Privacy Policy
The purpose of this Privacy Policy is to explain the methods and purposes for which Orange Torino S.r.l., as Data Controller (the "Company" or "Data Controller"), collects and processes personal data of users ("User") who interact with the website https://palestreitaliane.it/ (the "Site") and with the various web services offered through it.
The information provided in this Privacy Policy is given pursuant to Article 13 of Legislative Decree No. 196 of 30 June 2003 - Code regarding the protection of personal data (the "Privacy Code") and Article 13 of EU Regulation No. 679 of 27 April 2016 (the "Regulation"), as well as in accordance with the measures issued by the Guarantor Authority for the protection of personal data and applicable European legislation.
The information regarding data processing applies solely to the Site and to the processing carried out by the Company, and does not extend to any processing performed by third parties that the User may access through external links. The Company assumes no responsibility for such external processing, and the User is advised to consult the Privacy Policies of the respective third-party sites.
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1. Data Controller and place of processing
The Data Controller is the Company Orange Torino S.r.l., based in Turin (Italy), Piazza Nizza n. 44, 10126. The data are primarily processed at the Data Controller’s headquarters and managed by the Company’s technical personnel appointed as data processors within the European Union. Additionally, for services entrusted to or provided by third parties, processing may also take place outside Italy and/or outside the European Union. In the event that data are transferred to countries without data protection standards equivalent to those in Italy, the Company undertakes to implement the necessary safeguards to ensure the lawful and secure transfer of such data.
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2. Data processing methods
The Company processes the User’s data in accordance with all appropriate security measures designed to prevent unauthorised access, disclosure, alteration, or destruction of the data. Processing is carried out using manual, computer, and/or electronic tools, in accordance with organisational procedures and strictly for purposes directly related to and limited to those indicated.
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3. Purpose of data processing and legal basis
Through the Site, the Company may process the User’s data for the following purposes:
a. Management of and response to information requests submitted by the User.
By completing the relevant section of the "Request Info" page on the Site and providing personal data - such as name, surname, date of birth (optional), mobile number, and the e-mail address at which the User wishes to be contacted - the User may request specific information regarding the services offered by the Company. In this context, the User’s personal data will be processed by the Company to receive, properly manage, and respond to the User’s information request. Upon receiving a request, the Company will contact the User through the channel it determines to be most appropriate for efficiently processing the request. The legal basis for processing personal data is the performance of the service explicitly requested by the User. If the User chooses not to provide the required personal data, the Company will be unable to process the request or provide the requested information.
b. Orange Torino S.r.l. marketing
When submitting a request in the 'Request Info' section of the Site, the User may freely provide their consent by selecting the appropriate check box for the use of their personal and contact data (e.g., email address). This consent allows the Company to send marketing communications, including newsletters, invitations to participate in surveys and market research, and information or promotional material about the Company's services and offers, using both automated methods (e.g., email, SMS) and traditional methods (e.g., telephone calls by an operator). The legal basis for processing in this case is the User’s express consent, which may be freely granted or withheld for marketing purposes. Providing such consent is entirely optional and will not affect the User’s ability to use the Company’s services or the Site, nor will it prevent the User from receiving the information requested through the 'Request Info' form. The User may object to the processing and withdraw their consent at any time, including partially for specific communication channels, by contacting the Company using the details provided in the 'Rights and Contacts' section or by using the dedicated link included in the emails.
c. Group company marketing
When submitting a request in the 'Request Info' section of the Site, the User may also provide consent, by selecting the relevant check box, for the Company to share the personal data provided with other Group companies of which Orange Torino S.r.l. is a part. This allows the User to receive marketing communications, newsletters, invitations to participate in surveys and market research, and information or promotional material about their services and/or offers, through both automated methods (e.g., email, SMS) and traditional methods (e.g., telephone calls by an operator). Also in this case, the legal basis for processing is the User’s express consent, which may be freely granted or withheld for third-party marketing purposes. Providing such consent is also entirely optional and will not affect the User’s ability to use the Company’s services or the Site, nor will it prevent the User from receiving the information requested through the 'Request Info' form.
d. Collection of "Work in Orange Torino S.r.l.” applications
The Company provides the User with the opportunity to submit their job application for positions at Prime/Palestre Italiane via e-mail through the "Work with Us" page on the Site. To this end, the Company will collect and use the information provided by the User through the submission of their CV solely for the purpose of managing and processing job applications. The User is, in any case, advised not to include sensitive personal data in their CV (e.g., health information, political opinions, sexual orientation, etc.), except for data strictly necessary for the purpose of evaluating and processing the application (e.g., membership in protected categories). Pursuant to the Privacy Code (Articles 13(5-bis) and 26(3), lett. b-bis), which provide the legal basis for such processing, these data may be collected and processed even without the User’s consent.
e. Pursuit of the legitimate interests of the Company and/or third parties.
The User’s data may also be used to safeguard the rights and legitimate interests of the Company and/or third parties, including, for example, the defence of legal claims, management of disputes and litigation, recovery of receivables, and the prevention of fraud or other unlawful activities. In such cases, while providing personal data is not mandatory, it is still necessary because the data are strictly related and instrumental to the pursuit of these legitimate interests. These interests do not override the User’s rights and fundamental freedoms, and failure to provide the data may make it impossible to deliver the requested services (e.g., responding to inquiries submitted to the Company).
f. Compliance with legal obligations and/or applicable obligations.
The Company may also use the personal data provided by the User, or otherwise collected during the User’s interaction with the Site, for purposes related to compliance with legal obligations, regulations, national and EU laws, as well as directives issued by legitimate authorities. Such processing is based on legal requirements and does not require the prior consent of the User.
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4. Categories of processed data
The Company receives and collects, through the Site, information relating to the User who visits the pages of the Site and who uses the web services available on the Site. In particular, the Company acquires and processes the following information.
4.1 Data collected through browsing and through cookies
When the User visits the Site, certain information is collected, including the pages viewed, links or buttons clicked, date and time of access, the User’s IP address, the browser used, and the operating system (so-called “Browsing data”).
By their nature, navigation data may allow the identification of the User, especially when combined or processed together with data held by third parties. However, the Company uses this data for the sole purpose of obtaining statistical and anonymous information on the use of the Site for purposes strictly related to its operation. Browsing data could also be used to identify people involved and potentially responsible in case any cyber crime is committed against the Site.
For information regarding the collection of User data through cookies and similar technologies, please refer to the Cookies Policy.
4.2 Data provided voluntarily by the user
The Company restricts the collection of information voluntarily provided by the User to what is necessary for the purposes described in paragraph 3 above and for the specific services explicitly requested. Furthermore, the Company may collect and process additional personal data that the User voluntarily provides in relation to the services available on the Site, such as when contacting the Company to report problems, seek support, or exercise their rights under applicable data protection regulations. Such data will be processed by the Company solely for the purposes strictly related to the User's request. Failure to provide data may make it impossible to obtain the requested service.
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5. Communication of data to third parties
The data provided by the User, as well as data collected by the Site in connection with its services (e.g., IP address), will not be publicly disclosed. Such data may be shared, within or outside the European Union, for the purposes and in the manner described above, with the categories of recipients listed below:
• Group companies affiliated with the Company, for administrative and accounting purposes pursuant to Article 24(1) (i-ter) of the Privacy Code, for the pursuit of the legitimate interests of the Company and/or third parties, and for the fulfilment of services expressly requested by the User;
• Collaborators, consultants, or independent professionals engaged by the Company for technical or organisational support (e.g., IT and web service providers), or with whom the Company cooperates, in connection with the provision and operation of its services or for communication and promotional activities;
• Individuals, companies, or professional firms providing assistance and consultancy services to the Company, particularly - though not exclusively - in the areas of accounting, administration, legal affairs, taxation, and financial management;
• Other companies within the Orange Torino S.r.l. Group, for the marketing purposes described in paragraph 3 above and, where required by law, subject to the User’s prior consent;
• Individuals who are authorised to access the data recognised both by law and by order of the authorities.
The entities belonging to the categories listed above will process the data either as independent data controllers, in accordance with applicable law, or as data processors duly appointed by the Company.
In particular, where such entities are located in non-EU countries, the Company adopts the measures required under the Privacy Code and the Regulation to ensure the lawful transfer of personal data to them.
The list of entities to whom the data are or may be disclosed, as well as information on the safeguards adopted to legitimize data transfers outside the EU, may be requested from the Company by contacting the addresses provided in the “Rights of Users and Contacts” section.
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6. Data retention
Data are processed for the period necessary to provide the services requested by the User and to perform the related and instrumental activities described in paragraph 3 above. Once the purposes for which the data were collected and processed no longer apply, the data will be deleted. In particular, the Company will delete the personal data of a User who has requested information once the relevant request has been duly processed, provided that the User has not consented to receive marketing communications nor subscribed to or otherwise engaged with the Company’s services.
Finally, personal data collected for the Company’s marketing purposes will be retained until the User withdraws consent or objects to such processing. Once this period has expired, the data will be anonymized and retained solely for analytical and statistical purposes.
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7. Rights of Users and contacts
The User has the right to contact the Company, through the methods indicated below, to obtain:
• Confirmation as to whether their personal data are being processed and, if so, access to such data held by the Company, along with the following information:
a) processing aims;
b) categories of personal data processed;
c) the recipients or categories of recipients to whom the personal data have been or will be disclosed - particularly if located in third countries (in which case, information on the appropriate safeguards that legitimize such data transfers);
d) the period for which the personal data will be retained, or if that is not possible, the criteria used to determine that period.
Furthermore, where applicable, the User may exercise the rights provided for in Articles 16 to 21 of the Regulation, including in particular:
• the rectification of data, i.e. the updating or modification of the same;
• the deletion of data;
• restriction of processing;
• data portability.
The User also has the right to object, on legitimate grounds, to the processing of their personal data and, even selectively based on different communication channels, to the use of such data for commercial information, marketing, advertising, or market research purposes carried out by the Company or third parties.
Finally, the User has the right to lodge a complaint with the Data Protection Authority regarding any processing of personal data carried out in accordance with this Privacy Policy.
Contact details for exercising rights
Email: info@orangepalestre.it
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8. Amendments to the Privacy Policy
The Company reserves the right to amend this Privacy Policy at any time by publishing the relevant notice on the Site. We encourage the User to check the Site for such updates.
If the changes are particularly significant and/or materially impact the User’s rights, the Company may also notify the User through additional means (for example, by sending an email).
