Information ex art. 13 EU Regulation 2016/679
Legal references: – Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, hereinafter “EU Regulation”) – Legislative Decree no. 196 of 30 June 2003 (hereinafter “Privacy Code”), as amended by Legislative Decree no. 101 of 10 August 2018 |
Adiacent S.r.L., subsidiary company of Var Group S.p.A. pursuant to art. 2359 of the Italian Civil Code (hereinafter also “the Company”), with registered office in via Piovola 138, Empoli (FI), VAT no. 04230230486, wishes to inform the data subjects of the terms and conditions applied by the Company to the processing operations carried out on personal data regarding the contact form of the website.
The Company acts as “Data Controller”, meaning “the natural or legal person, public authority, service or other body that, individually or together with others, determines the purposes and means of the processing of personal data”. In concrete terms, the processing of personal data may be carried out by persons specifically authorized to carry out processing operations on data subjects’ personal data and, for this purpose, duly instructed by the Company. In application of the regulations on the processing of personal data, users who consult and use the Company’s website assume the quality of “data subject”, meaning the natural persons to whom the personal data being processed refers.
- Purpose and legal basis for the processing of personal data
Personal data processed by the Company are directly provided by the website users, by filling in the appropriate contact form, in order to request information or receive assistance. In this case, the processing is based on the execution of specific requests and the fulfillment of pre-contractual measures; therefore, the express consent of the users is not necessary.
Basing upon the specific and optional consent given by the data subjects, personal data may be processed by the Company in order to send commercial and promotional communications regarding Company’s services and products, as well as information messages regarding the Company’s institutional activities.
In addition, basing upon the specific and optional consent given by data subjects, personal data may be communicated to the companies belonging to Var Group S.p.A. group of undertakings, in order to allow them to transmit commercial and promotional communications related to services and products of the above mentioned companies, as well as information messages related to the institutional activities of the same companies.
Finally, basing upon the specific and optional consent provided by the data subjects, personal data may be communicated to third party companies, belonging to the ATECO J62, J63 and M70 product categories, concerning information technology and business consulting products and services.
Please note that data subjects may revoke, at any time, the consent already given to the processing of personal data; the revocation of consent does not affect the lawfulness of the processing carried out before the revocation.
It is possible to revoke the consent already given to the Company, by writing to the following email address: dpo@sesa.it
- Processing methods and data retention of personal data processing
Processing of personal data may be carried out by persons specifically authorized to carry out processing operations on users’ personal data and, for this purpose, duly instructed by the Company. Processing may be carried out through the use of computer, telematic or even paper instruments and supports in compliance with the provisions aimed at guaranteeing the security and confidentiality of personal data, as well as, among other things, the accuracy, updating and relevance of the personal data with respect to the stated purposes.
Personal data collected will be stored in electronic and/or paper archives at the Company’s registered office or operating offices. Personal data provided by data subjects will be stored in a form that allows their identification for a period of time not exceeding that necessary to achieve the purposes, as identified in point 1 of this policy, for which the data are collected and processed.
In any case, the determination of the data retention period is made in compliance with the terms allowed by applicable laws. In relation to marketing and commercial promotion purposes, in case of expression of the voluntary consent, personal data collected will be kept for the time strictly necessary for the management of the purposes indicated above, according to criteria based on compliance with the current regulations and correctness as well as on the balance between the legitimate interests of the Company and the rights and freedoms of data subjects. Consequently, in the absence of specific rules that provide for different retention periods, the Company will take care to use the personal data for the above-mentioned marketing and commercial promotion purposes for an appropriate period.
In any case, the Company will take every care to avoid the use of personal data for an indefinite period of time, proceeding periodically to verify in an appropriate manner the effective persistence of the users’ interest in having the processing carried out for marketing and commercial promotion purposes.
- Nature of the provision of personal data
The provision of personal data is optional but necessary, in order to respond to requests for information or assistance made by data subjects. In particular, the non-filling of the fields in the contact form precludes the submission of requests for information or assistance to the Company. In this case the consent to the processing of personal data is ” mandatory” as instrumental to obtain response to requests for information or assistance made to the Company. In all other cases referred to in point 1 of this information notice, the processing is based on the provision of specific and optional consent; as already stated, consent is always revocable.
- Recipients of personal data
Data subjects’ personal data may be communicated, in Italy or abroad, within the territory of the European Union (EU) or the European Economic Area (EEA), in compliance with a legal obligation, EU regulation or legislation; in detail, personal data may be communicated to public authorities and public administrations for the purpose of executing institutional functions.
Moreover, without the data subjects’ consent, personal data may be communicated to Var Group S.p.A., the parent company pursuant to art. 2359 of the Italian Civil Code, as well as to companies belonging to the Var Group S.p.A. business group, for the sole purpose of responding to requests for information or assistance addressed to the Company.
Prior to specific and optional consent provided by data subjects, personal data may be communicated to companies belonging to the Var Group S.p.A. entrepreneurial group, in order to allow the latter to transmit commercial and promotional communications relating to services and products of the aforementioned companies, as well as information messages relating to the institutional activities of the same companies.
Finally, subject to specific and optional consent provided by users, personal data may be communicated to the companies belonging to Var Group S.p.A. group of undertakings, in order to allow them to transmit commercial and promotional communications related to services and products of the above mentioned companies, as well as information messages related to the institutional activities of the same companies.
Personal data will not be transferred outside the territory of the European Union (EU) or the European Economic Area (EEA). Personal data will not be disclosed or disclosed to the public or to an indefinite number of persons.
- Rights under Articles 15, 16, 17, 17, 18, 20 and 21 of EU Regulation 2016/679
Users, as data subjects, may exercise the rights of access to personal data provided for in Article 15 of the EU Regulation and the rights provided for in Articles 16, 17, 18, 20 and 21 of the same Regulation regarding the rectification, cancellation, limitation of the processing of personal data, data portability, where applicable, and opposition to the processing of personal data. The aforesaid rights can be exercised by a written communication to the following address: dpo@sesa.it. If the Company does not provide feedback within the time limits provided for by the legislation or the response to the exercise of rights is not suitable, users may lodge a complaint to the Italian Data Protection Authority using the following contact information: Italian Data Protection Authority, Fax: (+39) 06.69677.3785 Telephone: (+39) 06.69677.1 E-mail: garante@gpdp.it
- Data protection Officer
SeSa S.p.A., company acting as holding company in SeSa group of undertakings to which Adiacent S.r.L. belongs in consideration of the control of Var Group S.p.A. pursuant to art. 2359 of the Italian Civil Code., has appointed, after assessing the expert knowledge of data protection law, a Data Protection Officer. The Data Protection Officer supervises compliance with data protection regulations and provides the necessary advice. In addition, where necessary, the Data Protection Officer cooperates with the Italian Data Protection Authority. Here are the contact details:
E-mail: dpo@sesa.it