Privacy Policy

Pursuant to art. 13 of the European Regulation n. 679/2016 (hereinafter also the “GDPR”) this information is provided.


The Data Controller is [insert company name] with registered office in [insert registered office] e-mail [insert company e-mail]. The Data Protection Officer can be reached at the following email address [insert email of the DPO or delegate].


The related processing takes place within the European Community and there is no transfer or dissemination activity in non-EU countries. No data is communicated or disseminated, except for statistical survey purposes and in any case in an anonymous and/or aggregate manner.


The personal data provided through the use of the SignalAct platform are used for the sole purpose of managing the Whistleblowing report made by the Reporter.


The personal data processed are exclusively:

  • Name, Surname, e-mail address of the Reporter (if the same has opted for the “confidential” method);
  • Information reported in the report, made in written or oral form, and in any documents attached to it.


The legal basis legitimizing the processing of personal data coincides with the need to fulfill the legal obligations deriving from the legislation on Whistleblowing (Legislative Decree 24/2023 regarding the protection of people who report violations of Union law and containing provisions regarding the protection of people who report violations of national regulatory provisions).


The personal data provided with the report will be kept in compliance with confidentiality requirements, for the time necessary to carry out the management activities of the reports received and, in any case, no later than five years from the date of communication of the final outcome of the reporting procedure.


Only those responsible for investigating Whistleblowing reports, in their capacity as Report Manager, may have access to the personal data contained in the report.

If, for investigative reasons, parties other than the Manager must be made aware of the content of the report and/or the documentation attached to it, the identity of the Reporter and any other information from which such identity can be deduced, directly or indirectly, will be revealed to such subjects only with the express consent of the Reporter.


Personal data is processed both with IT tools and with manual tools and for the purposes indicated above.

Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.


The rights referred to in articles 15 to 22 of Regulation (EU) 2016/679 can be exercised. The interested party also has the right to lodge a complaint with the Data Protection Authority of the Member State in which he resides, works or the alleged violation occurred.

Within the limits of the provisions of article 2-undecies of the legislative decree of 30 June 2003, n.196A you have the right to exercise the rights provided for by the art. 7, 8, 9 and 10 of the Privacy Code and articles. 15, 16, 17, 18, 19, 20, 21 and 22 of the GDPR and, in particular, to ask us:

  • access to your personal data
  • the copy of the personal data that you have provided to us (so-called portability),
  • the rectification of the data in our possession,
  • the deletion of any data for which we no longer have any legal basis for processing,
  • opposition to processing where required by applicable law
  • the revocation of your consent, in the event that the processing is based on consent;
  • the limitation of the way in which we process your personal data, within the limits established by the legislation for the protection of personal data.

The exercise of these rights is subject to some exceptions aimed at safeguarding the public interest (for example the prevention or identification of crimes) and our interests (for example the maintenance of professional secrecy). In the event that you exercise any of the aforementioned rights, it will be our responsibility to verify that you are entitled to exercise them and we will usually respond within one month.

In case of doubts regarding compliance with the privacy protection policy, its application, the accuracy of your personal data or the use of the information collected, you can contact the Data Controller at the addresses indicated above.

If you wish, you can forward your complaints or reports, pursuant to art. 77 of the GDPR, to the authority responsible for data protection, using the relevant contact details:

Guarantor for the protection of personal data – Piazza di Monte Citorio n. 121 – 00186 ROME – Fax: (+39) 06.69677.3785 – Telephone: (+39) 06.696771 – E-mail: – Certified

For complete information regarding the functioning of the reporting channel and the protection of the confidentiality of the Reporter and the people involved, we invite you to read the Whistleblowing Policy adopted by the company.

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