Privacy Policy
1. Scope and Data Controller
This Privacy Policy explains how Fifth Ingenium s.r.l.s. processes personal data collected through the website fifthingenium.com, in accordance with Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) and Legislative Decree 196/2003 (Italian Privacy Code).
Personal data of job applicants is processed under a separate Candidate Privacy Notice.
Data Controller | Fifth Ingenium s.r.l.s. |
Registered office | Viale Carlo III di Borbone 8, 81100 Caserta (CE), Italy |
Operating office | Viale Romagna 46, 20133 Milano (MI), Italy |
VAT number | 08642200961 |
REA | CE 290077 |
Certified email (PEC) | fifthingenium@pec.it |
Privacy contact | info@fifthingenium.com |
2. Purposes, Legal Bases and Retention
| Purpose | Personal data | Legal basis | Retention period |
|---|---|---|---|
| Responding to requests sent through the contact forms | First name, last name, email, phone number, company, area of interest, message content | Pre-contractual measures taken at your request (Art. 6(1)(b) GDPR). For requests not related to our products or services, our legitimate interest in replying to inquiries (Art. 6(1)(f) GDPR) | 24 months from the last exchange. If a contract follows, data is retained for the duration of the contract and for 10 years thereafter, as required by Art. 2220 of the Italian Civil Code |
| Sending news and updates by email | Email address, first name, last name | Your consent (Art. 6(1)(a) GDPR), given through the dedicated optional checkbox | Until you withdraw consent or unsubscribe, using the link in each email or by writing to the privacy contact |
| Website usage statistics (Google Analytics) | Online identifiers, pseudonymised IP address, pages visited, device and browser data | Your consent given through the cookie banner (Art. 6(1)(a) GDPR and Art. 122 of the Italian Privacy Code) | 14 months, as configured in Google Analytics |
| Measuring the effectiveness of LinkedIn campaigns (LinkedIn Insight Tag) | Online identifiers, pages visited, device and browser data | Your consent given through the cookie banner (Art. 6(1)(a) GDPR and Art. 122 of the Italian Privacy Code) | As set by LinkedIn; see the LinkedIn Cookie Policy |
| Website operation and security (system logs) | IP address, date and time of access, requested resources, server response codes | Our legitimate interest in ensuring the security and correct operation of the website (Art. 6(1)(f) GDPR) | 6 months, unless needed to investigate a security incident |
| Compliance with legal obligations and defence of legal claims | Data listed above, limited to what is necessary | Legal obligation (Art. 6(1)(c) GDPR) and legitimate interest in establishing, exercising or defending legal claims (Art. 6(1)(f) GDPR) | For the time required by law or until the claim is finally settled |
3. Recipients
Your data is accessed only by authorised Fifth Ingenium staff who need it for the purposes above and who are bound by confidentiality. We do not sell personal data. The following categories of providers process data on our behalf as data processors under Art. 28 GDPR:
| Provider | Service | Location of processing |
|---|---|---|
| Siteground | Website hosting | EU |
| Microsoft Ireland Operations Ltd. | Email and document management (Microsoft 365) | EU and USA |
| HubSpot Ireland Ltd. | Management of contacts and requests (CRM) | EU and USA |
| Google Ireland Ltd. | Website analytics (Google Analytics) | EU and USA |
| LinkedIn Ireland Unlimited Company | Advertising measurement (LinkedIn Insight Tag) | EU and USA |
The up-to-date list of processors is available on request from the privacy contact. Data may also be disclosed to public authorities when required by law.
4. Transfers Outside the European Economic Area
Some providers listed above may process data in the United States. Such transfers take place only on the basis of the European Commission adequacy decision for the EU-US Data Privacy Framework, where the recipient is certified, or of the Standard Contractual Clauses adopted by the European Commission (Art. 46 GDPR), with supplementary measures where needed.
You may request a copy of the safeguards applied by writing to the privacy contact.5. Mandatory Data, Security and Minors
Fields marked as mandatory in the contact forms are needed to process your request. If you do not provide them, we cannot reply. Optional fields and the newsletter checkbox can be left blank without any consequence.
We apply technical and organisational measures appropriate to the risk, including access control, encrypted connections (HTTPS) and Role based access control (RBAC), to protect data against unauthorised access, loss or disclosure. This website is not directed at children under 14. We do not knowingly collect their data. If you believe a child has sent us personal data, please contact us and we will delete it.6. Your Rights
Under Articles 15 to 22 GDPR you have the right to:
- access your personal data and obtain a copy of it;
- obtain the rectification of inaccurate or incomplete data;
- obtain the erasure of your data, where the conditions of Art. 17 GDPR apply;
- obtain the restriction of processing;
- receive the data you provided in a structured, machine-readable format and have it transmitted to another controller, where processing is based on consent or contract and carried out by automated means;
- object at any time to processing based on legitimate interest, on grounds relating to your particular situation, and to processing for direct marketing without giving any reason;
- withdraw your consent at any time.
7. Cookies and Changes to this Policy
This website uses technical cookies, which are necessary for its operation, and analytics and advertising measurement cookies, which are activated only with your consent. You can change your choices at any time through the cookie settings link in the footer. Details are available in the Cookie Policy.
We may update this Policy to reflect changes in our processing or in the law. The current version is always published on this page with its date. Where a change affects processing based on your consent, we will ask for your consent again.