We, the undersigned Companies, would like to inform you that we need to process some information about you which is deemed to be personal data, pursuant to article 13 and article 14 of EU Regulation 679/2016, in order to develop the contractual relationship, we have established with you.
The Companies “Adatto Logistics Srl” with its registered offices in Via dei Zattieri 21/D – 32014 Ponte Nelle Alpi (BL-Italy) Tel. 0289038785 mail: firstname.lastname@example.org, “Italiagroup Corporate Srl with its registered offices in Via dei Zattieri 21/D – 32014 Ponte Nelle Alpi (BL-Italy) Tel. 0289038785 mail: email@example.com, “WDF Company Srl” with its registered offices in Via dei Zattieri 21/D – 32014 Ponte Nelle Alpi (BL Italy) Tel. 0289038785 mail: firstname.lastname@example.org, “Metropolisgroup di Dal Farra Walter” with its registered offices in Via dei Zattieri 21/D – 32014 Ponte Nelle Alpi (BL Italy) Tel. 0289038785 mail email@example.com are a Joint Controllers. This means we are the companies which will determine the purpose and means of the processing of your personal data.
SCOPE OF PROCESSING
We shall use and process your personal data:
a) To comply with all legal (administration, bookkeeping and tax) and contractual obligations.
b) Furthermore, if you give us your consent, our Company will use your personal data to deliver advertising, promotional and information material relating to the products and services which our Company can provide you with as well as to any further business initiatives that we might promote.
LAWFUL BASIS FOR PROCESSING
The lawful bases for processing are:
⦁ legal obligation with regard to regulations such as tax regulations;
⦁ the contract with reference to the processing of personal data connected with obligations under such a contract;
⦁ legitimate interests A legitimate interest of the Joint Controllers in the case of sharing your personal data with other companies in the group.
CONSEQUENCES OF FAILURE TO COMMUNICATE PERSONAL DATA
As regards personal data relating to the execution of the contract which you are a party to or related to compliance with a regulatory obligation (such as bookkeeping and tax obligations), failure to communicate your personal data will prevent us from drawing up the contract itself.
CATEGORIES OF PERSONAL DATA
Specifically, we wish to inform you that we could process the following categories of personal data:
⦁ Personal details
⦁ Fiscal data
⦁ Contact details
⦁ Bank account details
⦁ Information about types of purchased and sold products
⦁ Information about any breach of contract
SUBJECTS WE WOULD LIKE TO SHARE YOUR PERSONAL DATA WITH
Your personal data shall be processed in a strictly confidential manner; specifically, we may have to share your personal data with the following subjects:
⦁ Public bodies (ex. Tax offices);
⦁ Agencies responsible for tax document processing;
⦁ Credit institutions;
⦁ Insurance companies and debt recovery companies.
For the same purposes, the employees of the aforesaid organizations who work in the accounting, administrative, commercial and marketing field will also be allowed to use your personal data.
PLACE OF PROCESSING
All processing will be performed within the European Economic Area (EEA). More specifically, processing will mostly take place at the Joint Controllers and will be carried out by the Joint Controllers itself. Subject to communications as provided for by the law and contractual obligations, the personal data collected may be transferred to non-EU countries. In such a case, the Joint Controllers shall ensure, where possible, that the regulations in force in the country of destination are in compliance with EU regulations. Otherwise, the Joint Controllers may transfer the personal information collected only when it is strictly necessary for the execution of the existing contract, pursuant to Art. 49 paragraph 1 letter b).
PARTIES RESPONSIBLE FOR PROCESSING
According to their competences, the following third parties may be responsible for data processing (included but not limited to): professionals or service providers in charge of company administration and management who act on behalf of our company.
If you want, we will provide you with the list of and information about third parties. You need only contact the aforementioned Joint Controllers.
MODE OF DATA PROCESSING
Data are processed both manually and by computerized modes, in accordance with the purposes heretofore and meeting privacy requirements as well as putting in place all appropriate security measures.
According to article 5 of EU GDPR 679/2016, we also assure you that your personal data shall be
⦁ processed lawfully, fairly and in a transparent manner;
⦁ collected for explicit and legitimate purposes;
⦁ further processed in a manner that is compatible with such purposes;
⦁ adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; accurate and, where necessary, kept up to date;
⦁ kept in a form that permits identification of data subjects;
⦁ processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organizational measures.
DATA RETENTION PERIOD
We will only retain your personal information for as long as necessary to fulfil the purposes for which your data are being processed and for a further period as required by current tax regulations.
Except what set out above, processing for marketing purposes will be performed until the Customer/Supplier exercises the right to withdraw their consent to this type of processing.
RIGHTS OF DATA SUBJECTS
Data subjects are entitled to exercise their rights pursuant to articles 15, 16, 17, 18, 20 21 of the aforesaid EU Regulation, and specifically:
⦁ the right of access, i.e. to know what personal data our company is processing;
⦁ the right to request that any errors and/or omissions be corrected;
⦁ the right to ask us to delete their personal data;
⦁ the right to restrict processing of personal data;
⦁ the right to data portability, that is the right to receive all the personal data concerning them and processed by our company in a structured, commonly used and machine readable format;
⦁ the right to object to the inclusion of all information.
In addition, data subjects shall have the right to lodge a complaint with a regulatory Authority.
Date of last update 15 November 2019