REFERENCE: Privacy notice pursuant to and in accordance with EU GDPR 2016/679 regarding the protection of how personal data is processed
In your capacity as both “Controller” and “Data Subject”, i.e. the entity whose data we process and whose third-party data you yourself process, we would like to inform you of the essential elements of the processing carried out.
Purpose of collecting the data
Personal data are collected and processed for the following purposes:
- to comply with all operations imposed by legal obligations, taxation requirements and duties that may arise from carrying out the business activity and with all regulations on matters of money laundering;
- to establish and execute the ongoing contractual relationship;
- operations strictly relating to and useful for establishing the aforementioned relationships, including acquiring preliminary information before concluding the Contract;
- managing relations with the Customer for the purposes of administration, accounting, orders, shipping, invoicing, services and dealing with any disputes;
- assessing levels of customer satisfaction and for generating statistics for internal use;
- in particular for sending advertising or direct marketing material, for carrying out market research or commercial communications by both automated (email, other remote communication systems through communications networks such as, purely by way of example: text, mms, WhatsApp) as well as traditional means (postal mail), by the Controllers;
and will be processed on the principles of lawfulness, fairness and transparency and safeguarding your confidentiality and rights. The personal data of the Customer only will be processed for contractual purposes, in order to provide services, for commercial disputes and otherwise, and for advertising purposes. The customer's personal data will be processed for the entire duration of the contractual relationships established and also subsequently to comply with all legal obligations as well as for future commercial purposes.
Money laundering and Anti-terrorism
Supplying the data demanded by the laws on matters of Money laundering and Anti-terrorism is mandatory and any refusal to provide such data will make it impossible to obtain the professional service requested and may lead to the facts being notified to the relative supervisory authorities. On this point, notice is given that the processing of personal data to do with money laundering obligations will take place with regard to the specific methods imposed upon non-financial operators by the Regulation on matters of identifying and conserving the information prescribed by art. 3 paragraph 2 of Legislative Decree no. 56/2004, as transposed by Ministerial Decree no. 143/2006. Other information may also be processed by public bodies in order to comply with the obligations of Legislative Decree 231/2007.
Data will be processed, for the purposes stated, by automated means on electronic or magnetic supports, and by non-automated means on paper, conforming to the rules of confidentiality and security provided for by the law, the consequent regulations and internal rules.
Data processing location
Data are currently processed and stored at the registered office, Via dell'Industria, 2/4 - 31029 VITTORIO VENETO (TV). Data are also processed, on behalf of our company, by professionals and/or companies entrusted with carrying out technical, developmental, managerial, administrative and accounting activities.
Mandatory or optional nature of the data supplied
Some data are essential for establishing or for fulfilling the contractual relationship, while other data can be considered ancillary for such purposes. Supplying data to our company is only mandatory if it pertains to a regulatory or contractual obligation.
Consequences of refusal to give consent
In cases where the supply of data is mandatory because of a regulatory or contractual obligation, any refusal to give consent would make it impossible for the Supplier to execute or continue the contract as the processing would become illegal. In cases where there is no legal obligation to supply data, refusal would not bring the above consequences but would make it impossible to execute the ancillary operations.
Dissemination of Data
As well as obligatory communications and notifications made in order to comply with the law, your personal data may be forwarded in Italy and/or abroad to:
- Professionals and consultants, consultancy firms, factoring companies, banking institutions, debt recovery companies, credit insurance companies, marketing information companies and companies providing transport services;
- Public and private bodies, including as a result of inspections or audits such as for example: Taxation Authorities, Excise and Revenue Police, Judicial Authorities, Italian Foreign Exchange Office, the Employment Inspectorate, Local Health Units, Social Security agencies, National assistance board for commercial agents and representatives (ENASARCO), Chamber of Commerce, etc.;
- Entities that may access your data under the terms of the law;
Sensitive data, despite being processed in a totally anonymous way, will not be forwarded or transferred in any way, except in the case of close collaboration with appropriate organisations for the development, implementation, creation and assistance with software developed by us and/or marketed exclusively to achieve the aims set out in this document and only with your express written consent.
Data storage times
The data you supply will be stored in our archives according to the following parameters:
- For the purposes of administration, accounting, orders, providing quotations and the entire production flow, assistance and maintenance, shipping, invoicing, services and dealing with any disputes: 10 years as prescribed by the law and by art. 2220 of the Civil Code, apart from any delayed payments that would justify an extension;
For marketing purposes: 24 months;
Data subject's rights
You are advised that you, the data subject, have the right to:
- Obtain confirmation as to whether or not we are processing your personal data, even if not yet registered, and that these data are made available to you in an intelligible form;
- Obtain details and, if required, copies of: a) the origin and categories of personal data concerned; b) the logic applied if the information is processed with the aid of electronic means; c) the processing purposes and methods; d) the identity of the data controller and processors; e) of the entities or categories of entities to which the personal data may be communicated and who may gain knowledge of them, especially if the recipients are in third countries or are international organisations; e) where possible, the period for which the data will be stored or the criteria used to determine this period; f) whether or not an automated decisional process exists, including profiling, and in such cases the logic used, the importance and the consequences for the data subject; g) whether or not there are adequate guarantees in the event of the data being transferred to a country outside the EU or to an international organisation;
- obtain, without undue delay, updating and correction of incorrect data as well as the integration of incomplete data;
- exercise the right to withdraw consent at any time, easily and without any hindrance, and where possible using the same channels used when the data was supplied;
- have erased, converted into an anonymous form or ceased to be processed any data which is: a) illegally processed; b) no longer necessary in relation to the purposes for which they were collected or subsequently processed; c) if the consent on which the processing is based is withdrawn and if there are no other judicial grounds, d) if you oppose the processing and there is no legitimate reason to continue with processing the data; e) in order to fulfil a legal obligation; f) if the data concerns a minor. The Data Controller may only refuse to erase the data in order to: a) exercise the right to freedom of expression and information; b) fulfil an overriding legal obligation, to execute a duty undertaken in the public interest or for a public authority; c) for reasons of public health; d) storage in the public interest, scientific or historical research or for statistical purposes; e) to exercise a right in court proceedings;
- obtain restriction of the processing if: a) the accuracy of the personal data is contested; b) the Controller acts illegally to prevent erasure; c) to exercise your right in court proceedings; d) to verify whether the legitimate grounds of the controller override those of the data subject;
- if the processing is carried out by automated means, to receive the personal data concerning you without hindrance and in an organised, commonly used and machine-readable format and have the right to transmit those data to another Controller or – if technically feasible – to have them transferred directly by the Controller to another Controller;
- to object, either in whole or in part: a) for legitimate reasons, to the processing of your personal data, even if pertinent to the purpose for which it was collected; b) to the processing of your personal data for the purposes of sending advertising or direct marketing material or for carrying out market research or marketing communications, by the use of automated calling systems without the intervention of an operator by email and/or traditional marketing methods via telephone and/or postal mail;
- complain to the Independent Supervisory Authority for the protection of Personal data.
In the above cases, where necessary, the Controller will notify all third parties to whom your personal data have been communicated that you have exercised your right, except for specific cases (e.g. where such action proves impossible or involves the use of means clearly disproportionate compared to the right protected).
Methods of exercising your rights
You may exercise your rights at any time:
- by sending the Data Controller a registered letter with return receipt;
- by sending an email to firstname.lastname@example.org
- by telephoning +39 0438 500044
Data Controller and Processor
The Data Controller, who you may contact to exercise your rights as outlined in this privacy notice, see the methods for exercising your rights, is TECNOSYSTEMI SPA with head office in Via dell' Industria 2/4 - 31029 VITTORIO VENETO (TV); You may exercise the aforementioned rights by the methods specified.