GDPR: Notice on the processing of data and privacy policy

NOTICE PROVIDED PURSUANT TO ARTICLES 13-14 OF GDPR 2016/679 (GENERAL DATA PROTECTION REGULATION)

Pursuant to Article 13 of GDPR 2016/679, we inform you that any personal data provided or otherwise collected as a result of a Contract Proposal, will be processed as follows:

  1. Purpose of processing
    1. for purposes strictly related to manage any contractual relationship (such as, for example, accounting and invoicing of services, recovery of any receivables, fulfilment of tax, accounting, administrative or legal requirements, management of complaints, etc.);
    2. for purposes related to the protection of credit risk, CUSTOMER identification and implementation of disclosures aimed at verifying the truthfulness of data provided and CUSTOMER solvency, including during the contractual relationship;
    3. management of services provided and products supplied as well as promotions and/or marketing activities.

      With reference to points a) b) and c) above, the provision of data and their processing is a necessary condition for the establishment of the contractual relationship and for its correct management; therefore, any refusal to provide such data and to give consent to their processing will not make a contractual relationship possible and result in the non-execution of contract requirements

    4. promotion and marketing - for commercial and promotional purposes, such as delivery of informational/promotional material and commercial communications, for promotional contacts, marketing or direct sales, and for market research on customer satisfaction and quality of services offered, through every means of communication (such as regular mail, email, telephone, text messages, etc.);
    5. profiling - for customer profiling purposes aimed at the development of products or proposals calibrated and studied according to the CUSTOMER'S habits and consumption patterns
    6. transfer - for the transfer of data to third parties considered as reliable partners, selected by Servetto S.r.l., to allow the latter to perform advertising and promotional activities;

    With reference to the purposes discussed in points d) e) and f) above, the authorization to process data is free and requires explicit and specific consent, with awareness that the provisions set forth in point e) are necessary to provide a complete service to the CUSTOMER.

  2. Mode of processing
    The processing of personal data, consisting of data registration, storage, organization, processing, extraction, use and communication, will be carried out on paper and with the support of electronic means, according to principles of correctness, transparency and lawfulness for the purposes indicated above, in such a way as to guarantee data security and confidentiality and protect the rights of the data subject.

    For the purposes referred to in points a) b) and c) above, personal data collected will be processed by the subjects indicated below and by Servetto S.r.l. employees, collaborators or staff who may need such data to carry out their professional activities, and, in compliance with the provisions in force, may be disclosed to outside companies for the fulfilment of tax and contractual obligations.

    They may also be disclosed to third parties belonging to the following categories:
    • banks where invoices are paid, for the management of receipts and payments;
    • credit recovery agencies;
    • third parties in charge of carrying out activities connected and instrumental to processing;
    • authorities, supervisory and control bodies, judicial bodies and public administrations, for the fulfilment of regulatory requirements.

      Only in cases when data concern an entrepreneurial or professional activity, such data can be shared with subjects who carry out database management activities related to credit risk, solvency and timely payments.

      If the CUSTOMER has given his/her consent to the processing for the purposes referred to in paragraph 1, letters d) (promotion and marketing) and e) (profiling), any personal data collected may also be disclosed:
    • to entities or subjects linked to Servetto S.r.l. by commercial agreements (such as, by way of example, subjects that conduct customer satisfaction research, and subjects linked to Servetto S.r.l. through collaboration agreements, etc.);
    • subjects who carry out promotional and marketing activities on behalf of Servetto S.r.l.

    All the subjects belonging to the above categories, pursuant to agreements with Servetto S.r.l., will act in the capacity of independent Data Controllers, as external Data Processors.

    If the CUSTOMER has given his/her consent to the processing for the purposes referred to in paragraph 1, letter f) (transfer to third parties), the subjects to whom data have been transferred will act independently, without any interference by Servetto S.r.l.

    The complete list of Data Processors is available at the Servetto S.r.l. offices. Any request for information sent by e-mail and containing personal data provided in an optional, explicit and voluntary manner, involves the automatic acquisition of the sender's address, which is necessary for the reply, as well as any other personal data included in the communication. The Data Controller is Servetto S.r.l., with registered office in Bovisio Masciago, via Brughetti, 32, represented by the Director and Legal representative.

    Without prejudice to any legal requirements for document storage, at the end of the service, supply of products or services or after any reply has been provided, personal data will be stored exclusively for historical or statistical purposes, in accordance with EU laws, regulations, and statutory provisions, as well as codes of ethics and good conduct signed in accordance with Article 40 of the GDPR, for a legally defined period of 10 years, unless otherwise specified, or, where processing is not subject to any law, for a period not exceeding five years. Beyond this period, personal data will be stored in anonymous form or destroyed.

  3. Exercise of the rights of the interested party
    In relation to the processing, a data subject may exercise his/her rights provided for by Art. 15 of DGPR no. 2016/679, including the right governing the portability of personal data, by contacting the Data Controller, also by email, at Esta dirección de correo electrónico está siendo protegida contra los robots de spam. Necesita tener JavaScript habilitado para poder verlo.

    In particular, the interested party may request confirmation of the existence of his/her personal data at Servetto S.r.l.; obtain data in an intelligible form; obtain information on the origin of data, as well as logic and purposes of processing; update, correct and supplement data, as well as delete, transform into anonymous form, and block any data processed in violation of the law. Finally, the interested party may revoke his/her consent, as referred to in paragraphs c), d) and (e), oppose data processing, for legitimate reasons, in whole or in part, itself, and file a complaint with the Control Authority (Privacy Authority).