Data Protection Policy

The protection of your Personal Data matters to us.
We aim to process your Personal Data in a lawful, appropriate and transparent manner.

Take your time to read this Data Protection Policy.

In accordance with the European General Data Protection Regulation (EU) 679/2016 (GDPR) article 13 and the Italian Privacy Code (D.lgs. 196/2003 as amended by the D.lgs.101/2018), Daikin Applied Europe S.p.A, (hereinafter “DAE”), a company part of the Daikin Group, wishes to inform you regarding the use of your Personal Data collected from you (hereafter indicated as the “User” or “you”) through its local Website.

Key Definitions

Data Controller: means a natural person or a legal entity which determines purposes and means of the Processing of Personal Data;

Data Processor: means a natural person or a legal entity which processes Personal Data of a given Data Subject under the Data Controller’s instructions;

Data Subject: means an identified or identifiable natural person whose Personal Data are processed;

Personal Data: means any information relating to an identified or identifiable natural person (‘Data Subject’) such as a name, an e-mail address, an identification number, location data, an online identifier etc.;

Processing of Personal Data: means any operation or set of operations which is performed on Personal Data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Special Categories of Personal Data: means any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data processed for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation;

Website: means the Daikin website reachable at the following link: https://www.daikinapplied.eu

1. Data Controller and Data Protection Officer

The Data Controller is Daikin Applied Europe S.p.A. (DAE), with registered office in Ariccia (Rome), 00040, Via Piani di S. Maria no. 72, VAT no. 01318801006, phone 06-937311, fax 06-9374014, email: dataprivacy@daikinapplied.eu.
The Data Protection Officer can be reached by clicking here

2. Personal Data we collect, purposes and legal basis of the processing

DAE may collect, process, register, store and transfer your Personal Data provided through the Website while, for example filling in online registration Forms or submitting job application. You can be asked to provide us, depending on the purpose of each Processing and to the extent necessary, different kind of Personal Data including, but not limited to, name, surname, address, telephone, mobile, email address, country, curriculum information, etc.

Even if not directly requested by DAE, you may also provide us some Special Categories of Personal Data (e.g.  trade union membership, Personal Data concerning health) when submitting a job application.

Personal Data are collected either on a facultative basis or on a compulsory basis. If it is compulsory to provide the Personal Data, this will be marked accordingly. In case you fail or deny providing the Personal Data that DAE has marked as compulsory, DAE will not be able to carry on the process or the activity requested by you.

An example of Personal Data that is marked as compulsory is the situation in which a Data Subject wants to submit an inquiry related to our products or services. In this case DAE needs some personal details in order to process the related inquiry. If the Data Subject wishes to submit an inquiry but does not provide the personal details marked as compulsory, DAE will not be able to accept and process the inquiry.

2.1 Purposes of the collection of Personal Data

DAE processes your Personal Data solely in the manner, under the terms and for the purposes listed below:

(I) Customers’ inquiry management

DAE will need some Personal Data provided by Data Subjects through online Forms and Applications with regard to the management of the relationship with customers and to contact the customer in response to a specific enquiry.

Providing Personal Data for this specific purpose is compulsory and failing to do so will make impossible to answer to your requests. The legal basis of the Processing is the performance of a contract or the performance of pre-contractual steps prior to entering into a contract, according to article 6 (b) of the GDPR.

(II) Quality improvement of products and services

DAE may process Personal Data collected through Forms, inquiries, comments, feedback submitted to DAE in order to: improve its products and services; carry out further surveys; develop analytical, risk, marketing and other models and to produce statistics.

Example: DAE may need to process the number of people that have selected a specific DAE product or have applied for a certain service in a specific country.

In this regard, DAE commits as much as possible to aggregate Personal Data in anonymous form to make sure that these Personal Data are not easily or are no longer identifiable as yours.

The practice of Processing Personal Data for statistical purposes is particularly justified by DAE’s desire to put in place strategic choices in order to better perform in the market and to provide you with better products and services. The legal basis of the Processing is the legitimate interest, according to article 6 section (f) of the GDPR.

(III) Recruitment and Selection

For the purpose of recruiting talents, DAE collects Personal Data such as, but not limited to, name, email, phone number, curriculum information. This processing is allowed by the fact that applicants are voluntarily taking steps in order to enter into a contract with DAE.

The Personal Data provided by applicants (when entering Applications) will be used for Processing applications, contacting applicants for human resources management related activities, managing hiring processes (e.g. inviting applicants for interviews and for conducting written tests) and drafting employment contracts.

For this Purposes providing Personal Data is compulsory and failing to do so will make impossible to go ahead with the recruitment process. The legal basis of the Processing is the performance of a contract or the performance of pre-contractual steps prior to entering into a contract, according to article 6 (b) of the GDPR.

(IV) Sending Newsletter

DAE may send you newsletters about DAE business. With reference to this purpose, the legal basis of the Processing is your consent, according to article 6 section (a) of the GDPR; you can always exercise the right to withdraw your consent as described in paragraph 9.

(V) Legal obligations and claims

DAE can also process Personal Data in order to fulfil legal obligations and safeguarding DAE rights in case of legal claims and disputes; With reference to this purpose, the legal basis of the Processing is related with the compliance with legal obligation according to article 6 section (c) of the GDPR.

The Personal Data provided by you will be processed mainly by electronic means under the authority of the Data Controller, by persons specifically appointed, authorized and instructed for the Processing according to Articles 28 and 29 of the GDPR. Appropriate security measures will be observed also under Article 32 of the GDPR to prevent data loss, illicit or incorrect use and unauthorized access.

3 To whom and in what context the Data Controller may transmit the Users’ Personal Data

For the above purposes, DAE may need services, assistance from third parties, including, but not limited to, Daikin Group Affiliates, data hosting, supply services, Internet providers’ services and public authorities, where this is required by law or upon their request.

In this regard, to the extent necessary, we can transmit or disclose Personal Data we collected to any natural person or legal entity, to subcontractors and Daikin Group Affiliates.

Every time that a third-party acts as Data Processor, DAE will make sure to have in place a data processing agreement with this third party under the provisions of Regulation (EU) 679/2016, asking the third party to comply with the principles and the provisions of the same Regulation and to align on appropriate security standards.

Your Personal Data collected through online Forms in the Website, for the purpose described in the point (i) of paragraph 2.1, may be transferred to other Daikin Group’s Affiliates acting as Data Controllers.

4 Transfer personal data to third countries (NON-EU)

Within the scope of the above described purposes DAE may transmit the Personal Data collected, with other Daikin Group’s companies and/or Business Partners established in any non-EU countries.

In any case of transfer of Personal Data towards a non-EU country, Daikin shall:

  • ensure an adequate level of protection by setting appropriate safeguards and complying with the provisions of Regulation (EU) 679/2016;
  • manage the transfer of Personal Data on the basis of:
  1. a) European Commission’s adequacy decisions; if not
  2. b) standard contractual clauses;

5 How Daikin uses Cookies

Through the use of Cookies, DAE may collect some Personal Data in order to facilitate the use of the Website and to increase your comfort while using them.

DAE uses different types of Cookies. Please, read more about Cookies, what they are, what types we use and why we are using these in our “Cookie policy”.

6 Duration of the Processing

DAE does not keep your Personal Data forever. We use your Personal Data to the extent necessary and only with the aim of pursuing the purposes described above. Once the aim no longer exists, we commit to delete the Personal Data.

Personal Data collected for Recruitment and Selection purposes will be retained for not longer than 24 months.

Users who have provided their consent to the processing of personal data to receive newsletters, will be reminded of the possibility to withdraw their consent at periodic intervals of 12 months, as long as the processing continues, unless the User requests to opt-out.

As has been stated, DAE commits as much as possible to work with aggregated, anonymized or Pseudo-Anonymized Personal Data and in all cases, it will cease the connections to individuals as quickly as possible.

7 Minors

Through its Website DAE does not process any Personal Data of natural persons aged under 14, neither does it make commercial offers to or tries to contact them, unless their legal representative has consented.

8 Your rights as Data Subject

If you have any questions about the protection of your Personal Data or the exercise of your rights, you can contact us at any time by writing to Daikin Applied Europe S.p.A and by sending via postal mail a specific Form or by submitting the Form available online throughout the Website.

You have several rights as Data Subject that can be exercised, as listed below.

DAE can only properly answer queries filled in sufficient detail. DAE will need to verify your identity in as much detail as possible, in order to avoid that someone else tries to exercise your rights. You will therefore be asked to provide a valid identification document when making such a request.

 You can have access to your Personal Data

You can access the Personal Data that DAE processes about you or you can know more about:

  • the purposes of our Processing;
  • the categories of Personal Data concerned;
  • the categories of recipient to whom the Personal Data have been or will be disclosed;
  • the envisaged period of storage or the criteria used to determine that period;
  • the Data Subject’s rights;
  • the rights you can exercise with respect to our Processing;
  • the existence of Automated Decision-Making, including Profiling, and envisaged consequences;

You can complete/rectify/erase/restrict the processing of your Personal Data

It can happen that certain Personal Data held by DAE are not (or have ceased to be) correct. It can also happen that you want to add something to the Personal Data you provided us.

If you want DAE to erase your Personal Data your request will be processed, unless no impediment or incompatibility arise according to law or Legitimate Interests towards the deletion.

You can also obtain the restriction to the Processing of your Personal Data at any time.

You can ask for the portability of your Personal Data to yourself or to third parties

If your Personal Data were collected through electronic means, you can ask for the portability of the Personal Data you provided us to yourself or to third parties.

You can withdraw your consent to Processing of your Personal Data

Please remember that every time you provide your consent to process your Personal Data, you can subsequently withdraw that consent at any time by following the suggested procedure and as easily as you gave it.

You can object to Processing or object to Processing by automatized decision-making systems

If you disagree with how DAE processes certain Personal Data, you can object. We shall process objections unless there are valid reasons not do so or reasons provided by law (for example, an objection will be declined if the Processing of Personal Data has been conducted in view of combating fraud).

If you want to exercise the rights described in this paragraph, please click here 

If you do not agree with the way DAE is Processing your Personal Data or you have other questions in this regard, you can always contact the Data Protection Authority of your country of residence (for instance if you reside in Italy, you can contact the Data Protection Authority involved: Piazza Venezia n. 11 – 00186 Rome, web site www.gpdp.it or www.garanteprivacy.it, fax (+39) 06.69677.3785, telephone (+39) 06.69677.1, email: garante@gpdp.it.

  • Security measures

Through the Website, your Personal Data are processed in compliance with the applicable law, using appropriate security measures, in accordance with the legislation in force pursuant to Article 32 of the General Data Protection Regulation. In this regard, inter alia, appropriate security measures are once again adopted to prevent unauthorized access, theft, unauthorized disclosure, alteration or destruction of the Users’ data.

  • Changes to the Privacy Policy

This Data Protection Policy can be changed or updated in the light of upcoming legislations, both at international, European and national level.

You can always find the most recent version of our Data Protection Policy available in the Website by clicking on the “Data Protection Policy” section.

Last modified: September 2019


Contact DPO

If you want to exercise your rights, please fill in the following request form with the necessary information (the required fields are marked with an asterisk (*)).
Personal Data collected through the following form will be used by Daikin in accordance with the Regulation (EU) 679/2016, only to process your request.

  • Date Format: MM slash DD slash YYYY

Request form to exercise your rights

If you want to exercise your rights, please fill in the following request form with the necessary information (the required fields are marked with an asterisk (*)).
Personal Data collected through the following form will be used by Daikin in accordance with the Regulation (EU) 679/2016, only to process your request.