GAMBINI S.p.A . Variante Via Romana, 9 Badia Pozzeveri 55011 Altopascio (LU) (below, “Controller”) as the Data Controller, informs that in accordance with article 13 EU Regulation n. 2016/679 (below, “GDPR”) and D.Lgs. 101/2018 (Italian law). Your personal data will be processed according to the following modalities and for the following purposes:
1. Type of data processing:
The Controller processes personal data, identifying and not sensitive (specifically name, last name, social security number, VAT registration number, email, telephone number – below “Personal Data” or “Data”) reported by you in the registration stage on the occasion of working relationships, contracts or other exchanges between you and the Controller.
2. Intended use of personal data:
Your personal data will be processed A) without your express consent (art. 6 lett. b), e) GDPR), with the following purpose of service: conclude contracts for the Controller services, comply with the pre-contractual, contractual and fiscal obligations arising from relationships with you; comply with the obligations set out in the law, in a Regulation, in a Community legislation or in an Authority’s order (e.g. on the anty-money-laundering ‘AML’); exercise the right of the Controller, e.g. the right of defense in court.
B) only with your prior distinct and separate consent (art. 7 GDPR) with the following Marketing purposes: send you by e mail, mail and/or sms and/or telephone contact, newsletter, commercial communications, advertising material on products and services offered by the Controller and detection of the level of satisfaction for the services quality forms; send you by e-mail, mail and/or sms and/or telephone contact commercial communications and/or advertising material on third parties (e.g. business partners, insurance companies or other companies of the Group).
We note that, if you are already our customer, we may send you commercial communications on services and products of the Controller similar to those you already received, unless your disagreement.
3. Modalities of data processing
Your data are processed by means of the operations indicated in article 4 n. 2) GDPR and precisely: collection, registration, organization, retention, consultation, processing, alteration, selection, mining, comparison, use, interconnection, blocking, reporting, deletion, destruction of data.
Your data are processed both with paper and electronic and/or automated treatment.
The controller will process your data for the time required to comply with the above-mentioned purposes and no later than 10 years after the termination of the contract for the service purposes and no later than 2 years after the collection for Marketing purposes.
The legitimate interests pursued by the Controller in the data processing shall respect and perform the contractual obligations between the parties. Under Article 6 the lawfulness of the data processing is based on the consent expressed by the involved subject, in written form.
3. Data Access
Your data will be made accessible for the purpose at point 2.A) and 2.B):
– to employees and collaborators of the Controller or to Companies of the GAMBINI group to which the Controller belongs, as employees in charge and/or internal processors and/or system administrators.
– to Companies of the GAMBINI group to which the Controller belongs (e.g. for support activities in feasibility studies on projects for the customer, for project’s technical management activities, for data storage, etc.) or to third parties (e.g. web site operation and maintenance providers, suppliers, credit institutions, professional firms, etc.) who pursue outsourcing activities for the Controller, as external Data Processors.
5. Data Reporting
Without your express consent, (art. 6 lett. b) and c) GDPR), the Controller may report your data for the purposes at point 2.A) to Supervisory Authorities, Judicial Authorities, as well as to all the others to which the communication is mandatory by law for the performance of the said purposes. Your data will not be widespread.
6. Data transfer
The management and conservation of personal data will take place on servers hosted in the European Union, of the Controller and/or of third companies nominated and duly appointed as Data Processors. Your data will not be transferred outside the European Union. However it is understood that the Controller, when necessary, will have the right to change the servers hosting in Italy and/or in the EU and/or in extra-EU countries. In that case, the Controller ensures from now that the extra-EU data transfer will take place in accordance with applicable requirements, by entering into, if necessary, agreements which ensure an adequate level of protection and/or by adopting the standard contract terms envisaged by the European Commission.
7. Data contribution and consequences of a refusal to reply
It is mandatory to provide your data for the purposes at point 2.A). In absence of your data we will not be able to guarantee neither the registration on the web site nor the services at point 2.A).
It is optional instead to provide your data for the purposes at point 2.B). You can decide to not provide your data or to deny subsequently the possibility to process the already provided data: in that case, you will not receive newsletters, commercial communications advertising material on Services offered by the Controller. In any case, you will continue to have the right for Services as per point 2.A)
8. Rights of the data subject
In your capacity of Subject, you have the rights provided for in art. 15 GDPR, and precisely the rights to:
i. obtain confirmation as to whether or not data relating to you are being processed, even if not stored yet, and their communication in an intelligible form;
ii. Obtain indication a) on the data source; b) on the processing purposes and modalities; c) on the approach applied in case of processing by electronic means; d) on the contact details of the Controller, the processors and of the designated Representative as provided in art. 3, comma 1, GDPR; e) on the subjects or categories of subjects to which your data can be communicated or who may become aware of them, as designated representative within the Nation’s territory, as officers or as appointed;
iii. Obtain: a) the update, rectification and, when you have an interest to, integration of your data; b) the deletion, transformation in an anonymous form or blocking of data processing in breach of the law, Including those that do not require the storage for the purposes that the data were collected for or later processed; c) documentary evidence that operations at points a) and b) have been made aware, also regarding their content, to the ones to whom data have been communicated or spread, except when this requirement proves to be impossible or requires disproportionate large measures of deployment compared to the protected right;
iv. oppose in full or in part a) for legitimate reasons the data processing of data regarding your person, although relevant to the collection purpose. b) your data processing for the purposes of sending you advertising material or of direct selling or of market research or of commercial communication, by using automated calling systems without the intervention of an operator, by sending emails and/or by traditional marketing modalities by telephone or by mail.
Please note that the right to object of the subject, exposed to point b) for direct marketing purposes by using automated systems extends to the traditional ones and that it is and remains the possibility for the subject to exercise the right to object even partially. Therefore, the subject may decide to receive communications only by traditional modalities or only automated communications or neither of those types of communication.
If applicable, the subject has also the rights as for articles 16-21 GDPR (Right of rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to complain with the Guarantor Authority.
9. Procedure for the exercise of your rights
You will at all times be able to exercise your rights by sending:
- a registered letter with return receipt to GAMBINI S.p.A. Variante Via Romana, 9 Badia Pozzeveri 55011 Altopascio (LU)
- an e-mail to firstname.lastname@example.org
Without any prejudice to any other administrative or judicial review, we inform you that whether you believe that your data processing infringes this regulation, you have the right to lodge a complaint with the Supervisory Authority (Data Guarantor), particularly in the nation where you are habitually resident, work or in the nation where the alleged breach took place.
11. Controller, processor and officers
The processing Controller is GAMBINI S.p.a.
The updated list of data processors and persons in charge of processing is kept at the headquarters of the Data Controller.
12. Amendments to this informative report
This informative report may be subject to amendments. It is therefore recommended to check this informative report on a regular basis, as well as to refer to the latest version.