The DAV Tech Srl (hereinafter "Holder"), as data controller, informs you pursuant to art. 13 D.Lgs. 30.6.2003 n. 196 (hereinafter, "Privacy Code") and art. 13 EU Regulation n. 2016/679 (hereinafter, "GDPR") that your data will be processed in the manner and for the following purposes:
1. Object of the Treatment
The Data Controller processes personal data, such as name, surname, company name, address, telephone number, e-mail address, bank and payment details) - hereinafter, "personal data" or even "data") that you have communicated on the conclusion of contracts for the services of the Owner.
Purpose of the Treatment
Your personal data are processed:
A) without your express consent (Article 24 letter a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes:
- conclude the contracts for the services of the Owner;
- fulfill the pre-contractual, contractual and tax obligations deriving from relations with you in existence;
- fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as for anti-money laundering);
- exercise the rights of the owner, for example the right to defense in court;
B) Only subject to your specific and distinct consent (articles 23 and 130 of the Privacy Code and article 7 of the GDPR), for the following Marketing Purposes:
- send via e-mail, mail and / or sms and / or telephone contacts, newsletters, commercial communications and / or advertising material on products or services offered by the Owner and recognition of the degree of satisfaction on the quality of services;
- send you via e-mail, post and / or sms and / or telephone contacts commercial and / or promotional communications of third parties.
Please note that if you are already subscribed to our mailing list, we may send you commercial communications relating to services and products of the Owner similar to those you have already used, subject to your disagreement (Article 130 paragraph 4 of the Privacy Code).
2. Processing methods
The processing of your personal data is carried out by means of the operations indicated in art. 4 of the Privacy Code and art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electronic and / or automated processing.
The Data Controller will process the personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the Service Finality relationship and no later than 2 years from the collection of data for the Marketing Purposes.
3. Access to data
Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):
- to employees and collaborators of the Data Controller, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators;
- to third party companies or other subjects (as an indication, credit institutes, professional firms, consultants, insurance companies for the provision of insurance services, platforms for the registration of contracts) that carry out outsourced activities on behalf of the Owner, in their quality of external data processors, for the only period necessary for data processing;
- to third-party companies that manage specific portals for advertising the owner's business.
4. Data communication
Without the need for express consent (pursuant to Article 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies (such as IVASS), Judicial Authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is mandatory by law for the accomplishment of said purposes. These subjects will process the data in their capacity as independent data controllers. Your information will not be disseminated.
5. Transfers and retention of data
Personal data is stored on servers located within the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.
6. Nature of the provision of data and refusal to grant them
The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we can not guarantee the services of the art. 2.A). The provision of data for the purposes referred to in art. 2.B) is optional. You can therefore decide not to give any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material concerning the Services offered by the Data Controller. However, you will continue to be entitled to the Services referred to in art. 2.A).
7. Rights of the interested party
In your capacity as an interested party, you have the rights set forth in art. 7 of the Privacy Code and art. 15 GDPR and precisely the rights of:
A obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
B obtain the indication:
i) of the origin of personal data;
ii) of the purposes and methods of the processing;
iii) the logic applied in case of treatment carried out with the aid of electronic instruments;
iiii) of the identifying details of the owner, the managers and the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR;
iiiii) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the territory of the State, managers or agents;
i) updating, rectification or, when interested, integration of data;
ii) cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
iii) the attestation that the operations referred to and ii have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right;
D oppose, in whole or in part, for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of collection; to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by and -mail and / or through traditional marketing methods by telephone and / or paper mail.
It should be noted that the right of opposition of the interested party for direct marketing purposes through automated methods extends to the traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition even partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication. Where applicable, it also has the rights referred to in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.
8. Methods of use of the rights and Holder, Manager and Distributors
You can exercise your rights at any time by sending:
- a registered letter a.r. to the headquarters of the owner.
- an e-mail to firstname.lastname@example.org.
The data controller is Dr. Andrea Grazioli.
The updated list of data processors and data processors is kept at the registered office of the Data Controller.