR”).
This means, in particular that any Personal Data processing carried out by Palladio will respect to the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.
The Data Controller regarding all Personal Data processing operations carried out through the Website is Columbia Srl, with registered offices at Via del Progresso,1 Monticello Conte Otto (VI), 36010, Italy.
Palladio has appointed a coordinator for privacy/Data Protection Officer (DPO). To get in touch with him/her for any information regarding the processing of Personal Data by Palladio, including a list of its data processors, please contact: email@example.com
In limited circumstances, other companies of the Columbia Group may also operate as data controllers, either independently or jointly with Columbia, for their own purposes and under the same principles as defined in this Notice.
What information do we collect from you?
As you use the Website and, in particular, as you provide information and upload files to the Website in order to access the Website’s services, Palladio may collect and process information related to you as an individual and which allows you to be identified, either directly or together with additional information (“Personal Data”). This information can be collected by Palladio both when you choose to provide it (e.g., when you request any services provided by Palladio over the Website) or simply by analyzing your behavior on the Website.
Data voluntarily provided by users
When requesting to be contacted on the Website, you will be asked to provide certain Personal Data such as contact details (e.g. your name, email address, telephone number) for the purposes listed below.
The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation, whose transmission is automatic when using Internet communication protocols.
Although Palladio does not collect this information in order to associate it to specific users, it is still possible that, by their nature and through processing and association with further data held by third parties, such data may permit to identify user, either directly via that information or by using other information collected. As such, this information must also be considered Personal Data.
Such data shall only be used by Palladio for aggregated, statistical purposes about the use of the Website, without associating them to any identifier of the users, to ensure its correct operation and identify any faults and/or abuse of the Website. This data may also be used for the purposes of investigating liabilities in the event of information crimes committed against the Website.
The processing of data shall be made by such procedures, technical and electronic means, which are suitable to protect the confidentiality and security of data and consists of collection, recording, organization, storage, consultation, elaboration, alteration, selection, retrieval, alignment, use, combination, block, communication, dissemination, erasure, and destruction of data, including a combination of two or more of such activities.
Why do we process this information? Purposes of processing and legal grounds
Palladio intends to use your Personal Data, collected through the Website, for the following purposes:
- delivery or purchase of products and services
- reply to the requests sent by Users throught the interaction methods present on the Site, or to the e-mail addresses available on the Website;
- allow the Users to browse the Website;
- managing customer, supplier and business partner relations
- marketing and development of our products and services
- providing you information you have requested from us
- facilitating communication between you and us, including customer and supplier feedback and satisfaction surveys
- improving customer experience and developing our customer insight
- operating and improving our websites
- analyzing, profiling, reporting, segmentation, and statistics for the purposes explained above
We will only process your personal data when the law allows us to. Our legal basis for processing your data is:
- the performance of a contract between us and a customer, supplier or another business partner as well as taking steps prior
- to entering into a contract, e.g. to manage requests for information or quotation
- legitimate interest of Palladio based on a business or other relationship, which includes e.g. relationship management and marketing of our products and services
- your consent or
- compliance with a legal obligation
- Who will be able to access your Personal Data?
In the framework of its activity and for the purposes specified above, your Personal Data may be shared with the following entities (“Recipients”):
- Other companies within the Columbia Group for internal administrative purposes; and
- Duly appointed data processors, providing specific processing or accessory services (e.g. storing data, sending out messages for us, web hosting, contests’ management, consumer service, IT services regarding the Website operation, emailing) on Columbia’s behalf and under its instructions, whose data protection maturity has been checked by Columbia before entering into the required data processing agreement. The full updated list of appointed as data processors, which may include other companies within the Columbia Group, is available from our data protection officer;
- Selected individuals authorized by Columbia to process Personal Data needed to carry out activities strictly related to the provision of the services through the Website (e.g. technical maintenance of network equipment and electronic communications networks), who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Palladio or Columbia);
- Public entities, bodies or authorities, in accordance with the applicable law or binding orders of those entities, bodies or authorities. We may also disclose your Personal Data when we believe in good faith that disclosure is necessary to protect your safety or the safety of others, investigate fraud, or respond to a government request.
- Who will be able to access your Personal Data?
Personal data shall not be disclosed nor transferred to third parties, except in the event of extraordinary corporate transactions, when Personal Data may be assigned or contributed to third party purchasers/lessees or assigns.
As Columbia is a group of companies with affiliates and service providers both within and outside the EU, your personal data may be processed, transferred or made accessible across country borders. If your data is transferred outside of the EU, we rely on adequacy decisions, data transfer agreements or other EU approved mechanisms for such transfers.
Transfers of personal data from the EU to Columbia affiliates outside of the EU are primarily done on the basis of intra-group agreements, which are based on the EU’s standard contractual clauses for export of personal data to third countries.
Security of Personal Data
All Personal Data collected and processed through the Website will be stored and processed so as to minimize the risk of destruction, loss (including accidental loss), unauthorized access / use or incompatible use with the initial purpose of collection. This is achieved by the technical and organizational security measures put in place by Palladio.
Retention of Personal Data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for or as required by applicable legislation. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the data, the time limits on legal claims and the applicable legal requirements.
What are your rights? How can you exercise them?
As a data subject, you are entitled to exercise the following rights, at any time:
– Obtain confirmation as to the existence of your Personal Data being processed by Palladio, access and obtain copy of such data;
– Update, modify and/or rectify your Personal Data where it may be inaccurate or incomplete;
– Obtain erasure of your Personal Data where you feel that the processing is unnecessary or otherwise unlawful, block data whose processing is unlawful or set limits to the processing;
– Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Palladio from processing your Personal Data for a given purpose;
– Object to processing of Personal Data that is made for the purposes of sending advertising material, carrying out direct sales, market researches or for commercial communication;
– Withdraw your consent to processing (for Marketing and Profiling), where your consent serves as the legal basis for processing – this will not affect the lawfulness of processing carried out prior to your withdrawal.
– Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, or that the processing is unnecessary or unlawful, as well as where you have objected to the processing;
– Portability – you have the right to obtain a copy of the Personal Data you provided to Palladio in a structured, commonly used and machine-readable format, as well as to request the transmission of those Personal Data to another data controller;
When requesting services via the Website, you may have selected one or more means of communication via which Personal Data processing for Marketing purposes may be carried out (e.g., phone, SMS, email, mail, social media). You may withdraw your consent to this processing for all selected means of communication, or you can choose to block specific means only (e.g., if you only withdraw consent for SMS marketing communications, you will not receive further communications via SMS, but may continue to receive them via e-mail), by means of your user profile created on the Website, where applicable.
Consent for Profiling carried out by cookies may be withdrawn at any time. Where consent for Profiling was given via a specific tick box, you may withdraw this consent by changing your preferences, at any time, within your user profile created on the Website, where applicable.
At any time, you shall be entitled to exercise the rights established by the law in force, by addressing the relevant request to our Data Controller at physical and email address: firstname.lastname@example.org.Compliants
Each Users has the right to lodge a complaint pursuant to art. 77 et seq. of the GDPR to a supervisory authority, which for the Italian Republic is identified in the Italian Data Protection Authority (Garante per la protezione dei dati personali). The methods of compliant are indicated at the link: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524.