POLICY AND CONSENT PURSUANT TO ARTICLE 13 OF LEGISLATIVE DECREE 196/03 AND EU REGULATION 679/2016
Objective of Processing
The data controller shall process the identifying personal data (e.g. name, surname, company name, address, telephone number, e-mail – hereinafter “data”) provided by you in the contact form and for all other possible services you requested to the data controller. Health and criminal law data shall not be processed.
Purpose of Processing
The abovementioned data shall be processed in the context of the normal activity of the company according to the following purposes:
a- Purposes strictly connected with and instrumental to the management of customer relations (e.g. acquisition of information prior to the conclusion of a contract, execution of operations based on obligations deriving from contracts concluded with customers, etc.).
b- Purposes deriving from legal obligations, regulations, community legislation and provisions issued by authorities legitimated by the law or by supervisory and control bodies.
c- Purposes of accounting obligations (invoicing, compulsory accounting entries and records), tax and fiscal obligations.
Methods of Data Processing
In relation to the aforementioned purposes, personal data shall be processed by manual or automated means using a logic strictly related to the purposes and, in any case, in such a way as to guarantee the security and confidentiality of the data, as provided for and regulated by Annex B “Technical Regulations” and by Articles 31 to 36 of the Personal Data Protection Code (Legislative Decree no. 196 of 30 June 2003, no. 196 – hereinafter the Code) and always in compliance with Article 11 of the Code.
Your consent is mandatory for the processing and communication relating to the purposes of point a-, as required for the execution of contractual and pre-contractual obligations, and of point b-, c-, as required by law. Therefore, any refusal to provide them or to authorize their subsequent processing may result in the undersigned company’s impossibility to proceed with the contractual relations in question.
Categories of Recipients
Within the company, only employees in charge of processing your personal data, as well as individuals assigned by the company in their capacity as data processors and/or internal controllers and/or system administrators, may become aware of your personal data;
The data shall be communicated or disclosed to third parties, in Italy and abroad, exclusively for the necessary contractual obligations or legal requirements. Furthermore, if necessary, the data may be disclosed to agents, credit institutions for the management of collections and payments and to law firms for credit recovery. The data shall be processed for the duration of the contractual relationship and subsequently for the fulfilment of any legal obligation as well as for future commercial purposes.
Compulsory or Optional Consent to pursue the Purposes of Personal Data Processing
In order to send the requested information (by email or telephone) F.LLI POLI SRL must acquire in advance a specific, separate, express, documented and optional consent. Consequently, where the data subject decides to give their specific consents requested in the contact form, they must be informed in advance and aware that the purposes of the processing are of a specific informative, promotional and marketing nature in the broadest sense. To ensure absolute transparency, F.LLI POLI SRL shall therefore inform individuals agreeing to the data processing about the consequences of their consent to collect data, i.e. sending the information requested by the user as well as sending newsletters on similar products (which in any case has an informative and promotional nature pursuant to Articles 23 and 130 of the Privacy Code). In any case, even where the data subject has given their consent and authorised F.LLI POLI SRL to send emails or to contact them by telephone, they shall have the right to withdraw it at any time simply by notifying at firstname.lastname@example.org. Upon receipt of this opt-out request, F.LLI POLI SRL shall promptly remove and erase the data from the company database.
Third Party Personal Data provided by the Data Subject
The user acknowledges that any data entered in the contact form concerning any third party other than the data subject represents a processing of personal data for which the user acts as independent owner, assuming all the obligations and responsibilities provided for by the Privacy Regulation. In this sense, the user assures F.LLI POLI SRL that any third party data provided by the user (consequently processed as if the third party had submitted informed consent to the processing, where mandatory) have been acquired by the user in full compliance with the Privacy Code and the Regulation. On this point, the user confers the widest possible indemnity with respect to any dispute, claim, request for compensation for damage caused by the data processing, etc. that may be received by F.LLI POLI SRL from any interested third party due to the provision of the data submitted by the user in violation of the relevant rules on the protection of personal data.
Rights of the Data Subject
The data subject shall have the right of exercising specific rights, such as the modification and erasure of stored personal data.
1. The data subject shall have the right to obtain confirmation of the existence or not of personal data concerning them, even if not yet recorded, and its communication in an intelligible form.
2. The data subject shall have the right to obtain the following information:
a) the origin of personal data;
b) purposes and modalities of data processing;
c) the logic applied in the case of automated data processing;
d) the identity of the data controller, data processors and the representative designated pursuant to Article 5 (2);
e) the individuals or categories of individuals who may receive your personal data and who may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
3. The data subject shall have the following rights:
a) to have the data updated, rectified or, where interested therein, completed;
b) to obtain the erasure, anonymization or blocking of data processed in breach of the law, including data whose retention is not necessary for the purposes for which the data were collected or subsequently processed;
c) to obtain the statement that the actions as per letters a) and b) have been notified, as also related to their contents, to the data recipients, unless this requirement proves impossible or involves a clearly disproportionate effort compared with the right to be protected.
4. The data object shall have the right to object totally or partially:
a) for legitimate reasons, to their personal data processing, even if pertinent to the purpose of collection;
b) to the processing of their personal data, where it takes place for sending advertising materials or direct selling or else for carrying out market or commercial communication surveys.
Data Controller and Data Processor
The data controller and data processor is F.LLI POLI SRL, in the person of its legal representative with registered office in Via del Fabbri, 26 – 36042 Breganze (Vicenza) – C.F. and P.IVA 01960170247, enrolled in the Register of Companies of Vicenza, R.E.A. n. 196730, which you can contact via email email@example.com or all matters concerning the processing of your data, in particular for the exercise of the right referred to in Article 7 of Legislative Decree no. 196/2003
The data shall not be transferred abroad and shall be retained for a duration equal to the associative relationship or until you unsubscribe from the newsletter.
To communicate directly and effectively to F.LLI POLI SRL you can use the following contact details, including the email address: Telephone +39 0445 300189 – Fax +39 0445 879134 – email firstname.lastname@example.org – PEC email@example.com.
Users may apply to the Data Controller to assert their rights (access, rectification, erasure, objection, updating) as provided for in Article 7 of the Privacy Code.
The updated list of data processors is available at F.LLI POLI SRL.
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