Privacy Policy

Data Controller

The Data Controller is AXACTOR ITALY S.p.A. with registered office at Via Cascina Colombaro n. 36, 12100, Cuneo (CN) - Italy.

Applicable law

The processing of personal data relating to the site is governed by European legislation, Reg. (EU) 2016/679, and the national legislation in force concerning the protection of personal data, as well as the provisions of the Authority for the protection of personal data.

Rights of interested parties

In relation to the treatments described in this Notice, as an interested party, you may, under the conditions provided by the GDPR, exercise the rights sanctioned by articles 15 to 21 of the GDPR and, in particular, the right to:

  • to obtain confirmation that your personal data is being processed and whether or not to do so, and in this case, to gain access to your personal data - including a copy of them - and the communication, among others, of the following information: purpose of processing, categories of personal data processed, recipients to whom these were or will be communicated, data retention period, rights of the data subject (right of access - article 15 GDPR);

Art. 15 GDPRRight of access by the data subject

The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
a) the purposes of the processing;
b) the categories of personal data concerned;
c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
f) the right to lodge a complaint with a supervisory authority;
g) where the personal data are not collected from the data subject, any available information as to their source;|
h) 
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

3. The controller shall provide a copy of the personal data undergoing processing. 2For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. 3Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

  • To obtain, without unjustified delay, the correction of inaccurate personal data concerning you and / or the integration of incomplete personal data (right of rectification - article 16 GDPR);

Art. 16 GDPRRight to rectification

1The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. 2Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

  • To obtain, without unjustified delay, the deletion of personal data concerning you (right to cancel - article 17 GDPR);

Art. 17 GDPRRight to erasure (‘right to be forgotten’)

The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
a)the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
d) the personal data have been unlawfully processed;
e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
a) for exercising the right of freedom of expression and information;
b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
c) or reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
e) for the establishment, exercise or defence of legal claims.

  • To obtain the limitation of the processing (right of limitation of treatment - article 18 GDPR);

Art. 18 GDPRRight to restriction of processing

1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

  • To receive in a structured format, commonly used and readable by an automatic device, the personal data concerning you, transmit them to another owner without impediment and, where technically feasible, obtain that your personal data is transmitted directly by the other owner, if the processing is based on consent and is carried out by automated means (right to data portability - article 20 GDPR);

Art. 20 GDPRRight to data portability

1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
b) the processing is carried out by automated means.

2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. 2That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

• object to the processing of personal data concerning you, unless there are legitimate reasons for the Data Controller to continue processing (opposition right - article 21 GDPR);

Art. 21 GDPRRight to object

1. 1The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. 2The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

  • To make a complaint to the Guarantor Authority for the protection of personal data, Piazza di Montecitorio n. 121, 00186, Rome (RM).

Data Protection Officer

Requests should be sent to the Data Protection Officer, responsible for data protection, through the address privacy@axactor.com to the attention of the engineer. Massimiliano Bonsignori.

The information is a general obligation to be fulfilled before or at the latest when initiating the direct collection of personal data. In the case of personal data not collected directly from the person concerned, the information must be provided within a reasonable time, or at the time of communication (not registration) of the data (to third parties or to the interested party). Follow the information for the various categories of interested parties.

+ WEBSITE & COOKIES

+ DEBTORS, GUARANTEES, COBLIGATORS, THIRD PARTIES

+ REGISTRATION OF TELEPHONE CONVERSATIONS

+ CUSTOMERS, SUPPLIERS AND CONTACTS

+ INFORMATION FOR CANDIDATES FOR WORK INTERVIEW

Axactor Privacy Policy

1 DATA CONTROLLER WITH REGARD TO YOUR PERSONAL DATA

 

Your data will be processed by Axactor España, SL with Company No.: B87334637, Axactor España Platform SA with Company No.: A81238917, Alcalá Lands Investments SLU with Company No.: B87774865, Beta Properties Investments SLU with Company No.: B87774881 and by Borneo Commercials Investments SLU, with Company No.B87774857, and registered address at C/Alcala 63, 4th floor, 28014 – Madrid [Spain], (hereinafter, all referred to as AXACTOR) who respect the privacy of users and protection and security of your personal data. The User is therefore hereby informed of the way AXACTOR collects, processes and protects personal data as set out on https://www.axactor.es, (hereinafter, the “Website”).

AXACTOR has a Data Protection Delegate (hereinafter, “DPD”) you may contact on [+34] 910 120 462 or by email at: compliance.spain@axactor.com.

 

Users should read this privacy policy carefully and freely and voluntarily decide whether to provide their personal data to AXACTOR.

AXACTOR assumes liability for compliance with current national and European data protection legislation and intends to process your data lawfully, faithfully and transparently. 

The Data Controller, according to the General Data Protection Regulation, is the natural or legal person, public authority, service or other body who, either alone or together with others, decides the purposes and methods of processing.

Axactor is not liable in any way for processing customer personal data.

2 DATA AND CONSENT

The user is hereby informed and freely provides informed, specific and unequivocal consent for AXACTOR to process personal data provided through the Website, as well as data deriving from user browsing and other data the user may provide at a later date, as described in this policy.

3 DATA PROVIDED BY YOU

 

Data provided by the User through the email addresses given on the Website or by any other means are generally deemed compulsory for achieving the established purposes. It will not therefore be possible to respond to requests if the user fails to provide certain data (such as identity data or contact details) or if any data provided is incorrect

 

Furthermore, the User:

  • Guarantees that he or she is an adult and that data provided to AXACTOR is true, accurate, complete and up to date. For the aforesaid purposes, the user is held liable for the truthfulness of all data communicated by the user and shall appropriately keep the data provided up to date, to reflect the true user status.
  • Guarantees that he or she duly informed third parties whose data is provided, as the case may be, of the aspects set out in this policy. Additionally, the User guarantees that he or she obtained authorisation from those persons for providing their data to AXACTOR for the stated purposes.
  • Held liable for any false or inaccurate information provided through the Website and for any direct or indirect harm caused either to AXACTOR or to third parties.

4 END PURPOSES OF PROCESSING

Personal data provided through the Website will be processed by AXACTOR mainly to respond to requests from you and to meet the end purposes set out below: 

  • To provide information about our products and services, either electronically or by telephone.
  • To forward information on agreements, arrangements and initiatives we agree with third parties in relation to the photography sector and media, as well as other providers of interest to users. 
  • If required, to manage selection processes using CVs of persons seeking to work with us. The User should, for the purpose, send an email job application attaching a CV in PDF format, to the following email address: cvspain@axactor.com given on the AXACTOR website.
  • Manage payments of outstanding amounts, and also, as the case may be, to check the status of your case.
  • When necessary, to manage claim procedures and/or requests for information from the data titleholder through channels provided for the purpose. 
  • Exercise your rights to Access, Correct, Remove and Oppose, Limit processing, Port data and not to submit your data to computerised individual decisions, by writing to the following email address: derechosarco@axactor.com

5 DATA TYPES

  • Identity data: Name, surnames and nationality.
  • Contact details: Email address, landline telephone number and/or mobile telephone and home address.
  • Financial data: Credit rating, debts and/or financial income.
  • Academic and professional data for candidates seeking work and for employees: e.g. your CV and membership of professional associations 
  • Browsing data: minimum absolutely required for Website operation.

6 BASIS OF LEGITIMATE INTEREST

 

Legitimate interest for processing your data is as follows:

 

  • For selection of employees, legitimate interest is the consent of the candidate, given when sending in an application. 
  • For managing queries, requests for information, complaints and claims, legitimate interest is the consent provided by the User in that regard.
  • As the case may be, for preparing internal statistics reports, legitimate interest lies with AXACTOR.
  • For sending commercial and/or promotional notices, covered by legitimate interest, if a previous contractual/business relationship exists between the parties.
  • For meeting various legal obligations, legitimate interest lies in the respective legal regulations. 

7 RECIPIENTS

User data may be forwarded to:

  • Companies in the AXACTOR GROUP:

А) AXACTOR ESPAÑA S.L.

 

Registered office: Calle Alcalá 63. 4th Floor, 28014 –Madrid (Spain)

Company ID: B87334637

Tel: [+34] 910 120 462

B) AXACTOR ESPAÑA PLATFORM S.A.

 

Registered office: Calle Alcalá 63. 4th Floor, 28014 –Madrid (Spain)

Company ID: A81238917

Tel: [+34] 910 120 462

C) ALCALÁ LANDS INVESTMENTS, SLU

 

Registered office: Calle Alcalá 63. 4th Floor, 28014 –Madrid (Spain)

Company ID: B87774865

Tel: [+34] 910 120 462

D) BETAPROPERTIES INVESTMENTS, SLU

 

Registered office: Calle Alcalá 63. 4th Floor, 28014 –Madrid (Spain)

Company ID: B87774881

Tel: [+34] 910 120 462

E) BORNEO COMMERCIALS INVESTMENTS, SLU

 

Registered office: Calle Alcalá 63. 4th Floor, 28014 –Madrid (Spain)

Company ID: B87774857

Tel: [+34] 910 120 462

 

  • AXACTOR service providers, who are necessary in order to provide the requested services. The aforesaid service providers will not process your data for proprietary purposes not previously informed by AXACTOR

Your data may also be forwarded to National Security Forces and Bodies as provided in Law and/or to Banks and Financial institutions for debt settlement. In this sense, you are hereby informed that payments from you will be deposited into the account of the debt titleholder.

8 INTERNATIONAL DATA TRANSFERS

You are hereby informed that your data may be forwarded to third countries in the European Economic Area and, specifically to businesses in the AXACTOR GROUP, only for internal administrative purposes and/or for the end purposes described above. 

Furthermore, we hereby confirm that in instances when your data is transferred internationally (beyond the EEA) such data transfers will be carried out with all guarantees necessary to maintain data confidentiality and security.

9 CONSERVATION PERIODS

 

Data will be processed for the length of time necessary to achieve the end purposes for which the data was collected, unless the user wishes to deregister from AXACTOR, or opposes use of the data or revokes consent.

 

Personal selection purposes, your curriculum data will be kept for as long as AXACTOR needs to carry out selection processes.

10 EXERCISING RIGHTS

Users may write to AXACTOR to exercise their rights at any time, free of charge, attaching a photocopy of their ID document, giving the following reference “Data Protection”, and may do so by any of the following methods:

Users are hereby informed they may exercise the following rights: 

  • To revoke consent granted.
  • To obtain confirmation as to whether or not personal data is being processed, at AXACTOR, that does or does not involve the user.
  • To access your personal data.
  • To correct inaccurate or incomplete data.
  • To request the removal of your data whenever, among other grounds, data is no longer required for the purposes for which it was gathered.
  • To have AXACTOR limit processing of data when any of the conditions established in data protection legislation are met.
  • To request porting of data provided by the user in instances established in legislation.
  • To bring a claim with regard to personal data protection before the Spanish Data Protection agency, with address at Calle de Jorge Juan, 6, 28001 Madrid (Spain), if the User considers AXACTOR infringed rights acknowledged for the user in applicable data protection legislation.


 

Without prejudice to the above, the user may contact our Data Protection Delegate making the request in writing and sent to C/Pedro Muñoz Seca,2, 4ªplanta, 28001 – Madrid (Spain) or by email to the following email address: compliance.spain@axactor.com, always attaching a document as evidence of user identity and specifying the right the user wishes to exercise. 

11 SECURITY MEASURES.

Lastly, we are pleased to inform you that we shall always process your data in an absolutely confidential manner and abiding by the legal principle of the duty of secrecy in relation to your data, pursuant to applicable law. We take technical and organisational measures for the purpose that will guarantee your data is kept safe and will avoid any unauthorised changes, loss, processing or access, bearing in mind state-of-the-art technology, the nature of stored data and the risks to which the data are exposed.

 

Last update: July 2018