PRIVACY POLICY
The Privacy Policy is part of the General Conditions that rule this website.
We are responsible for your data treatment in this website:
NEW HORIZON srls
Via Giorgio Chiesa 45/19
16147 GENOVA
ITALIA
VAT N°: IT02337700997
Commercial brand name: NEW HORIZON, NEWHO, INGEGNI, INGEGNI.ORG
Phone: (+39) 351 312 1988
Email: contact@newho.io
You may use any means to communicate with us.
We reserve our rights to modify or adapt this Privacy Policy at any point in time. Users that have already been registered and access their account or profile will be informed of any modifications. We recommend that you review this Privacy Policy from time to time to remain informed of any potential changes if you are not part of our subscribers list.
The legitimacy of this data treatment goes down to:
The legal basis for this treatment is your consent.
________________________
When you contact us through web or email channels we collect the following data:
We may process your IP, what operating system or navigator you're using, or even monitor the duration of your visit – all of it anonymously. If you provide information in the contact form, you will be identified in order to contact you should it be necessary.
The information will used for the following purposes:
- Answering your queries, requests or petitions.
- Managing your requested services; replying to your queries, or processing your petitions.
- Providing information through electronic means about your requests.
- With explicit authorization for it, providing commercial or event-related information.
- Performing web upgrades and analysis on our web, products, services, or commercial strategy.
Interested party's acceptance and consent:
In those cases where in order to perform a request it is necessary to fill in a form and click the "Send" button, the realization of this process implies that the interested party has been informed and has explicitly granted their permission to the contents of the clause annexed to said form or the acceptance of the privacy policy. All our forms have their obligatory data fields marked with an asterisk (*). If you do not fill in those fields, or do not mark the checkbox to accept the privacy policy, the information will not be sent.
___________________
When you contact us through or subscribe to our newsletter we collect the following data:
In the website you may subscribe to the newsletter by providing us with an email address, to which the newsletter will be sent. We will only store your email in our database and we will proceed to send you periodic emails until you request to unsubscribe, or we stop sending emails. You will always have the option to unsubscribe, in any of our communications.
The information will used for the following purposes:
- Managing the requested service.
- Providing you with information through electronic means about your requests.
- With explicit authorization for it, providing commercial or event-related information.
- Performing upgrades and analysis in the mailing system to improve our commercial strategy.
Interested party's acceptance and consent:
In those cases where you subscribe it will be necessary to accept a checkbox and click on the send button. This necessarily implies that you acknowledge that you have been informed about the privacy policy and grant your explicit consent to receiving the newsletter.
_____________________
Data management of our customers
Your data is used for the following purposes:
- Elaborating a budget, and for any communications required for its follow-up.
- Providing information through electronic means about your requests.
- With explicit authorization for it, providing commercial or event-related information.Managing the administrative, communications or logistics services performed by the Responsible.
- Billing and tax filing.
- Performing any transactions as appropriate.
- Financial control and recovery.
The legal basis is the acceptance of a contractual relationship, otherwise, your consent is given when contacting us to purchase our products or hire our services.
____________________
Data management of surveys
The data you supply through surveys and other information gathering methods is used for the following purposes:
- Verify the quality of the provided services and the degree of satisfaction with the performance of our products.
- Improve the offered products and services, following ISO standars.
The legal basis for this treatment is the interested party's explicit consent by filling out and sending the answers to the quality survey.
____________________
Data management of our suppliers
Your data is used for the following purposes:
- Providing information through electronic means about your requests.
- With explicit authorization for it, providing commercial or event-related information.
- Managing the administrative, communications or logistics services performed by the Responsible.
- Performing any corresponding transactions.
- Billing and tax filing.
- Financial control and recovery.
The legal basis for this treatment is the acceptance of a contractual relationship, or your implicit consent by contacting with us or directly offering your products to us in some way.
____________________
Data management of our partners
Your data is used for the following purposes:
- Planning of necessary activities for the successful achievement of the organization's objectives.
- Internal management and derived legal obligations.
- Announcement of meetings.
- Performing any corresponding transactions.
- Tax filing.
The legal basis is a contractual relationship, the acceptance of an action trading contract or alike, or participation in the society's constitution.
____________________
Data management of our associates
Your data is used for the following purposes:
- Planning of necessary activities for the successful achievement of the organization's objectives.
- Internal management and derived legal obligations.
- Announcement of meetings.
- Performing any corresponding transactions.
- Tax filing.
The legal basis is contractual, the acceptance of the terms of the founding act, and the association's statutes.
____________________
Contacts coming from social networks
Your data is used for the following purposes:
- Answering your queries, requests or petitions.
- Managing your requested services; replying to your queries, or processing your petitions.
- Relating with you and creating a follower community.
The legal basis is the acceptance of a contractual relation in the corresponding social network's environment, conforming to their privacy policy.
We may only query or unsubscribe your data in a limited manner since we have a specific profile. We shall therefore treat them only for so long as you allow us to, by "Friending", "Following", "Liking" us, or similar actions. Any correction to your data or information restriction must be performed through your profile or user configuration in the social network itself.
____________________
Data management of our job seekers
Your data is used for the following purposes:
- Organizing selection processes for employee hiring.
- Summon you for interviews and evaluate your candidacy.
- Informing you, should we believe that your CV may be interesting in future selection processes, that it will be kept for a maximum of one year.
The legal basis is your explicit permission, by sending us your CV.
As a general rule we only treat data handed to us by the holder. If you wish to provide us with data from third parties, you must previously inform them and request their consent to share their data. If you fail to do so, you are exempting us of any responsibility for unfulfilling this requirement.
____________________
Data coming from underage people
We do not treat data from people under 14. Please refrain from giving us your data if you are not at least that old or, where it applies, from facilitating us data from third-parties that are not at least 14. New Horizon srls exempts itself from any responsibility from this request not being followed.
Communications by electronic means from our side
We will do so only to manage your request, if it is one of the contact means you have given us. We will contact you to offer you commercial information only if previously you have given us your authorization for it.
Security measures that we apply
We have adopted an optimal level of protection of the Personal Data that we handle, and we have installed all the means and technical measures at our disposal according to the state of technology to avoid loss, misuse, alteration, unauthorized access and theft of Personal Data.
Data sharing with third parties
Your data will not be transferred to third parties, except for legal obligation. Specifically, we will need to inform the State Tax Administration Agency, banks and financial entities about the collection for the service provided or products purchased. Also those responsible for the treatment necessary for the execution of the agreement.
In case of purchase or payment, if you choose any application, web, platform, bank card, or any other online service, your data will be transferred to that platform or will be treated in that environment, always with maximum security.
When we order it, the web development and maintenance company or the hosting company will have access to our website. A service contract has been signed among the parties to ensure that the same level of privacy as we have is implemented and respected.
Any international transfer of data when using American applications, will adhere to the Privacy Shield agreement, which guarantees that American software companies comply with European data protection policies regarding privacy.
Your rights
- To know if we are processing your data or not.
- To access your personal data.
- To request the rectification of your data if they are inaccurate.
- To request the deletion of your data if they are no longer necessary for the purposes for which they were collected or if you withdraw the consent granted.
- To request the limitation of the treatment of your data, in some cases, in which case we will only keep them in accordance with current regulations.
- To transfer your data, which will be provided in a structured, commonly used or mechanical reading format. If you prefer, we can send them to the new responsible you designate. It is only valid in certain cases.
- To file a claim with the Spanish Data Protection Agency or competent control authority, if you believe that we have not treated you correctly.
- To revoke consent for any treatment for which you have consented, at any time.
- If you modify any information, we thank you for letting us know to keep them updated.
Forms to exercise your rights
We have forms for the exercise of your rights, request them by email or if you prefer, you can use the ones elaborated by the Spanish Data Protection Agency or third parties. These forms must be signed electronically or be accompanied by an ID photocopy. If someone represents you, you must attach a copy of the ID, or have the form signed electronically. The forms can be handled in person, sent by letter or by email using the contact data of the Responsible, provided at beginning of this text.
Average time in which we will reply to your Exercise of Rights
It depends on the right, but at most one month from your request, and two months if the subject is very complex and we notify you that we need more time.
Use of cookies
If we use other types of cookies than the ones necessary, you may consult our cookies policy.
Period that your personal information will be kept by us
Your personal data will be kept while you are still connected with us. Once you dissociate, the personal data processed in each purpose will be maintained during the legally stipulated deadlines, including the period in which a judge or court may request them, taking into account the limitation period for legal actions. The data processed will be maintained as long as the aforementioned legal deadlines do not expire, if there is a legal maintenance obligation, or if the legal period does not exist, until the interested party requests their suppression or revokes the consent granted. We will keep all the information and communications related to your purchase or to the provision of our service, while the guarantees of the products or services last, in order to properly manage potential claims.
In each treatment or type of data, we provide you with a specific period, which you can consult in the following table:
FILE TYPE / DOCUMENT DETAILS / CONSERVATION PERIOD
Conservation / Conservation / 10 years
Conservation / Forms and coupons / 15 years
Conservation / Contracts / 5 years
Human Resources / Payroll, TC1, TC2, etc. / 10 years
Human Resources / Curriculums / Until the end of the selection process or 1 more year if consent
Human Resources / Docs regarding compensation for dismissalContractsData of temporary workers / 4 years
Human Resources / Worker's file / Max. 5 years after termination
Marketing / Databases or web visitors / While the processing exists
Suppliers / Bills / 10 years
Suppliers / Contracts / 5 years
Access control and video surveillance / List of visitors / 30 days
Access control and video surveillance / Videos / 30 days, blocked 3 years, destruction
Accounting / Books and accounting documents / 6 years
Accounting / Partner agreements and board of directors, company bylaws, minutes, board of director's regulation and delegated committees / 6 years
Accounting / Financial statements, audit reports, records and documents related to grants / 6 years
Taxes / Handle the management of the company, rights and obligations related to the payment of taxes. Dividend payments and tax withholdings / 10 years
Taxes / Information about the intra-group price establishments / 18 years, 8 years intra-group price establishments
Security and Health / Medical Records of Workers / 5 years
Environment / Reports on accidents / 5 years
Environment / Documents related to environmental permits while the activity is being carried out / 3 years after end of activity, 10 years (crime prescription)
Environment / Records on recycling or waste disposal / 3 years
Environment / Grants for cleaning operations. You must keep the documents of rights and obligations, receipts and payments / 4 years
Insurance / Insurance policies / 6 years (general rule), 2 years (damages), 5 year (personal), 10 years (life)
Purchases / Register all deliveries of goods or services, intra-community acquisitions, imports and exports for VAT purposes / 5 years
Legal / Documents for Intellectual and Industrial Property. Contracts and agreements / 5 years
Legal / Permits, licenses and certificates / 6 years starting from the date the permit, license or certificate expires, 10 years (criminal prescription)
Legal / NDA's and Non-competition agreements / Always the date of the obligation or confidentiality
LOPD / Processing of personal data, if different from the treatment notified to the AEPD / 3 years
LOPD / Personal data of employees stored in the networks, computers and communications equipment used by them / 5 years
LOPD / Personal data of employees stored in access control, internal management and administration systems / 5 years
We appreciate your time going through our Privacy Statement. Don't hesitate to contact us for any related question!
We are responsible for your data treatment in this website:
NEW HORIZON srls
Via Giorgio Chiesa 45/19
16147 GENOVA
ITALIA
VAT N°: IT02337700997
Commercial brand name: NEW HORIZON, NEWHO, INGEGNI, INGEGNI.ORG
Phone: (+39) 351 312 1988
Email: contact@newho.io
You may use any means to communicate with us.
We reserve our rights to modify or adapt this Privacy Policy at any point in time. Users that have already been registered and access their account or profile will be informed of any modifications. We recommend that you review this Privacy Policy from time to time to remain informed of any potential changes if you are not part of our subscribers list.
The legitimacy of this data treatment goes down to:
The legal basis for this treatment is your consent.
________________________
When you contact us through web or email channels we collect the following data:
We may process your IP, what operating system or navigator you're using, or even monitor the duration of your visit – all of it anonymously. If you provide information in the contact form, you will be identified in order to contact you should it be necessary.
The information will used for the following purposes:
- Answering your queries, requests or petitions.
- Managing your requested services; replying to your queries, or processing your petitions.
- Providing information through electronic means about your requests.
- With explicit authorization for it, providing commercial or event-related information.
- Performing web upgrades and analysis on our web, products, services, or commercial strategy.
Interested party's acceptance and consent:
In those cases where in order to perform a request it is necessary to fill in a form and click the "Send" button, the realization of this process implies that the interested party has been informed and has explicitly granted their permission to the contents of the clause annexed to said form or the acceptance of the privacy policy. All our forms have their obligatory data fields marked with an asterisk (*). If you do not fill in those fields, or do not mark the checkbox to accept the privacy policy, the information will not be sent.
___________________
When you contact us through or subscribe to our newsletter we collect the following data:
In the website you may subscribe to the newsletter by providing us with an email address, to which the newsletter will be sent. We will only store your email in our database and we will proceed to send you periodic emails until you request to unsubscribe, or we stop sending emails. You will always have the option to unsubscribe, in any of our communications.
The information will used for the following purposes:
- Managing the requested service.
- Providing you with information through electronic means about your requests.
- With explicit authorization for it, providing commercial or event-related information.
- Performing upgrades and analysis in the mailing system to improve our commercial strategy.
Interested party's acceptance and consent:
In those cases where you subscribe it will be necessary to accept a checkbox and click on the send button. This necessarily implies that you acknowledge that you have been informed about the privacy policy and grant your explicit consent to receiving the newsletter.
_____________________
Data management of our customers
Your data is used for the following purposes:
- Elaborating a budget, and for any communications required for its follow-up.
- Providing information through electronic means about your requests.
- With explicit authorization for it, providing commercial or event-related information.Managing the administrative, communications or logistics services performed by the Responsible.
- Billing and tax filing.
- Performing any transactions as appropriate.
- Financial control and recovery.
The legal basis is the acceptance of a contractual relationship, otherwise, your consent is given when contacting us to purchase our products or hire our services.
____________________
Data management of surveys
The data you supply through surveys and other information gathering methods is used for the following purposes:
- Verify the quality of the provided services and the degree of satisfaction with the performance of our products.
- Improve the offered products and services, following ISO standars.
The legal basis for this treatment is the interested party's explicit consent by filling out and sending the answers to the quality survey.
____________________
Data management of our suppliers
Your data is used for the following purposes:
- Providing information through electronic means about your requests.
- With explicit authorization for it, providing commercial or event-related information.
- Managing the administrative, communications or logistics services performed by the Responsible.
- Performing any corresponding transactions.
- Billing and tax filing.
- Financial control and recovery.
The legal basis for this treatment is the acceptance of a contractual relationship, or your implicit consent by contacting with us or directly offering your products to us in some way.
____________________
Data management of our partners
Your data is used for the following purposes:
- Planning of necessary activities for the successful achievement of the organization's objectives.
- Internal management and derived legal obligations.
- Announcement of meetings.
- Performing any corresponding transactions.
- Tax filing.
The legal basis is a contractual relationship, the acceptance of an action trading contract or alike, or participation in the society's constitution.
____________________
Data management of our associates
Your data is used for the following purposes:
- Planning of necessary activities for the successful achievement of the organization's objectives.
- Internal management and derived legal obligations.
- Announcement of meetings.
- Performing any corresponding transactions.
- Tax filing.
The legal basis is contractual, the acceptance of the terms of the founding act, and the association's statutes.
____________________
Contacts coming from social networks
Your data is used for the following purposes:
- Answering your queries, requests or petitions.
- Managing your requested services; replying to your queries, or processing your petitions.
- Relating with you and creating a follower community.
The legal basis is the acceptance of a contractual relation in the corresponding social network's environment, conforming to their privacy policy.
We may only query or unsubscribe your data in a limited manner since we have a specific profile. We shall therefore treat them only for so long as you allow us to, by "Friending", "Following", "Liking" us, or similar actions. Any correction to your data or information restriction must be performed through your profile or user configuration in the social network itself.
____________________
Data management of our job seekers
Your data is used for the following purposes:
- Organizing selection processes for employee hiring.
- Summon you for interviews and evaluate your candidacy.
- Informing you, should we believe that your CV may be interesting in future selection processes, that it will be kept for a maximum of one year.
The legal basis is your explicit permission, by sending us your CV.
As a general rule we only treat data handed to us by the holder. If you wish to provide us with data from third parties, you must previously inform them and request their consent to share their data. If you fail to do so, you are exempting us of any responsibility for unfulfilling this requirement.
____________________
Data coming from underage people
We do not treat data from people under 14. Please refrain from giving us your data if you are not at least that old or, where it applies, from facilitating us data from third-parties that are not at least 14. New Horizon srls exempts itself from any responsibility from this request not being followed.
Communications by electronic means from our side
We will do so only to manage your request, if it is one of the contact means you have given us. We will contact you to offer you commercial information only if previously you have given us your authorization for it.
Security measures that we apply
We have adopted an optimal level of protection of the Personal Data that we handle, and we have installed all the means and technical measures at our disposal according to the state of technology to avoid loss, misuse, alteration, unauthorized access and theft of Personal Data.
Data sharing with third parties
Your data will not be transferred to third parties, except for legal obligation. Specifically, we will need to inform the State Tax Administration Agency, banks and financial entities about the collection for the service provided or products purchased. Also those responsible for the treatment necessary for the execution of the agreement.
In case of purchase or payment, if you choose any application, web, platform, bank card, or any other online service, your data will be transferred to that platform or will be treated in that environment, always with maximum security.
When we order it, the web development and maintenance company or the hosting company will have access to our website. A service contract has been signed among the parties to ensure that the same level of privacy as we have is implemented and respected.
Any international transfer of data when using American applications, will adhere to the Privacy Shield agreement, which guarantees that American software companies comply with European data protection policies regarding privacy.
Your rights
- To know if we are processing your data or not.
- To access your personal data.
- To request the rectification of your data if they are inaccurate.
- To request the deletion of your data if they are no longer necessary for the purposes for which they were collected or if you withdraw the consent granted.
- To request the limitation of the treatment of your data, in some cases, in which case we will only keep them in accordance with current regulations.
- To transfer your data, which will be provided in a structured, commonly used or mechanical reading format. If you prefer, we can send them to the new responsible you designate. It is only valid in certain cases.
- To file a claim with the Spanish Data Protection Agency or competent control authority, if you believe that we have not treated you correctly.
- To revoke consent for any treatment for which you have consented, at any time.
- If you modify any information, we thank you for letting us know to keep them updated.
Forms to exercise your rights
We have forms for the exercise of your rights, request them by email or if you prefer, you can use the ones elaborated by the Spanish Data Protection Agency or third parties. These forms must be signed electronically or be accompanied by an ID photocopy. If someone represents you, you must attach a copy of the ID, or have the form signed electronically. The forms can be handled in person, sent by letter or by email using the contact data of the Responsible, provided at beginning of this text.
Average time in which we will reply to your Exercise of Rights
It depends on the right, but at most one month from your request, and two months if the subject is very complex and we notify you that we need more time.
Use of cookies
If we use other types of cookies than the ones necessary, you may consult our cookies policy.
Period that your personal information will be kept by us
Your personal data will be kept while you are still connected with us. Once you dissociate, the personal data processed in each purpose will be maintained during the legally stipulated deadlines, including the period in which a judge or court may request them, taking into account the limitation period for legal actions. The data processed will be maintained as long as the aforementioned legal deadlines do not expire, if there is a legal maintenance obligation, or if the legal period does not exist, until the interested party requests their suppression or revokes the consent granted. We will keep all the information and communications related to your purchase or to the provision of our service, while the guarantees of the products or services last, in order to properly manage potential claims.
In each treatment or type of data, we provide you with a specific period, which you can consult in the following table:
FILE TYPE / DOCUMENT DETAILS / CONSERVATION PERIOD
Conservation / Conservation / 10 years
Conservation / Forms and coupons / 15 years
Conservation / Contracts / 5 years
Human Resources / Payroll, TC1, TC2, etc. / 10 years
Human Resources / Curriculums / Until the end of the selection process or 1 more year if consent
Human Resources / Docs regarding compensation for dismissalContractsData of temporary workers / 4 years
Human Resources / Worker's file / Max. 5 years after termination
Marketing / Databases or web visitors / While the processing exists
Suppliers / Bills / 10 years
Suppliers / Contracts / 5 years
Access control and video surveillance / List of visitors / 30 days
Access control and video surveillance / Videos / 30 days, blocked 3 years, destruction
Accounting / Books and accounting documents / 6 years
Accounting / Partner agreements and board of directors, company bylaws, minutes, board of director's regulation and delegated committees / 6 years
Accounting / Financial statements, audit reports, records and documents related to grants / 6 years
Taxes / Handle the management of the company, rights and obligations related to the payment of taxes. Dividend payments and tax withholdings / 10 years
Taxes / Information about the intra-group price establishments / 18 years, 8 years intra-group price establishments
Security and Health / Medical Records of Workers / 5 years
Environment / Reports on accidents / 5 years
Environment / Documents related to environmental permits while the activity is being carried out / 3 years after end of activity, 10 years (crime prescription)
Environment / Records on recycling or waste disposal / 3 years
Environment / Grants for cleaning operations. You must keep the documents of rights and obligations, receipts and payments / 4 years
Insurance / Insurance policies / 6 years (general rule), 2 years (damages), 5 year (personal), 10 years (life)
Purchases / Register all deliveries of goods or services, intra-community acquisitions, imports and exports for VAT purposes / 5 years
Legal / Documents for Intellectual and Industrial Property. Contracts and agreements / 5 years
Legal / Permits, licenses and certificates / 6 years starting from the date the permit, license or certificate expires, 10 years (criminal prescription)
Legal / NDA's and Non-competition agreements / Always the date of the obligation or confidentiality
LOPD / Processing of personal data, if different from the treatment notified to the AEPD / 3 years
LOPD / Personal data of employees stored in the networks, computers and communications equipment used by them / 5 years
LOPD / Personal data of employees stored in access control, internal management and administration systems / 5 years
We appreciate your time going through our Privacy Statement. Don't hesitate to contact us for any related question!
© 2023 INGEGNI™. All Rights reserved. Informations on Privacy.