Privacy and Cookie Policy

Alpinfluence vGmbH, located at Luis-Zuegg-Straße 40, 39012 Merano, Italy (hereinafter 'Alpinfluence vGmbH'), places great importance on protecting the online privacy of its users. This document has been created in accordance with Article 13 of EU Regulation 2016/679 (hereinafter 'Regulation') to inform you about our privacy policies. It explains how your personal data is processed when using our website and enables you to give your explicit and informed consent to the processing of your personal data (applies only to individuals aged 16 and above).

The information and data you provide or that are collected during the use of our website and services (hereinafter 'Services') are processed in accordance with the provisions of the Regulation and the confidentiality obligations governing the activities of the data controller.

INDEX

• The Data Controller
• Personal Data Subject to Processing
  • Browsing Data
  • Special Categories of Personal Data
  • Data Voluntarily Provided by the Data Subject
  • Cookies and Other Tracking Technologies
• Purpose of Processing
• Legal Basis and Mandatory or Optional Nature of Processing
• Recipients of Personal Data
• Transfer of Personal Data
• Retention of Personal Data
• Data Protection Officer
• Data Subject Rights
• Changes

1. The Data Controller

The Data Controller for processing activities carried out on the website is Alpinfluence vGmbH, as determined above (hereinafter referred to as 'Controller').

For information on the processing of personal data by the Controller, including the list of data processors assigned to handle the data, please write to the following address: privacy@alpinfluence.com

2. Personal Data Subject to Processing

In the course of using the website, the Controller processes personal data that can directly or indirectly identify you. This includes, for example, name, identification number, online identifier, postal address, email address, telephone number (landline and/or mobile), as well as other characteristics of your physical, physiological, psychological, economic, cultural, or social identity (hereinafter 'personal data').

The personal data processed through the website include, in particular:

2.a Browsing Data

The computer systems and software procedures used to operate the website collect certain personal data during their normal operation, which are automatically transmitted through Internet communication protocols. This information is not collected to identify you as a data subject but could allow identification through processing and linking with third-party data.

This data includes, among others:

1. IP addresses or domain names of the devices used by users to access the website
2. URI (Uniform Resource Identifier) addresses of the requested resources
3. Time of the request
4. Method used to submit the request to the server
5. Size of the response file received
6. Server status code (e.g., success, error)
7. Operating system and computing environment used

This data is used exclusively to generate anonymous statistical information about website usage, verify proper functionality, and detect anomalies or abuse. It is deleted immediately after processing. In exceptional cases, this data may be used to determine liability in hypothetical crimes against the website or third parties. Apart from such cases, the collected data is deleted after a short period.

2.b Special Categories of Personal Data

If you use the website to apply for a job (e.g., via a contact form or email), you may submit personal data that falls under special categories according to Article 9 of the Regulation. This includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning sex life or sexual orientation.

Please submit such sensitive data only if absolutely necessary. If you provide special categories of personal data without explicitly consenting to their processing, the Controller assumes no liability. In such cases, processing is considered lawful under Article 9(2)(e) of the Regulation, as the affected data has been manifestly made public by the data subject.

We note that we may also review publicly available professional social profiles (e.g., LinkedIn) for application analysis to support the selection process.

2.c Data Voluntarily Provided by the Data Subject

If, while using specific services on the website (e.g., request, contact, or reservation forms), you provide personal data of third parties, we process this data in compliance with applicable data protection laws. However, you, as the submitting party, are responsible for the lawfulness of the data processing.

You agree to indemnify us against any claims, damages, or liabilities that may arise from the unlawful processing of the data you provide.

If you provide personal data of third parties, you guarantee that this is based on a legal basis under Article 6 of the Regulation and that the processing of this information is lawful.

2.d Cookies and Other Tracking Technologies

General Information on Cookies

Cookies are small text files stored on your device by a website via your browser to save certain information for a limited period. There are different types of cookies serving different purposes:

1. Essential cookies: Necessary for the website to function properly (e.g., navigation or shopping cart cookies).
2. Analytics cookies: Collect statistical information, such as the number of visitors or the origin of website traffic.
3. Functional cookies: Store user-defined settings like language or filter options to enhance the user experience.
4. Profiling cookies: Capture preferences and user behavior to create personalized advertising messages. These cookies often come from third parties enabling targeted advertising.

Consent Requirement for Cookies: Cookies that are not essential for the basic functionality of the website may only be set with your active consent. You also have the right to withdraw your consent at any time.

When visiting the website, a banner informs you about cookie usage. It provides the following options:

1. Consent to all cookies
2. Select individual cookie categories
3. Approve each cookie separately

The Cookie Management Tool (CMP) stores your preferences and applies them upon your next visit. You can use the tool to withdraw consent or adjust your preferences at any time.

Blocking Cookies via Browser Settings

3. Purpose of Processing

The processing of your personal data occurs, if necessary, with your explicit consent and serves the following purposes:

1. Provision of the services you requested
2. Responding to customer service inquiries, information requests, or reservations.
3. Analyzing submitted resumes and contacting applicants.
4. Compliance with all legal, accounting, and tax requirements.
5. With your explicit and specific consent, the provided data may be processed for the sending of advertising and marketing communications, including: sending newsletters, conducting market research surveys, sending communications via automated systems (SMS, MMS, email, push notifications) and non-automated systems (mail, call center).

The legal basis for processing your data for marketing purposes is Article 6(1)(a) of the Regulation. Consent for processing your data for direct marketing purposes is voluntary and does not affect your ability to use the offered services. If you do not give your consent, you will not suffer any disadvantages.

4. Legal Basis and Mandatory or Optional Nature of Processing

The legal basis for the processing of personal data for the purposes mentioned in Section 3 (a-b-c) is Article 6(1)(b) of the Regulation (fulfillment of a contract), as data processing is necessary for the provision of services or for responding to requests from the data subject. The provision of personal data for these purposes is optional, but failure to do so would make it impossible to activate the services provided by the website, process requests, or evaluate resumes. Specifically, regarding purpose 3.c and the associated analysis of professional social media profiles that are publicly accessible on the Internet in accordance with Section 2.b, Article 6(1)(f) of the Regulation constitutes the legal basis for processing, i.e., the Controller's legitimate interest in assessing potential risks regarding the applicant's suitability for the specific job position.

The purpose mentioned in Section 3.d constitutes lawful processing of personal data under Article 6(1)(c) of the Regulation (fulfillment of a legal obligation). Once personal data is provided, processing is indeed necessary to comply with a legal obligation to which the Controller is subject.

The legal basis for processing for the purposes mentioned in Section 3.e is Article 6(1)(a) of the Regulation (user consent). The Controller may, without your consent, carry out processing for the same purposes related to the direct sending of advertising material or direct sales or conducting market research or commercial communications regarding the Controller’s products or services (excluding soft spam), which are similar to those purchased, using email addresses and postal addresses in accordance with and within the limits permitted by Article 130(4) of the Privacy Code and the decision of the Data Protection Authority dated June 19, 2008. The legal basis for processing your data for this purpose is Article 6(1)(f) of the Regulation (legitimate interest). This processing also includes messages that contain text, voice, video, sound, or images sent via an electronic communications network and that may be stored on the network, on a computer, or on the recipient's device. This also includes SMS, MMS, and functionally equivalent applications and techniques.

5. Recipients of Personal Data

Your personal data may be disclosed for the purposes mentioned in Section 3 to:

Entities typically acting as data processors, i.e.: i) individuals, companies, or professional firms that provide the Controller with assistance and consulting in accounting, administrative, legal, tax, financial, debt collection, marketing, and communication matters concerning the provision of services; ii) entities with which collaboration is necessary for the provision of services (e.g., hosting providers); iii) entities tasked with performing technical maintenance work (including network equipment and electronic communication network maintenance) (collectively referred to as 'Recipients').

Entities, bodies, or authorities to whom your personal data must be disclosed pursuant to legal provisions or regulatory orders. Individuals authorized by the Controller to process personal data who are necessary for performing activities related to the provision of services or for the other purposes mentioned in Section 3 and who have committed to confidentiality or have an appropriate legal obligation of confidentiality (e.g., employees of the Controller).

6. Transfer of Personal Data

Some of your personal data may be transferred to recipients who may be located outside the European Economic Area. The data controller ensures that the processing of your personal data by these recipients complies with the Regulation. Transfers may indeed be based on an adequacy decision, standard contractual clauses approved by the European Commission, or another appropriate legal basis. For more information, please contact the Controller at the following address: privacy@alpinfluence.com

7. Retention of Personal Data

Personal data processed for the purposes mentioned in Section 3(a-b) will be retained for as long as necessary to achieve these purposes. Since data processing is carried out for service provision, the Controller will in any case process personal data up to the time limit prescribed by Italian law for the protection of interests (Article 2946 et seq. of the Civil Code). Regarding resumes submitted through the website or via email according to Section 3.c, personal data will be retained for a period deemed appropriate for the purpose for which the data was collected. This does not preclude the Controller from contacting the applicant shortly before the specified retention period expires to request an extension of this period.

Personal data processed for the purposes mentioned in Section 3.d will be stored until the time specified by the specific obligation or applicable law.

Personal data processed for the purposes mentioned in Section 3.e, on the other hand, will be retained until the data subject withdraws consent or, if such withdrawal does not occur, for a specific maximum period deemed appropriate.

For more information on data retention periods and the criteria used to determine this period, please contact the Controller at the following address: privacy@alpinfluence.com

8. Data Protection Officer

In accordance with the applicable legislation and in compliance with the principle of accountability, the Data Controller has decided to appoint a Data Protection Officer (DPO). The DPO can be contacted via email at dpo@alpinfluence.com for information regarding the processing of personal data by Alpinfluence vGmbH.

9. Data Subject Rights

Pursuant to Articles 15 et seq. of the Regulation, you have the right to request access to your personal data from the Controller at any time, as well as to request its rectification or deletion, or to object to its processing. You also have the right to request the restriction of processing in the cases provided for in Article 18 of the Regulation and to receive, in the cases provided for in Article 20 of the Regulation, your data in a structured, commonly used, and machine-readable format.

All requests must be submitted in writing to the Controller at the following address: privacy@alpinfluence.com

You also have the right to lodge a complaint with the competent supervisory authority (Data Protection Authority) in accordance with Article 77 of the Regulation if you believe that the processing of your personal data violates applicable law.

10. Changes

This Privacy Policy has been in effect since March 11, 2021, and was last updated on April 23, 2021. The Controller reserves the right to modify or update the content in whole or in part, including due to changes in applicable legislation. Therefore, the Controller encourages you to visit this section regularly to stay informed about the latest and most up-to-date version of this Privacy Policy.