Privacy Policy

Information on the processing of personal data pursuant to art. 13 of EU regulation N. 2016/679 (hereafter GDPR)

We inform, pursuant to art. 13 EU Regulation n. 2016/679 (hereinafter, “GDPR”) that the personal data you have provided may be processed, in compliance with the aforementioned law and confidentiality obligations, in the manner and for the purposes set out below.

Object of the treatment

Pursuant to art. 4 point 2 of the Regulation, for processing personal data means “any operation or complex of operations, performed with or automated processes and applied to personal data or set of personal data, such as collection, registration, organization, structuring , storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or the destruction.

Recipients of Personal Data

We also inform you that (subject to the request of your consent in the cases provided for by the law) the Personal Data you provide will be made accessible for the purposes mentioned above:

• to the employees and collaborators of the Data Controller, as persons authorized to process the data;

• to third-party companies or other entities that perform certain outsourced activities on behalf of the Data Controller, in their capacity as external data controllers;

• to subjects to whom the communication is mandatory by law, which will process your data as Data Controllers.

Purposes of processing and legal basis

The Data Controller will process your Personal Data for the achievement of specific purposes and only in the presence of a specific legal basis provided for by the applicable law on privacy and protection of personal data. Specifically, the data will be processed for purposes related to the reciprocal obligations arising from the contractual relationship established with you and the Data Controller will process your Personal Data only when one or more of the following legal bases occurs:

• you have given your consent free, specific, informed, unequivocal and expressed to the treatment;

• the treatment is necessary to fulfill the obligations provided for by the contract in force with the interested party (natural / legal person);

• implementation of all operational and management activities related to this contract (eg invoicing, credit protection, other administrative, management and organizational services functional to the execution of the contract);

• in the presence of a legitimate interest of the Owner;

• the Holder is bound by a legal obligation to process Personal Data.

• in the case of provision of specific consent, statistical surveys on the degree of customer satisfaction;

The processing of your Personal Data does not require consent, pursuant to art. 6, lett. b), c) and e) of the GDPR, as strictly necessary for the following purposes:

• execution of the obligations established by the contract in force with the interested party (natural / legal person);

• fulfillment of the obligations established by law for the Owner;

• execution of a task of public interest.

No profiling activity will be carried out on the data communicated.

Method of treatment

The processing of your Personal Data is carried out by means of the operations indicated in art. 4 point 2 of the GDPR and precisely: collection, registration, organization, conservation, consultation, processing, extraction, use, cancellation and destruction of data. The data will be processed using appropriate tools to guarantee security and confidentiality and may also be carried out using automated tools to store, manage and transmit the data.

We also inform you that the personal data referred to you will be:

• processed lawfully and fairly;

• collected and registered for specific, explicit and legitimate purposes and used in other processing operations in terms compatible with these purposes;

• exact and, if necessary, updated;

• relevant, complete and not excessive in relation to the purposes for which they were collected or subsequently processed;

• kept in a form that allows identification of the data subject for a period of time not exceeding that necessary for the purposes for which they were collected or subsequently processed.

Data retention period

The Personal Data processed for the purposes set out above will be kept in compliance with the principles of proportionality and necessity, and in any case until the purposes of the processing have been pursued.

Your Personal Data will normally be kept as long as the relationship with the Data Controller exists, without prejudice to the requirements for the collection of residual credits and / or the management of data in the event of any disputes or complaints, such as for example those relating to invoices issued or the performance of the requested services and their possible preservation where necessary for the management of ongoing legal actions and the fulfillment of specific legal obligations.

Data transfer

Personal data are stored in electronic archives located in Italy. In no case is the transfer of personal data to a third country or to an international organization.

Nature of providing data and consequences of refusing to answer

Notwithstanding, that you have the right to object, in whole or in part:

• for legitimate reasons, the processing of personal data concerning him, even if pertinent to the purpose of the collection;

• to the processing of personal data concerning him for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.

it should be noted that the provision of data for the purposes referred to in art. 2 is mandatory and in their absence, we will not be able to carry out the requested activity. For this purpose it is specified that the acquisition of the data that have been or will be requested is an essential prerequisite for the evasion of the requested activities and that any refusal to provide the data requested by you at the time of collection, may involve the objective impossibility for the writer to establish or regularly conduct a contractual relationship with you.

Rights of the interested party

In relation to the aforementioned treatments, you may exercise the rights referred to in Articles 15-21 GDPR (Right of access, right of rectification, right to cancel, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor by registered mail addressed to Guarantor for the protection of personal data, Piazza di Monte Citorio, 121, 00186 Rome,

e-mail to: garante@gpdp.it, or protocollo@pec.gpdp.it or fax number: 06 / 69677.3785.