Privacy Policy

Italian Legislative Decree 196/2003 – Privacy Code

With the entry into force of Italian Legislative Decree 196/03 which lays down provisions for the protection of persons and other subjects with regard to the processing of personal data, the Subject in the heading, as Data controller, is required to provide some information regarding the use of personal data. We therefore inform you that the personal data provided, or otherwise acquired in conformity with the legislative and contractual provisions in force and inherent, connected and/or instrumental to existing relationships, may be processed in compliance with the above-mentioned legislation and the obligations of confidentiality.

Processing of personal data means the collection, recording, organization, retention, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, deletion, and destruction of personal data, or the combination of two or more of these operations.

Purposes of the processing for which the data are intended

The data will be processed for purposes related to mutual obligations arising from existing relationships, and in particular to fulfil:

• administrative procedures;
• civil procedures;
• tax procedures;
• social security procedures;
• organizational – management procedures.

Data processing methods

The data will be processed using instruments suitable for guaranteeing security and confidentiality. Manual and automated means (both computerised and telematic) that are suitable for storing, managing, and transmitting the data will be used.

The personal data in our possession will be collected directly or may be collected from third parties. In the former case, the Data subject will receive the privacy notice when their data is collected; in the latter case, it will be sent to him or her when they register or, if their disclosure is planned, no later than when the first communication is received.

The aforementioned personal data will be processed in accordance with the methods cited in Italian Legislative Decree 196/2003, which indicates, among other things, that said data must be:

• processed lawfully and fairly;
• collected and recorded for specific, transparent, and legitimate purposes;
• accurate and, if necessary, updated;
• pertinent, complete, and not excessive in relation to the formalities of processing.

Data processing is carried out by the Data processor, if there is one, and by the appointees appointed in advance on the basis of Articles 29 and 30, who operate under the control and responsibility of the Data controller.

Categories of subjects to whom the data may be disclosed

The personal data provided will not be subject to dissemination.

The personal data provided may be communicated to subjects to whom the communication of said personal data is necessary or functional for managing the existing contractual relationship, for example:

• financial administration, social security and welfare agencies, public security authorities;
• delivery agencies, carriers, forwarders or other entities for services ancillary to supply;
• companies or professional bodies for fraud control and debt collection;
• banks and credit institutes;
• insurance companies;
• financial statement auditors and administrative, tax, and contract consultants;
• software and hardware maintenance parties;
• subcontractors.

Consequences of refusing consent

It will be impossible to fulfil business relationship and contractual obligations if the Data subject refuses to authorise the processing of his/her data.

Rights of the Data subject

In relation to the aforementioned processing, you may exercise the rights set forth in Article 7 below:

1. The Data subject has the right to obtain confirmation of the existence or non-existence of his/her personal data, even if he/she has not yet registered, and of their communication in an intelligible form.
2. The Data subject has the right to be informed of:
   • the origin of the personal data;
   • the purposes and methods of processing;
   • the logic applied if the data is processed using electronic instruments;
   • the identification details of the Data controller, the Data processors, and the designated representative, in accordance with Article 5 paragraph 2;
   • the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative of the national territory, or as Data processors or appointees.
3. The Data subject has the right to obtain:
   • data updating, rectification, or integration when interested;
   • the cancellation, transformation into anonymous form or blocking of data that is processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
   • certification to the effect that the entities to whom or which the data were communicated or disseminated have been notified of the operations as per letters a. and b., and of their content, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
4. The Data subject has the right to object, in whole or in part;
   • for legitimate reasons, to the processing of his or her personal data, even if pertinent to the purpose of collection;
   • to the processing of his or her personal data for the purpose of sending advertising or for the direct sale of material, or for carrying out market research or business communications.

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