Privacy policy statement pursuant to art. 13, Regulation (EU) 2016/679 for contacts form
Cyres Consulting Services GmbH (hereinafter "the Company), with registered office at Highlight Towers, Tower 2, 17th Floor, Mies-van-der-Rohe-Str. 8, 80807 Munich, Germany, Tax Code and VAT no. DE286844569, part of Var Group S.p.A. (a company incorporated in Italy with registered office at Via della Piovola n. 138 - 50053 Empoli (Florence), VAT no. 07335850488), hereby provides information to users with regard to the methods and conditions applied by the Company to processing performed on personal data. Specifically, this privacy policy statement is issued with regard to the personal data contributed by users who fill in the “contacts form” on the Company’s website with domain address: https://www.cyres-consulting.com/
The Company acts as “Data Controller” with regard to the processing, defined as “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data”. In concrete terms, processing of personal data may be carried out by parties duly authorised and appointed by the Company to perform processing on users’ personal data. In application of regulations governing the processing of personal data, users who view and use the Company’s website are classified as “data subjects”, meaning the physical persons to whom the data being processed refer.
- Purpose and legal basis of the processing of personal data
The personal data processed by the Company are contributed directly by users when they fill in the contacts form provided in order to request information or receive assistance. In this case, processing is based on the fulfilment of specific requests and on compliance with precontractual measures; explicit user consent is therefore not required. On the basis of optional, specific consent supplied by users, the Company may process personal data in order to send commercial and marketing communications relating to the Company’s services and products and messages informing users about its corporate activities. Moreover, on the basis of optional, specific consent supplied by users, personal data may be disclosed to the Var Group S.p.A. corporate group, to enable the companies belonging to the said group to send commercial and marketing communications relating to their services and products and messages informing users about their corporate activities. Finally, on the basis of optional, specific consent supplied by users, personal data may be disclosed to third-party companies belonging to the product/service categories NACE J62, J63 and M70 relating to IT and business consultancy products and services). Uses who have already consented to the processing of personal data may withdraw this consent at any time; withdrawal of consent does not affect the lawfulness of any processing performed prior to such revocation. Consent already given to the Company may be withdrawn by emailing digitallaw&dataprotection@vargroup.it
- Methods and duration of processing of personal data
Users’ personal data are processed by company staff specifically authorised by the Company; all such staff are designated and instructed in writing. Processing may be performed through the use of IT, telematic or also hardcopy media and tools, pursuant to provisions intended to guarantee the security and confidentiality of the personal data, as well as ensuring that the data are accurate, up to date and relevant to the declared purposes. The personal data collected will be held in electronic and/or hardcopy archives at the Company’s registered office or operating sites. Personal data contributed by users will be stored in a form which enables their identification for a period of time not exceeding that necessary for the pursuance of the purposes, as stated in point 1 of this privacy policy statement, for which the said data are collected and processed. In all cases the storage period is determined in accordance with the terms permitted by the relevant legislation. With regard to marketing and sales promotion purposes, if the optional consents requested are given, the personal data collected will be stored for the time strictly necessary for management of the aforesaid purposes, in accordance with criteria of legal compliance and ethics, and the balancing of the Company’s legitimate interest with users’ rights and freedoms. Therefore, unless specific norms impose different storage periods, the Company will ensure that personal data are used for marketing and sales promotion purposes for an appropriate time. In all cases, the Company will take great care to ensure that personal data are not used for an indefinite period by performing regular checks that processing for marketing and sales promotion purposes is still in users’ interest.
- Nature of the contribution of personal data
The contribution of personal data is optional but necessary in order to enable a response to requests for information or assistance submitted by users. In particular, users who fail to fill in the fields of the contacts form will be unable to send requests for information or assistance to the Company. In this case, consent to the processing is “compulsory” as it is a necessary precondition for responding to requests for information or assistance submitted to the Company. In all the other cases covered by point 1 of this privacy policy statement, the processing is based on specific or optional consent; as already stated, consent can be withdrawn at any time.
- Recipients of personal data
Users’ personal data may be disclosed, in Italy or abroad, within the European Union (EU) or the European Economic Area (EEA), in order to fulfil an obligation imposed by law, regulations or EU directives; in particular, personal data may be disclosed to public authorities and public administrations for the performance of their institutional functions. Furthermore, personal data may be disclosed to the Var Group S.p.A. corporate group without users’ consent, for the sole purpose of fulfilling requests for information or assistance addressed to the Company. Moreover, with users’ optional, specific consent, personal data may be disclosed to the Var Group S.p.A. corporate Group, to enable the companies belonging to the said group to send commercial and marketing communications relating to their services and products and messages informing users about their corporate activities. Finally, on the basis of optional, specific consent supplied by users, personal data may be disclosed to third-party companies belonging to the product/service categories NACE J62, J63 and M70 relating to IT and business consultancy products and services). Personal data will not be transferred outside the European Union (EU) or European Economic Area (EEA). Personal data will not be published or disseminated, i.e. divulged to the public or an unlimited number of parties.
Rights pursuant to articles 15, 16, 17, 18, 20 and 21 of Regulation (EU) 2016/679
Users, as data subjects, can exercise their rights to access their personal data provided for by article 15 of the EU regulation and the rights provided for pursuant to articles 16, 17, 18, 20 and 21 of the same regulation regarding rectification, erasure, restriction of the processing, portability (where applicable), and the right to object to the processing of your personal data.
These rights can be exercised by emailing digitallaw&dataprotection@vargroup.it
If you consider that the processing of personal data relating to you infringes the GDPR, you have the right referring to in Article 77 of the GDPR to complain to the supervisory authority against the processing of your personal data (in particular in the Member State of your habitual residence, place of work or place of the alleged infringement).
We also specify that the competent supervisory authority for Cyres is:
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18
91522 Ansbach
Website: https://www.lda.bayern.de/