1.       Introduction

Asso.subsea (the “Company” and the “Controller”) is committed to protecting the privacy of its website users. This privacy policy aims to illustrate the means and purposes of the processing of personal data, in connection and through this website https://www.assogroup.com/ (the “Website”).

Please read the following policy to understand how we collect and use your personal data and the rights you have in relation to this data.

Note that this policy shall apply to anyone who navigates and/or uses the Website, or otherwise interacts with the contents and services accessible through the Website (The “User”).

The processing of personal data of all users is always taking place in full compliance with the applicable data protection legislation, including the EU Regulation 2016/679 (the “GDPR”).

2.       Redirection

Is my data redirected to any third party?

The Website incorporates links which allow you to connect to tother websites run by both other companies within the Asso Group and by third parties. The Company assumes no responsibility regarding the processing of personal data which mat take place through and/or in connection with third-parties’ websites.

Therefore, as a User who accesses such web pages and/or social platforms through the Website, you must carefully read the relevant policies in order to better understand how their personal data will be processed by the third parties which, as autonomous controllers, will provide and manage such websites.

3.       Categories

What personal data you collect?

The Company collects two types of personal data, traffic data and personal data provided by you.

3.1    Traffic Data

The computer systems and software procedures used to operate this Website need to acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This category of data includes: IP addresses, browser type, operating system, the domain name and website addresses from which you are logged in or out, the information on pages visited by User within the Website, the time of access, time period of User's staying on a single page, the internal path analysis and other parameters regarding the User's operating system and computer environment.

This technical / IT data is collected and used only in an aggregated and not immediately identifiable manner and can be used to ascertain liabilities in case of hypothetical crimes committed within or against the Website or upon competent authorities’ request.

3.2    Personal Data provided directly by the User

You are not required to provide us with your personal data to access any area of the Website. However, there are few sections (e.g. job application) which are aimed to collect only those personal data which the User will decide to share with the Company. It remains understood that, in this case, the Company as the controller must collect the data provided by the User in order to fulfil the requests received.

Accordingly, if you prefer that the Controller does not collect your personal data, you are invited not to send any request.

In any event, any User will be always free, after having read this policy in order to understand in detail how and for which purposes any personal data will be processed by the Company, to share his/her own data by filling out the specific forms available on the Website.

4.       Purpose

How you use my personal data and for which purposes?

The Website has been designed with the main goal of providing information – and therefore as an interactive window – regarding the activities, products and services offered by the companies belonging to the Asso Group. This is the reason why, in most cases, the collection of the User's personal data is not required.

We will use your data for the below purposes:

4.1 When you use the website purely for information purposes

We shall only collect the personal data which your browser transmits to our server for purposes of allowing an appropriate navigation on the Website and allowing you to better explore and get more information regarding the activities, services and products offered by the Company. If you wish to view our Website, we collect the following limited non-personally identifying information, which is technically necessary for us to display our website to you and to guarantee stability and security:

  • IP address
  • Date and time of the query
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status / HTTP status code
  • Data volume transferred in each instance
  • Website from which the request originates (browser type)
  • Browser
  • User’s operating system and user interface
  • Browser software language and version.

4.2 When you sign up for our newsletter

If you decide to sign up for our newsletter, we will collect and use your name and email address, in order to send you our newsletters, event invitations and updates. The legal basis of the processing of your personal data lies in your consent.

If you have subscribed to receiving newsletters and updates and you no longer wish to do so, you can, at any time, revoke your consent by sending an email at gdpr@assogroup.com or you can opt-out at any time by using the “Unsubscribe” link in the emails that you receive from us. In such case, we will delete your personal data from the relevant database and we will no longer send you newsletters and other similar material.

4.3 When you contact us

Our website gives you the possibility to contact us by sending us an email, or a letter by traditional post or contacting us by phone. If you contact us for any matter, we will process the information you provide us, in order to contact you and handle any message, request, information or query that you have submitted.

The personal data that we will process for that purpose are your name, surname, contact details provided by you and the contents of the message that you sent to us. In that case, the legal basis for processing your personal data will be the handling of your request and our overriding legitimate business interest to properly handle messages, requests, information or queries submitted by third parties.

 Any personal data that you have provided us when you contact us for submitting a message, request, information or query will be stored in our files until we can properly handle the relevant request.

4.4 When you apply for a job

Our website gives you the option to apply for a job by filling out an online application form and providing your CV. If you choose to provide us with your personal data in order to apply for a job, we will process such data, in order to evaluate your qualifications and process your application. The personal data that we will use are the ones provided by you, such as the information included in your CV, and your contact details.

The processing of your personal data in such case is based on our legitimate interest to properly evaluate job applications and make informed decisions on new recruitments and, in case that you are an eligible candidate, to take the necessary steps prior to entering into an employment contract with you.

Should your qualifications and experience match those required for the opening you applied for or any of our current openings, we will contact you. Otherwise, we will keep your CV for a maximum period of one (1) year.

5.       Cookies

What cookies do you use?

We use cookies on this website. For more information, please see our cookie policy.

6.       Security

How you protect my personal data?

The personal data are collected and processed lawfully and fairly, for the above purposes and in accordance with the fundamental principles established by the applicable legislation.

Processing operations may take place both manually and electronically, or by information technology tools, always under technical and organizational measures that ensure the security and confidentiality of the data, especially in view of reducing the risks of accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to the personal data or, more generally, processing that is not compliant with the purposes of the collection.

The processing will be carried out under the authority of the Controller only by those subjects who have been duly authorized to access and process the data in accordance with the instructions provided for by the Company and the applicable data protection laws and regulations.

7.       Communication

How you share my personal data?

The personal data collected through the Website will not be shared or communicated to third parties, unless upon specific consent of the User.

Should the data be made available by the Company to third-party suppliers or partners (such as service providers, mail carriers, hosting providers, IT companies, communication agencies) in order to enable them to perform specific services connected to or necessary for the fulfilment of the purposes listed above, it will be responsibility of the Controller to appoint such third parties as data processor by virtue of their capacity, experience and reliability and to provide them with specific instructions regarding the security of the data. The updated list of appointed data processors can be accessed at any time by sending a written request to the Company, as specified below.

It remains understood that if requested, your personal data must be communicated to third parties, such as public or judicial authorities, to comply with binding orders and request, as well as with applicable legal provisions.

We inform you that Google Analytics cookie is installed on the website, which allows Asso Group to evaluate user behavior.

7.1 Google Analytics

The Controller has integrated the component Google Analytics (with anonymization function) on this Website.

Google Analytics is a web analytics service. Web analysis is the gathering, collection and analysis of data about the behavior of visitors to websites. Among other things, a web analysis service collects data on which website a data subject has come to a website from (so-called referrers), which subpages of the website were accessed or how often and for which period of time a subpage was viewed. A web analysis is mainly used to optimize a website and for the cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Google Analytics uses cookies. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Google might transfer the personal information collected via this technical procedure to third parties.

As IP anonymization is activated on the Website, the User’s IP address will be shortened by Google within Member States of the European Union or other states in agreement with the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by a Google server in the USA. On behalf of the operator of the Website, Google will use this information to evaluate your use of the Website, compile reports on Website activity and to provide further services related to Website and internet use to us. The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google.

In addition, this Website uses the Analytics feature UserID to track interaction data. This User ID will be additionally anonymized and encrypted and will not be linked with other data.

You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible.

In addition, you may prevent the collection of the data generated by the cookie and related to your use of the Website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics.

In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Further information and Google‘s applicable privacy regulations can be found at https://policies.google.com/privacy?hl=en and https://marketingplatform.google.com/about/ The following link provides a further explanation of Google Analytics https://marketingplatform.google.com/about/.

Our website also uses Google Analytics performance reports relating to demographics and interests and reports on Google Display Network impressions. You can disable Google Analytics for display advertising and customize the ads on the Google Display Network by visiting the ad settings at this link: https://adssettings.google.com.

8.       Retention

How long will you keep my personal information?

Personal data collected by the Website will be kept in a format that allows any User’s identification for no longer than necessary to fulfill the purposes for which the data have been originally collected and, in any case, within the time limits set forth by applicable laws and regulations, as well as to enforce or protect the rights of the Controller (consistent with the retention periods and statutes of limitations provided for by the law), where necessary.

When no longer necessary in accordance with the above, the data will be deleted or anonymized.

9.       Rights

What are my rights?

Any User can at any time exercise his/her rights, including:

  • accessing his/her personal data, obtaining evidence of the purposes pursued by the Controller, the categories of data involved, the recipients to whom they may be disclosed, the applicable storage period, the existence of automated decision-making processes;
  • having incorrect personal data referred to him/her rectified without delay;
  • having his data erased in the cases provided for by the law;
  • obtaining restrictions to processing, where possible;
  • requesting portability of the data provided to the Controller, i.e. receiving them in a structured, commonly used and machine-readable format, also for transmitting such data to another controller, without any hindrance by the Company, in all situations where it is required by the law in force;

To exercise these rights, or for any further information and/or clarifications, please write to  gdpr@assogroup.com .

Additionally, the User also has the right to lodge a complaint with the Data Protection Authority, if it is considered that the Company violates the applicable data protection laws when processing his/her personal data.

10.   Data controller

The data controller is Asso.subsea Ltd., a company duly incorporated under Cypriot law, with head office at 281 28th Octovriou, 3035 Limassol (Cyprus).

The Controller’s Data Protection Officer may be contacted by writing to gdpr@assogroup.com .

11.   Policy updating

The Controller shall have the right to amend and/or integrate this Privacy Policy over time in order to comply with new legal provision and/or include new services. For this reason, each User is invited to periodically visit this page.

Last Update: 01/11/2020