San Donato Milanese 25 May 2018
RE: Information pursuant to art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council concerning the protection of individuals with regard to the processing of personal data, as well as the free movement of such data
Dear customer / supplier
In compliance with the obligations under the Regulation (referred to in the short “Regulations”), we inform you that the undersigned will submits and process the personal data that concerns you or the third parties communicated.
By virtue of the aforementioned treatment performed by us, we wish to provide you with the following information.
- TYPES OF DATA COLLECTED AND TREATED
The writer will gather only personal data that identify your company or your internal referents (or external parties that have authorized you to trasmit the data itself). The data referred to in art. 9, belonging to particular categories of data, and those referred to in art. 10, personal data relating to criminal convictions and offenses, of the Regulations won’t be treated.
- IDENTITY AND CONTACT DETAILS OF THE HOLDER AND HIS REPRESENTATIVE
The holder of the treatment is the undersigned company, with registered office in San Donato Milanese, Via XXV April 21.
The person in charge is the legal representative Mr. Alberto Maggioni domiciled for the office at the office indicated above.
- CONTACT DATA OF THE MANAGER IN CHARGE OF DATA’S PROTECTION
The analysis of the treatments carried out excludes the applicability of the art. 37 of the Regulations in relation to the non-public nature of the writer, the activity (main and ancillary) carried out by the writer, the absence of regular monitoring of the interested parties on a large scale.
- FINALITIES OF THE TREATMENT TO WHICH PERSONAL DATA ARE INTENDED AS WELL AS THE LEGAL BASIS OF TREATMENT
The processing of the data referred to in point 1 is exclusively directed to the achievement of the following purposes, whose regulations also constitute the legal basis of the processing itself (in particular the points a and b):
- a) for preliminary and / or contextual needs and for the execution of the obligations deriving from the contract with you;
- b) to comply with any type of obligation under applicable laws or regulations;
- c) for operational and management needs related to the management of sales or purchase orders.
The processing is also performed with the aid of electronic or automated means and is carried out in such a way as to guarantee the security and confidentiality of the data.
- LEGITIMATE INTERESTS PERFORMED BY THE HOLDER OF THE TREATMENT
They constitute legitimate interests of the Owner, who can proceed even without the consent of the interested party:
- those indicated in the preceding paragraph;
- specific procedures for debt collection or judicial protection;
- The prevention of fraud and crime.
- RECIPIENTS OF PERSONAL DATA
The personal data referred to in point 1 collected for the achievement of the purposes indicated in point 4, may be communicated and / or disseminated, as per their specific competence, to public and private subjects, natural and / or legal persons and having commercial purposes (eg communication of the name of the contact person to another person interested in the business practice) and / or management of information systems (eg maintenance of our information systems), including external parties that perform specific tasks on behalf of the writer (eg . business consultant).
Within the limits strictly relevant to the execution of obligations arising from relations with you, the data may be communicated to subjects located in the territory of the European Union (eg communication of the name of the contact person to another person interested in commercial
- THE TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY OR TO AN INTERNATIONAL ORGANIZATION
The personal data referred to in point 4, are not transferred to third countries because is necessary to refer to the existence of an adequacy decision by the Commission or, in the case of transfers referred to in articles 46, 47, 49 paragraph 2 of the Rules, to report an opportune choice to obtain a copy of such data or the place where they have been made available.
- PERIOD OF CONSERVATION OF PERSONAL DATA
The personal data referred to in point 1 reported for the achievement of the purposes indicated in point 4 considered stored at the end of the intercurrent relationship and / or that envisaged for the conservation of accounting records.
- EXISTENCE OF AN AUTOMATIC DECISION-MAKING PROCESS, INCLUDING THE PROFILING
The processing of personal data referred to in point 1 doesn’t provide for “profiling” as “any form of automated processing of personal data consisting of the use of such data to evaluate certain personal aspects relating to a natural person, in particular to analyze or provide for aspects concerning the professional performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movement of said physical person “(see Article 4 of the Rules).
- RIGHT’S OF THE INTERESTED PARTY
You can contact the data controller to assert your rights as provided by the articles. 15 (access), 16 (correction), 17 (cancellation), 18 (limitation), 20 (portability), 21 (opposition), to which reference is made in full.
- The interested party has the right to obtain confirmation of the existence or not of personal data concerning him / her, even if not yet registered, and a copy.
- The interested party has the right to obtain the indication:
- of the origin of personal data;
- of the purposes and methods of the processing;
- of the logic applied in case of treatment carried out with the aid of electronic instruments;
- of the identification details of the data controller, data processors and data processors;
- Of the subjects or categories of subjects to whom the personal data may be communicated.
- The interested party has the right to obtain:
- updating, rectification or, when interested, integration of data, limitation of data;
- the 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;
- data portability (only on the basis of a contract entered into with the data subject and does not apply to data whose processing is based on the legitimate interest of the owner);
- the attestation that the operations referred to in letters a) and b) have been brought to the attention, including as regards their content, of those to whom the data have been communicated or disseminated, except in the case where this fulfilment is it proves impossible or involves a use of means manifestly disproportionate to the protected right;
- the limitation of treatment;
- The interested party has the right to object, in whole or in part:
- on legitimate grounds, to the processing of personal data concerning him / her, even though they are relevant 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.
- The interested party has the right to present a complaint with a supervisory authority.
- DATA CONFERENCE AND CONSEQUENCES OF ANY REFUSAL TO RESPOND
The provision of data is:
(a) Mandatory for the achievement of the purposes connected to the obligations established by laws or other binding regulations;
(b) Necessary for the correct establishment or continuation of the relationship with you.
A possible refusal to provide the above data, although certainly legitimate, could compromise the smooth running of the relationship.
We remind you that, without prejudice to what is indicated above in points 4, 5 and 11 of this information, pursuant to art. 7 of the Regulation, the processing of your data is only permitted with the consent expressed by declaration or positive action unequivocal, but not necessarily in written form, however, for the particular categories of data and personal data relating to criminal convictions and crimes of to the articles 9 and 10 of the Rules.
The voluntariness whit which you / your data has been provided or you have made them available to the same subjects who have referred to them constitutes in itself an unequivocal positive action; In any case, we ask you to inform us of any objection to the processing referred to in point 10 of the information and whose absence will be interpreted by us as an expression of consent to the continuation of the treatment.