Informative

Privacy policy and cookie policy

This document provides information on how Pomilio Blumm processes personal data sent by users who consult this website or use forms to send messages and information requests.

Privacy Policy for Clients and Suppliers

PRIVACY NOTICE PURSUANT TO ARTICLES 13 TO 22 OF EU REGULATION 679/16 AND REQUEST FOR CONSENT

General Data Protection Regulation

By this document, and pursuant to Articles 13 to 22 of EU Reg. 679/2016, the Data Controller wishes to inform how it processes the personal data of its Clients and Suppliers.

1 - Types of data processed

The types of data processed are:

  • First name, last name
  • Place and date of birth
  • Tax code/VAT number
  • Residence/Registered office
  • Bank details
  • Customer code
  • E-mail

2 - Purposes of processing

2.1 - Mandatory legal purposes, essential for fulfilling contractual obligations, protecting company rights regarding Clients and Suppliers

  • Management of pre-contractual relations
  • Contractual execution
  • Fulfillment of contractual obligations
  • Fulfillment of regulatory obligations
  • Protection of company rights
  • Execution of orders from judicial authorities and/or independent authorities

2.2 Purposes essential to contract execution, for which failure to provide consent makes it impossible to conclude the agreement

Essential purposes for managing pre-contractual and contractual phases (including, by way of example, data communication to electronic communication service providers, e.g. Domain Name Registrars)

3 - Types of processing operations performed on personal data

  • Collection from public databases (e.g. Chamber of Commerce)
  • Collection through contract forms
  • Upload to IT systems for contractual, administrative, and technological management
  • Communication to IP address registries (RIPE, ARIN, etc.) and domain name registrars
  • Communication to logistics, transport, and shipping service providers
  • Communication to banking and financial service providers
  • Communication to professionals and consultants for dispute management (settlements, out-of-court, and judicial)
  • Communication to public entities and authorities
  • Selective and automated traffic filtering via antivirus, antispam, and intrusion detection systems
  • Content storage (to the extent specified in the contract and/or provided the Client has not deleted content independently)
  • Sending and receiving email messages
  • Data disconnection for personal data required to be kept for regulatory compliance, by moving it to separate systems/storage media distinct from those used for ordinary operations
  • Deletion upon data subject request (including following the exercise of the right to removal from phone directories) or following termination of the legal basis for processing

4 - Data location

The data centers used by the Controller are located in the European Union.

5 - Scope of communication and disclosure

Clients and Suppliers are informed that:

  • Due to the nature of the TCP/IP protocol and the technical/organizational structure of the internet, data (including general data) sent and received by Clients/Suppliers may transit outside the EU (e.g., routing of data packets)
  • (Limited to the Client) data provided to request IP allocations may be published by European entities (like RIPE) or entities outside the EU (like ARIN)
  • (Limited to the Client) domain name registration data may be made available via WHOIS services for ccTLD.it outside the EU, or via WHOIS services of other domain registration providers outside the EU. The Controller is unaffiliated with these operations and the Client must contact the respective Controllers directly to activate contact privacy masking where available
  • Common antispam systems rely on third-party blacklists. The IP address/domain of the Client/Supplier may be blacklisted for reasons outside the Controller's control, leading to email delivery issues. The Controller has no legal standing to intervene with blacklist managers, who may be located outside the EU
  • Institutional bodies like the National Cybersecurity Agency may independently perform security tests on public Italian IPs, including those of Clients/Suppliers. The Controller has no visibility over this data or third-party access. The Controller is entirely separate from these activities, their results, timings, and methods

6 - Security measures

6.1 - Technical measures

  • Software and databases comply with data protection by design and data protection by default principles
  • The corporate network is protected by firewalls
  • Connections to potentially harmful websites are blocked
  • Antispam and antivirus protection systems are active
  • Within technical limits under the Controller's direct control, VPN connections are free of backdoors or traffic interception tools
  • Individual client machines are protected by username/password (changed mandatorily every 3 months) and antivirus software
  • User accounts are managed via domain controllers, granting precise access control over communication tools, applications, and file servers
  • Inactive or expired accounts are automatically disabled
  • Storage media intended for third parties are low-level formatted before handover
  • Unused storage media are destroyed or rendered illegible
  • Physical documentation is stored securely to prevent unauthorized access

6.2 - Organizational measures

  • Where required by the GDPR, the Controller's vendors execute data processing agreements
  • Vendors not classified as "Processors" are contractually bound to process personal data lawfully and securely
  • All employees have received adequate training on GDPR compliance and internal policies
  • Internal procedures have been updated to accommodate personal data protection requirements
  • Audit processes monitor compliance with internal security procedures
  • Procedures exist for internal investigations for defensive or disciplinary purposes, communicated to staff prior to deployment
  • A Data Protection Officer has been appointed
  • System administrators are formally designated
  • Authorized data processing personnel are identified
  • A Data Breach management procedure is in place

7 - Rights under Articles 13-25 of EU Reg. 679/2016

EU Regulation 679/16, in Articles 13 through 22, grants data subjects various rights, including rectification, erasure, or restriction of processing carried out by the Data Controller.

These rights remain enforceable against the Data Controller following the termination of contractual relationships for any reason.

Rights may be exercised by contacting the Data Controller directly, specifying the affected data and the reason for the update, correction, erasure, restriction, or portability request.

Requests must be sent to the Data Controller's registered address along with a valid ID of the applicant.

If exercised via an agent, the request must include a power of attorney granting authority to request and receive responses, along with the representative's ID.

Within 30 days of receiving the request, the Controller will notify the applicant of its approval or refusal (providing detailed grounds for any rejection).

Data subjects may always assert their rights under EU Reg. 679/2016 by contacting the Data Protection Authority or ordinary judicial authorities.

CONSENT MANAGEMENT

Clients/Suppliers acknowledge this notice and note that mandatory data processing for regulatory and contractual fulfillment, specifically regarding:

  • Communication to IP/domain name registries within the EU
  • Communication to IP/domain name registries outside the EU, provided adequate legal protection is guaranteed
  • Communication to electronic communications sub-processors for service activation
  • Management of profiles on social networks/content delivery platforms

Do not require explicit consent, as they are performed under statutory legal bases and/or contractual necessity.

Privacy policy for candidates

PRIVACY NOTICE PURSUANT TO ARTICLES 13 TO 22 OF EU REG. 679/16

Pursuant to Articles 13 to 22 of EU Reg. 679/2016, the Data Controller provides information on the processing of personal data belonging to candidates submitting resumes spontaneously or in response to job postings.

1 - Types of data processed

The types of data processed include details standard to European resume formats.

2 - Purposes of processing

Data is processed to evaluate candidate suitability for potential employment opportunities.

3 - Types of processing operations performed on personal data

  • Upload to IT systems for applicant management
  • Communication to consultants and advisors for legal and job classification assessment
  • Retention for the duration necessary to conclude the evaluation procedure, up to a maximum of 24 months from receipt
  • Deletion upon termination of the legal basis for processing

N.B. Resumes are not evaluated using automated decision-making processes; all recruitment decisions are made exclusively by humans.

4 - Data location

Personal data contained in resumes is stored within the European Union.

5 - Scope of communication and disclosure

Personal data in resumes is not disclosed publicly. It is shared exclusively with authorized public authorities, as well as legal, accounting, and HR consultants for relevant assessments.

6 – Security measures - Erasure

Resumes are saved on network resources controlled by the Data Controller, accessible solely to HR staff tasked with candidate evaluation and interviews.

The Controller's technical infrastructure is secured via firewalls, antivirus, and antispam controls; data is backed up, and personnel are instructed to handle personal data strictly within assigned job duties using company tools.

Upon expiration of the retention period defined in Section 3, resumes will be deleted unless longer retention is mandated by law.

7 - Rights under Articles 13-25 of EU Reg. 679/2016

EU Regulation 679/16 (Articles 13-22) guarantees data subjects rights to request data access, correction, deletion, or processing restrictions from the Data Controller.

Rights may be exercised by contacting the Data Controller directly, detailing the exact data concerned and the reason for modification, update, erasure, blocking, or data portability.

Requests must be addressed to the Data Controller's registered address along with a copy of the applicant's identity document.

If acting via a proxy, the request must include a power of attorney granting explicit authority to receive information, alongside the representative's ID copy.

The Controller will respond within 30 days of receipt, stating whether the request is accepted or rejected (providing detailed justifications in case of refusal).

Data subjects retain the right to lodge a complaint with the Data Protection Authority or the competent courts under EU Reg. 679/2016.

CONSENT MANAGEMENT

Candidates acknowledge this privacy notice and note that processing required to assess candidacy for potential employment does not require consent, as it relies on legal grounds (Legislative Decree 196/03 Art. 111-bis - Information in case of receiving CVs) and/or legitimate interest.

Data Protection and Cookie Policy

Preamble

This privacy policy applies whenever browsing content on Pomilio Blumm S.r.l. domains allows the collection of information that directly or indirectly identifies a natural person.

Processing carried out by third parties (access providers, hosting providers, social network operators, analytics services) is governed by their respective privacy policies, which users are encouraged to review:

  • Google/Youtube (https://www.google.it/intl/it_it/policies/technologies/cookies/)
  • Linkedin (https://www.linkedin.com/legal/privacy-policy)
  • Akamai (https://www.akamai.com/legal/privacy-and-policies)

Identification of the Data Controller

The Data Controller is Pomilio Blumm S.r.l. - Lungomare Papa Giovanni XXIII n. 22 - contact@pomilio.com – phone +39 085 421 2032

Data Protection Officer Contact Details

The Data Protection Officer can be reached at: DPO c/o Pomilio Blumm S.r.l. - Lungomare Papa Giovanni XXIII n. 22 – dpo@pomilio.com

Data categories, purposes, and legal bases of processing

1 - Introduction

This website can be browsed anonymously and, in this mode, does not process personal data.

2 - Purposes and legal basis for processing

A - Direct processing of anonymous data generated by website access

Traffic logs generated automatically by systems (IP, user agent, timestamp, pages visited) and data from website usage analytics systems are used solely to ensure proper system operations, carry out maintenance and upgrades, protect the Controller's legal rights, and meet legal obligations.

B - Third-party processing of anonymous data generated by website access

The Controller uses the Matomo analytics platform, which does not collect personal data or export information outside the European Union, to fulfill statutory obligations (e.g., international localization rules) and protect the Controller's legal rights.

Matomo operates via cookies and tracking pixels on company websites. The anonymous traffic data mentioned in item A above may be shared with analytics providers who return aggregated reports to the Controller.

The Controller cannot identify users accessing its sites, but third-party analytics providers may possess additional data that enables them exclusively to identify individual users.

The Controller has no access to this additional data; the third-party provider is responsible for informing users and obtaining consent where required by law.

Users are responsible for reviewing the Controller's privacy policy before deciding whether to continue browsing the website.

C - Processing of personal data related to emails

All communications sent to the Controller via web forms or institutional email addresses are processed to respond to inquiries, protect the Controller's legal rights, and comply with regulatory requirements (e.g., documenting response times for data subject requests).

D - Data processing resulting from access to official social media pages and profiles

The Controller maintains official pages and profiles across social networks, each operating under its own privacy policy. Accessing the Controller's social media profiles triggers third-party processing, which may include collecting and analyzing user personal data.

The Controller has no access to this data and receives only aggregated analytics that do not permit personal user identification or individual profiling.

E - Processing of personal data posted by users accessing official social network pages and profiles

While user posts containing personal data are discouraged, users may post content containing personal details on official social profiles. In such cases, the Controller performs no processing other than collecting, storing, or deleting content to protect its legal rights.

3 - Categories of personal data processed

If identifying a user becomes necessary (e.g., upon registration), only essential data required to interact with the user will be collected: name, surname, and email address, plus any additional details specified prior to collection. Only an email address (which need not include a real name) is required to respond to inquiries under item 2.c.

4 - Purpose and legal basis of processing

Data specified in section 3, along with related traffic logs, is processed for the purposes and legal grounds listed in section 2 of this notice.

5 - Processing methods

Personal and non-personal data collected via this website are processed electronically through connection log systems (for site delivery), automated analysis tools (for troubleshooting and statistics), and automated messaging systems (for handling email communications).

6 - Use of cookies and trackers

This website:

  • Uses technical cookies necessary for site functionality
  • Does not use proprietary tracking or cross-site tracking systems
  • Uses cookies required by Matomo and LinkedIn services to generate aggregated website usage statistics

7 - Security measures

Hosting

The web hosting infrastructure provides high availability, automated backups, and perimeter network protection.

Server

  • Operating systems, web servers, and application dependencies (e.g., databases, preprocessors) are regularly updated
  • Administrative and traffic log credentials are assigned strictly to authorized staff for technical operations
  • Cloud server access requires two-factor authentication via verification codes on authorized devices

Publishing Platform

  • Database systems and plugins powering the platform are updated as new releases become available
  • CMS access credentials are managed under strict password security policies

Access Management

  • Personnel accessing server environments and CMS administrative tools receive explicit operational instructions
  • Administrative access is strictly assigned to named accounts and continuously logged

8 - Data processing locations

Data centers hosting the website infrastructure are located in the European Union.

We use Cloudflare services to manage DNS records for the domain pomilioblumm.eu.

Cloudflare acts as a DNS service provider and may process technical data associated with domain resolution requests (e.g., DNS queries). Processing complies with Cloudflare's privacy policy, accessible at: https://www.cloudflare.com/privacypolicy/

Data processing related to analytics services complies with the privacy policies of Matomo, LinkedIn, and any active vendors.

9 - Third-party Data Processors (Art. 28 GDPR)

Where applicable, Data Processing Agreements have been executed with third-party service providers.

The publishing platform is hosted on European servers provided by DigitalOcean. DigitalOcean acts as a cloud hosting and infrastructure vendor. Processing on these servers complies with applicable data protection regulations. For details, visit DigitalOcean's privacy policy: https://www.digitalocean.com/legal/privacy-policy

Email infrastructure and delivery services are managed by Google Inc. (https://support.google.com/policies/answer/9581826?hl=it)

Platform maintenance, collection of anonymous usage statistics, and email communications handling are managed by the Controller, which may engage technical sub-processors for dispatch activities.

10 - Retention period

Personal data processed is retained for the longest applicable statutory limitation period for civil and criminal claims, after which it is destroyed.

Email addresses provided voluntarily are processed for declared purposes until consent is revoked.

11 - Scope of communication and disclosure

Data collected through this site or submitted voluntarily is not shared with third parties, except for technical necessity related to platform operation or legal and international compliance requirements.

Embedded content from social networks and statistical cookies may allow third-party platforms to collect traffic data and match it with existing user profiles. Before interacting with embedded content or granting cookie consent, users are advised to review the privacy notices of the respective platforms.

No personal data is published or disclosed by the Controller beyond what is explicitly declared herein.

12 - Consent to processing

Without prejudice to the fact that failure to provide consent does not prevent access to or consultation of the Website, the following processing activities do not require the data subject's consent:

  • The processing of anonymous data;
  • Any processing of personal data for the purposes and on the legal bases set out in this Privacy Notice.

The following activities do require the data subject's consent:

  • The local installation of cookies and tracking technologies for the purposes of:
    • Enabling the Controller to use third-party analytics platforms;
    • Enabling links to the Controller's official pages on social networking platforms;
  • The use of the data subject's email address (where it constitutes personal data) for the purpose of sending newsletters requested by the data subject.

Specifically, newsletters are distributed through IT and electronic communication infrastructures owned by, or lawfully available to, the Controller. The Controller may also engage technology service providers, email management providers or message delivery service providers, duly authorised or appointed as data processors pursuant to Article 28 of Regulation (EU) 2016/679.

The email address used for newsletter subscriptions is neither disclosed nor communicated to third parties for their own independent promotional purposes, unless the data subject has provided specific and separate consent or another appropriate legal basis provided by law applies.

The Controller may record the information necessary to demonstrate that consent has been validly obtained, including the date and time of subscription, the email address used, the version of the Privacy Notice accepted and, where applicable, confirmation of the subscription completed through the relevant verification procedure. Such information is processed in accordance with the principles of necessity, proportionality, data minimisation and storage limitation.

The data subject may withdraw consent at any time, without any formalities and as easily as it was given, by using the unsubscribe link included in each newsletter or by contacting the Controller using the contact details provided in this Privacy Notice.

Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal. Following an unsubscribe request, the sending of communications will cease within the technical time strictly necessary to process the request. The Controller may retain only the information strictly necessary to document the withdrawal of consent, prevent any further unsolicited communications and protect its legal rights, in compliance with the applicable retention periods.

This is without prejudice to any exceptional circumstances in which applicable law permits communications to be sent by email without obtaining fresh consent, provided that all statutory conditions are fully met and the data subject is always given the opportunity to object to any further communications easily and free of charge.

Data Protection and Cookie Policy Integration

Newsletter

Specifically, newsletters are distributed through IT and electronic communication infrastructures owned by, or lawfully available to, the Controller. The Controller may also engage technology service providers, email management providers or message delivery service providers, duly authorised or appointed as data processors pursuant to Article 28 of Regulation (EU) 2016/679.

The email address used for newsletter subscriptions is neither disclosed nor communicated to third parties for their own independent promotional purposes, unless the data subject has provided specific and separate consent or another appropriate legal basis provided by law applies.

The Controller may record the information necessary to demonstrate that consent has been validly obtained, including the date and time of subscription, the email address used, the version of the Privacy Notice accepted and, where applicable, confirmation of the subscription completed through the relevant verification procedure. Such information is processed in accordance with the principles of necessity, proportionality, data minimisation and storage limitation.

The data subject may withdraw consent at any time, without any formalities and as easily as it was given, by using the unsubscribe link included in each newsletter or by contacting the Controller using the contact details provided in this Privacy Notice.

Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal. Following an unsubscribe request, the sending of communications will cease within the technical time strictly necessary to process the request. The Controller may retain only the information strictly necessary to document the withdrawal of consent, prevent any further unsolicited communications and protect its legal rights, in compliance with the applicable retention periods.

This is without prejudice to any exceptional circumstances in which applicable law permits communications to be sent by email without obtaining fresh consent, provided that all statutory conditions are fully met and the data subject is always given the opportunity to object to any further communications easily and free of charge.

13 - Statutory rights and exercise methods

Data subjects have the right to request access to, rectification of, or erasure of personal data, restriction of processing, or to object to processing (Articles 15 et seq., GDPR). Requests may be submitted via:

  • Registered mail with acknowledgment of receipt to the Controller's registered office
  • Email to: contact@pomilio.com

Pursuant to law, the application must include an identity document of the applicant. If submitted via a proxy, it must include a authorization proxy, representative ID, and specify whether the response should be addressed to the principal or the proxy.

Responses will be provided within 30 working days of receipt via the same delivery method and to the address specified in the application.

The applicant or designated representative is solely responsible for verifying that the specified physical or email address is active and monitored.

14 - Administrative complaints and judicial remedies

Data subjects who consider that processing of their personal data via this website breaches the Regulation have the right to lodge a complaint with the Data Protection Authority (Art. 77 GDPR) or seek judicial remedies (Art. 79 GDPR).

This website can be browsed completely anonymously. Anonymous profiling cookies for aggregated analytics are deployed only upon user consent. It does not identify or render identifiable any individual to Pomilio Blumm, except as accessible to analytics service providers. Details are published in this privacy notice.

Copyright and Intellectual Property

Domain Name Ownership

All corporate domain names are assigned to Pomilio Blumm S.r.l.

Copyright

Content published on this site is protected under Italian Copyright Law (L. 633/41) and remains the exclusive intellectual property of Pomilio Blumm S.r.l. Any use must be authorized in advance.

Direct linking to pages on this site is permitted; embedding pages within third-party sites is prohibited.

The publishing platform relies primarily on standard web technologies, including JavaScript, PHP, and HTML. This approach ensures enhanced control over data processing and infrastructure security. Certain third-party features are managed via MySQL databases.

Trademarks and Distinctive Marks

All trademarks, logos, and textual names used on this site, unless owned by third parties, are the property of Pomilio Blumm S.r.l. pursuant to Legislative Decree 30/2005 (Industrial Property Code).

Social Media Policy

Pomilio Blumm S.r.l. encourages interaction with anyone interested in its initiatives. However, before sharing content or data, users should observe the following guidelines.

1 – Publishing personal data

Unless strictly necessary, users should refrain from posting personal data belonging to themselves or third parties. If necessary, review Pomilio Blumm S.r.l.'s Data Protection and Cookie Policy prior to posting.

2 – Tone and form of communication

Pomilio Blumm S.r.l. promotes respectful and civil communication. Offensive, obscene, or inappropriate posts are prohibited. This includes, without limitation, content damaging personal reputation/dignity, infringing intellectual or industrial property rights, or promoting illegal goods and age-restricted services.

3 – Content moderation

Pomilio Blumm S.r.l. does not engage in proactive or general surveillance of user-generated content. However, upon notification of potential legal violations, it reserves the sole right to hide content and share available information with competent authorities.

4 - Intellectual property of official page content

All content published by Pomilio Blumm S.r.l. is its exclusive intellectual and industrial property or used under license from rights holders.

Content reuse is allowed within statutory copyright limits, subject to express permission and provided it remains strictly non-commercial.

5 - Intellectual property of user content and royalty-free license to Pomilio Blumm S.r.l.

Intellectual and industrial property rights over content posted by users on Pomilio Blumm S.r.l. official channels remain with the original authors.

Subject to moral rights and author attribution, Pomilio Blumm S.r.l. is granted a royalty-free, perpetual, worldwide, cross-platform license to reuse user-submitted content across all institutional and promotional activities.

6 – Availability of official pages and profiles

While official profiles are generally accessible, Pomilio Blumm S.r.l. assumes no obligation to guarantee availability across all geographic regions, full functionality, or specific language versions.

7 – Information accuracy

Pomilio Blumm S.r.l. takes reasonable measures to publish accurate, up-to-date information, but undertakes no legal obligation to guarantee continuous updates.

Consequently, users are advised to contact Pomilio Blumm S.r.l. directly before taking actions based on published site content.