Sens Srl Unipersonale (hereinafter referred to as the “Company”), with registered office at Via degli Olmetti, 5/B – 00060 Formello (Rome), Italy, pursuant to Article 13 of Regulation (EU) 2016/679 (“GDPR”) on the protection of personal data, as Data Controller, processes the data you provide when registering on the website https://www.eocroma2027.com/ (hereinafter the “Website”), on any other websites that the Company may create in the future, or on any applications (“Apps”) that the Company may create in the future.

Such processing will be carried out in accordance with the principles of fairness, lawfulness, transparency, protection of your privacy, and safeguarding of your rights. In this regard, we provide you with the following information.

1. Identity and Contact Details of the Data Controller The Data Controller is Sens Srl Unipersonale, with registered office at: Via degli Olmetti, 5/B – 00060 Formello (Rome), Italy (hereinafter referred to as the “Data Controller”).
2. Contact Details of the Data Protection Officer (DPO) The Data Controller has appointed a Data Protection Officer (DPO), whom you may contact regarding all matters relating to the processing of your personal data and the exercise of your rights under the GDPR. The DPO can be contacted by:
   • E-mail: info@lucamaroni.com
   • Mail: Via degli Olmetti, 5/B – 00060 Formello (Rome), Italy
3. Purposes and Legal Basis of Processing Personal data are collected and processed for the following purposes: (1) Website and/or App Registration: To enable registration on the Website and/or App and for purposes connected with the use and operation of the Website or App, including access to services reserved for registered users.
   Legal basis: Performance of a contract.
   (2) Marketing Activities: Subject to your prior consent, personal data may be processed for marketing purposes, including:
   • Sending advertising material;
   • Direct marketing activities;
   • Commercial communications by post;
   • Telephone calls with an operator;
   • E-mail communications;
   • SMS/MMS messages;
   • Automated calls (where you have provided your mobile phone number);
   • Communications through the Website (including personalized communications);
   • Communications through devices or similar equipment at points of sale;
   • Communications through the App;
   • Communications via social media platforms;
   • Participation in surveys not related to your consumption habits or preferences;
   • Sending newsletters.
   The newsletter is a periodic communication sent to the e-mail address you provide, through which registered users will be informed of exclusive initiatives made available by the Data Controller, including, by way of example only, exclusive services, blogs, forums, discussion areas, invitations, and similar initiatives.
   The newsletter may also contain advertising banners, promotional content, and commercial offers from both the Company and third parties.
   Legal basis: Your consent.
   (3) Profiling Activities: Subject to your prior consent, your personal data may be processed for profiling purposes, including detailed analysis of your behavior on the Website, your habits, preferences, choices, and for market research activities.
   Legal basis: Your consent.
   (4) Recruitment and Job Applications: Personal data, mainly identification and professional data, may be collected through the “Careers” section of the Website.
   The personal data collected will be processed to assess the qualifications and skills necessary for recruitment or the establishment of a professional collaboration.
   Applicants are requested to provide only ordinary personal data, including:
   • First name;
   • Last name;
   • E-mail address;
   • Telephone number;
   and to upload an electronic copy of their Curriculum Vitae.
   Personal data relating to job applications will be retained by the Data Controller for a maximum period of 24 monthsfrom the date the CV is entered into the database.
   Legal basis: Your consent.
4. Legal Basis for Processing The legal basis applicable to each processing purpose is specified alongside each purpose described above.
   Where consent is indicated as the legal basis, your personal data will be processed for the relevant purpose only after obtaining your specific consent.
5. Processing Methods Personal data will be processed using electronic tools and, in exceptional cases, physical media (paper archives), in compliance with the principles of necessity and proportionality.
6. Provision of Data and Consequences of Failure to Provide Data Personal data marked with an asterisk (*) in the registration forms are mandatory and necessary for registration on the Website or App.
   Failure to provide mandatory data will prevent registration.
   Personal data not marked with an asterisk are optional and may be omitted without any consequences.
   If provided, your mobile phone number may be used for specific purposes, such as contact via SMS, MMS, or instant messaging services in connection with prize competitions, contests, games, or surveys.
   Providing a mobile phone number is optional except where required for:
   • Management of job applications;
   • Registration to receive communications regarding Company offers and initiatives.
7. Recipients or Categories of Recipients of Personal Data Personal data may be processed by authorized employees and collaborators acting under the authority of the Data Controller.
   For certain processing activities necessary to achieve the purposes described in Sections 3(1), 3(2), and 3(3), external companies may be appointed as Data Processors pursuant to Article 28 GDPR, including, by way of example:
   • Providers of e-mail marketing services;
   • Market research providers;
   • Customer service providers;
   • Technology partners;
   • Commercial partners supporting service delivery.
   Personal data will never be publicly disclosed.
   In certain circumstances, personal data may be communicated to third parties, including:
   • Legal advisors;
   • Accountants;
   • Insurance companies;
   • Other professional consultants.
8. Data Retention Period The Data Controller will retain registration and identification data, together with any other processed data, for a period of 10 years from the last use.
   For marketing, profiling, and recruitment purposes, personal data will be retained for 24 months.
9. Your Rights Under the GDPR, you have the following rights, which may be exercised within the limits established by applicable legislation:
   • Right of access to your personal data (Article 15 GDPR);
   • Right to rectification (Article 16 GDPR);
   • Right to erasure (“right to be forgotten”) (Article 17 GDPR);
   • Right to restriction of processing (Article 18 GDPR);
   • Right to data portability (Article 20 GDPR);
   • Right to object to processing (Article 21 GDPR);
   Right not to be subject to decisions based solely on automated processing, including profiling (Article 22 GDPR);
   Right to withdraw, at any time, any consent previously given for one or more of the communication methods referred to in Section 3(2), without affecting the lawfulness of processing carried out before withdrawal.

Requests may be submitted through the form available at: www.senseventi.com
You also have:

1. The right to contact the Data Protection Officer (DPO) regarding any matter relating to the processing of your personal data and the exercise of your rights;
2. The right to lodge a complaint with the competent supervisory authority if you believe that the processing of your personal data infringes applicable data protection laws.

For Italy, complaints may be submitted to the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali): www.garanteprivacy.it

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