How we handle your personal data.

01

Who handles your data

The data controller is STEM S.r.l., the company that runs this website. All the contact details are below: for any question about your data, or to exercise the rights described further down, write to one of these addresses.

We have not appointed a data protection officer: the law requires one of public authorities, of those who systematically monitor people on a large scale, and of those who process sensitive data such as health data on a large scale, and we fall into none of the three.

02

When you visit the site

Like every website, our server records the requests it receives: the network address they come from, the page requested, the date and time, the type of browser and device. This is not a choice of ours, it is how the internet works.

Those records exist to keep the site running and to defend it against abuse, and keeping them for a short time is a legitimate interest of ours. We do not use them to identify anyone and we do not cross-reference them with anything else. They remain for a few days and are then overwritten.

This site sets no cookies of its own and has no tools that measure visits. The Cookie policy page explains this in full, including why you will not find any banner to dismiss before you can read.

03

When you write to us through the form

The form on the Contact page collects your name, the company you are writing for, an email address, a telephone number and a description of the work to be done.

Name, company, email and description are required: without them we cannot give you a real answer, and the form will not be sent. The telephone number is optional, and is only there so we can call you back more quickly when a conversation is faster than an email.

We use that information to read the enquiry, assess the work, ask you for the details we need, arrange a site visit where necessary and prepare a proposal.

We do not ask you for consent. Someone writing to us about a job is asking us to take the steps that come before a contract: where the person writing is the one who would sign that contract, the request itself is the reason for the processing. More often, though, whoever fills in the form does so on behalf of the company they work for, and the contract would not be theirs: in that case we handle their data on the basis of a legitimate interest of ours, which is answering the business enquiries we receive and keeping in touch with the people we deal with.

We have weighed that interest against your rights: the data is the professional contact information you gave us yourself, we use it only to answer you, we do not enrich it from other sources and we build no profiles from it. You can object at any time — how to do so is further down.

We do not add you to any mailing list, we do not send you commercial material you have not asked for and we do not pass your address to anyone. If one day we wanted to write to you about something else, we would ask you first.

04

Who reads your enquiry

The enquiry arrives by email in the company mailboxes of the people who handle commercial contacts and site planning. There are three of them, all inside STEM, and nobody else receives it.

It goes to three people rather than one for a practical reason: someone on site or on holiday does not read their email, and an enquiry waiting for a single person is an enquiry that stops.

05

The maps on the Contact page

The Contact page has two Google maps, one per location. They stay switched off: until you press the button, your browser sends no request to Google and no data leaves this site.

If you press it, the map is loaded and from that moment Google receives your connection data. In that processing Google is not working on our behalf: it decides for itself why and how to handle that data, and sets this out in its own privacy notice, which you will find linked on the Cookie policy page.

What Google receives, which companies are involved and how to give it nothing at all: it is all on the Cookie policy page, in the section about the maps.

06

Who else receives your data

To keep the website and the mail running we rely on a few suppliers, which process data on our behalf and are bound by contract to use it only for what we ask, to protect it and to do nothing else with it.

Beyond this list we disclose your data to no one. We do not sell it, we do not release it for advertising purposes and we do not make it available to profiling networks. The only exceptions are the ones that do not depend on us: a request from a judicial authority, a legal obligation, or the need to establish or defend a legal claim.

07

Where your data is processed

The part of the site that receives your enquiries runs on servers located in Germany, and the mailboxes that receive them are in the European Union. Under normal conditions your data therefore does not leave the European area.

The suppliers are, however, companies belonging to groups that also have offices in the United States, and in limited cases — technical support, maintenance, security — data may be accessed from there. When that happens, the transfer takes place on the basis of the decision by which the European Commission has recognised as adequate the level of protection of those United States organisations that adhere to the data protection framework agreed between the European Union and the United States — the finding covers those organisations, not any American recipient — or, for those that do not adhere, or should that decision fall away, on the basis of the standard contractual clauses approved by the Commission itself.

You can ask us for a copy of those safeguards, or for where to consult them, by writing to the contact details in the first section.

08

How long we keep it

No law sets a time limit for an enquiry: what the law asks of us is to tell you the criterion by which we decide. Ours is this.

If the enquiry goes no further — it does not turn into an offer and contact stops — we keep it for as long as it could still serve to pick the conversation back up with you, and then we delete it.

If the enquiry turns into a job, your data becomes part of the records of that relationship and stays for as long as civil and tax law require us to keep them.

The server records described in the second section stay a few days and are then overwritten: they do not follow the fate of the enquiry.

You can ask us to delete your data sooner at any time. We will, unless we have to keep it to meet a legal obligation or to defend ourselves in a dispute: in that case we tell you, and explain why.

09

What you can ask us

You have rights over the data that concerns you, and to exercise them you only have to write to us: no form, no set wording, no need to give a reason. You can ask us to:

• tell you whether we hold data about you, and give you a copy of it;
• correct what is wrong or complete what is missing;
• delete it;
• suspend its use while a dispute of yours is being settled;
• stop processing it, where we do so on the basis of a legitimate interest of ours;
• give you, in a machine-readable format, the data you provided to us, and pass it on to someone else.

Not all of these rights are unconditional, and that is not down to us: the law attaches conditions to them. Erasure, for instance, cannot be granted where we have to keep a piece of data to meet a legal obligation or to establish a legal claim; portability covers the data you provided to us and processed by automated means; the right to object applies to processing based on a legitimate interest of ours. Where we cannot grant a request we say so, and explain which condition is missing.

We answer within one month. If the request is complex we may take longer, but in that case we write to you first and explain why.

If you believe we have not handled your data properly, you can turn to the Italian supervisory authority, whose details are below. You may also go to court; the two routes are alternatives, but choosing one does not rule out the other.

10

If this page changes

If the suppliers, the purposes, the places where data is processed or the retention criteria change, we update this page and change the date you find at the bottom. We do not keep previous versions online: the one published is always the one in force.