PRIVACY POLICY

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This Privacy and Cookie Policy describes the modalities and the purposes through which  NORBERT HEWITT Pvt Ltd. and all the companies belonging, its subsidiaries, as data controllers (jointly referred to as the “Companies” or “Data Controllers”), collect and process the personal data of the users (“User/Users”) interacting with the website http://www.norberthewitt.com  and with the services offered on the same (“Site”).

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The information on the data processing refers only to the Site and to the processing carried out by the Companies, without covering the data processing operations carried out by third parties on other websites visited by the User through links present on the Site, for which the Companies takes no responsibility. Regarding the aforementioned processing operations, please refer to the third parties’ Privacy and Cookie Policies.

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I. DATA PROCESSING PURPOSES

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The Companies process the User’s personal data for the following purposes.

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Contact Us:

Through the "Contact Us" section of the Site, the Data Controllers allow the User to send communications, questions and requests for information on the activities, initiatives and/or services offered by the Companies. In this regard, the personal data provided by the User will be processed by the Companies to take charge of, properly manage and respond to the User's communication. The legal basis of the processing is represented by the execution of the service expressly requested by the User and any refusal to provide personal data involves the impossibility for the Companies to manage and respond to the communication or request for information.

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Compliance Reporting:

Through the "Contact Us" section of the Site, the User can also report, confidentially, any conduct contrary to the Companies' principles. In this case, the legal basis of the treatment is the execution of the service expressly requested by the User and the refusal to provide personal data involves the impossibility for the Companies to manage and satisfy the request.

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Legitimate Interests of the Companies and /or third parties:

The User's personal data may also be processed for the purpose of exercising the rights and legitimate interests of the Companies and/or third parties, such as the defense in legal proceedings, the management of complaints and disputes, the possible credit recovery, the prevention of fraud and/or illegal activities. In these cases, even though the provision of the User's personal data is not mandatory, it is still necessary because such data are strictly related and instrumental to the pursuit of these legitimate interests, which do not prevail over the fundamental rights and freedoms of the User; any refusal to provide such data may make it impossible to provide the services requested (e.g. request information to the Companies).

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Compliance with applicable legal and/or regulatory obligations:

Compliance with applicable legal and/or regulatory obligations. The Companies may also process the personal data provided by the User or otherwise acquired during the User's interaction with the Site for purposes connected with the fulfillment of legal obligations, regulations, national and/or European legislation as well as arising from provisions issued by authorities legitimated by law, which represent the legal basis of the processing, without the need to obtain the User's prior consent.

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II. CATEGORIES OF DATA PROCESSED 

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The Companies receive and collect, through the Site, information about the User who visits the pages of the Site and who uses the web services available on it. In particular, the Companies acquire and process the following information.

Web-browsing Data and Personal Data Collected by means of Cookie:

When the User visits the Site, the latter collects certain data such as the pages displayed, the links or buttons clicked by the User, the date and time of access, the IP address of the User, the navigation browser and the operating system used (so-called "browsing data"). The browsing data could, by their nature, allow to identify the User also through processing and association with data held by third parties. However, the Companies use this data for the sole purpose of obtaining statistical and anonymous information on the use of the Site for purposes strictly related to the functioning of the same. The browsing data may also be used to assess liability in the event of any computer crimes against the Site..

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Data Voluntarily Provided by the User:

The Companies limit the collection of the information voluntarily provided by the User to that necessary for reaching the purposes for which it is solely intended and for the provision of the services expressly requested. In addition, the Companies may collect and process further personal data, if the same are voluntarily provided by the User as part of the services offered by the Site, for example in the event that the User contacts the Companies to report malfunctions or malfunctions, exercise their rights on the processing of personal data, etc. Such data will be processed by the Company solely for purposes strictly related to the User's request. Failure to provide the data may make it impossible to obtain the service requested.

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III. COMMUNICATION OF PERSONAL DATA  

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The data provided by the User as well as those collected by the Site as part of its services (e.g. IP address) will not be disclosed and may be communicated, for the purposes and methods set out in this Privacy and Cookie Policy, to the categories of recipients listed below:

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• The company, for administrative purposes, for legitimate interests of the Companies and/or third parties and for purposes of carrying out the services expressly requested by the User;

• companies, collaborators, consultants or freelancers engaged by the Companies for the execution of technical or organizational tasks (such as, for example, IT service providers), or with which the Companies collaborate for the purposes of providing their services or for other communication activities;

• persons, companies or professional firms that provide assistance and advice to the Companies, with particular but not exclusive reference to accounting, administrative, legal, tax and financial matters;

• subjects whose right to access the data is recognized by law or by orders of the competent authorities.

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The subjects belonging to the above categories will process the data as autonomous data controllers pursuant to the law or as data processors, duly appointed by the Companies.

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IV. RETENTION PERIOD​

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The User's personal data will be kept only for the time necessary to reach the purposes for which they have been collected and to carry out the activities connected and instrumental to such purposes, as indicated in the previous paragraph 2; then, such data will be stored in compliance with the ordinary prescription terms identified by the Civil Code or by specific legal provisions, for administrative purposes and/or to enforce or defend a right or a legitimate interest. The User's personal data will be deleted when the purposes for which they have been collected no longer occur.

We also inform You that Your personal data may be stored for longer periods of time than those provided for in this paragraph, for the sole purpose of analysis and statistics, carried out in a pseudo-anonymous and aggregate form, in compliance with the technical and organizational measures required by law to protect your rights and freedoms.

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V. AMENDMENTS TO PRIVACY POLICY​

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The Companies reserve the right to make changes to this Privacy Policy at any time, giving notice thereof through publication on the Site. We encourage the User to check the Site for such updates.

If the changes are particularly significant and/or have a significant impact on the rights of the User, the Company may notify the User by a different method (for example, by sending an email).

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Last updated on: 02/09/2021