Privacy Policy

COMMERCIAL PARTNERS

Pursuant to Article 13 of EU Regulation 2016/679 of 27/04/2016, hereinafter referred to as GDPR (General Data Protection Regulation), Massimiliano Simone, with registered office at Via Niccolò Macchiavelli, 5 – 10045 Possiasco (TO), Italy, in his capacity as Data Controller of personal data, hereby informs you of the following:

Data Controller and Data Processor

The Data Controller is Massimiliano Simone, with registered office at Via Niccolò Macchiavelli, 5 – 10045 Possiasco (TO), Italy.

Purposes of Processing

The personal data provided by you will be processed exclusively for the following purposes:

1. Entering into and executing the contract, as well as all related activities, including but not limited to: invoicing, credit protection, administrative, managerial, organizational, and operational services necessary for the performance of the contract;

2. Fulfillment of obligations provided for by law, regulations, applicable legislation, and other provisions issued by authorities empowered by law and by supervisory and control bodies.

The processing of personal data for the aforementioned purposes does not require your express consent (Art. 24, letters a) and b) of the Italian Privacy Code and Art. 6, letters b) and e) of the GDPR).

Mandatory Nature of Data Provision and Consequences of Any Refusal

The data requested for the purposes referred to in letters a) and b) above must mandatory be provided for the fulfillment of legal obligations and/or for the conclusion and execution of the contractual relationship and the provision of the requested services. Therefore, they cannot be subject to your consent, as any refusal to provide such data would make it impossible to establish and manage the relationship itself and to provide the requested service.

Methods of Data Processing

The processing of personal data is carried out by means of the operations indicated in Art. 4, no. 2) of the GDPR, for the purposes stated above, both on paper and computer media, through electronic or otherwise automated tools, in compliance with current legislation, particularly regarding confidentiality and security, and in accordance with the principles of fairness, lawfulness, transparency, and the protection of the Customer's rights. The processing is carried out directly by the controller's organization, by its processors, and/or authorized persons.

Communication and Disclosure

Your personal data may be communicated, within the strict limits relevant to the obligations, tasks, and purposes mentioned above and in compliance with current applicable regulations, to the following categories of subjects:

1. Subjects to whom such communication must be made in order to fulfill or to require the fulfillment of specific obligations provided for by laws, regulations, and/or EU legislation;

2. Companies belonging to the Controller's Group, or parent, subsidiary, or associated companies pursuant to Art. 2359 of the Italian Civil Code, acting as data processors or for administrative-accounting purposes (purposes connected with the performance of internal organizational, administrative, financial, and accounting activities, specifically functional to the fulfillment of contractual and pre-contractual obligations);

3. External natural and/or legal persons providing services instrumental to the Controller's activities for the purposes referred to in point 1 above (e.g., call centers, suppliers, consultants, companies, entities, professional firms). These subjects will operate as data processors.

Personal data will not be disclosed to the public in any way.

Retention Period of Personal Data

Personal data will be stored for the entire duration of the contract entered into with the Controller. Upon its termination, the data will be retained for the period required by law for the preservation of administrative documents, after which they will be deleted.

Transfer of Data

Personal data are stored on servers located within the European Union. In any case, it is understood that the Controller, should it become necessary, shall have the right to move the servers even outside the EU. In such a case, the Controller ensures as of now that the transfer of data outside the EU will take place in accordance with the applicable legal provisions, subject to entering into the standard contractual clauses provided by the European Commission.

Rights of the Data Subject

In your capacity as a data subject, you have the rights set forth in Articles 15 – 22 of the GDPR, and precisely the rights to:

1. Obtain confirmation as to whether or not personal data concerning you exist, even if not yet recorded, and their communication in an intelligible form;

2. Obtain information regarding: a) the source of the personal data; b) the purposes and methods of the processing; c) the logic applied in the event of processing carried out with the aid of electronic tools; d) the identification details of the controller, processors, and the designated representative pursuant to Art. 3, paragraph 1, GDPR; e) 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 in the territory of the State, processors, or authorized persons;

3. Obtain: a) the updating, rectification or, when interested therein, integration of the data; b) the erasure, anonymization, or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which they were collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their content, to the entities to whom the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared to the right that is to be protected;

4. Object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning you, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct selling or for the performance of market research or commercial communication, through the use of automated calling systems without the intervention of an operator, via email and/or through traditional marketing methods by telephone and/or paper mail. Please note that the data subject's right to object, as set out in point b) above, for direct marketing purposes via automated methods extends to traditional ones, and that the data subject retains the possibility to exercise the right to object even only in part. Therefore, the data subject may decide to receive only communications via traditional methods, only automated communications, or neither of the two types of communication. Where applicable, you also have the rights referred to in Articles 16-21 of the GDPR (Right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Supervisory Authority (Garante).

To exercise the rights referred to in Articles 15 – 22 of the GDPR or for questions or information regarding the processing of your data and the security measures adopted, you may send a request to our company at the following address:

Massimiliano Simone

Via Niccolò Macchiavelli, 5 – 10045 Possiasco (TO), Italy

E-mail: info@elysionostuni.it