European Regulation 2016/679 hereinafter “GDPR”
ELCOS S.r.l., with registered office in S.S. 234 km 58,250 – 26023 Grumello Cremonese (CR), Tax Code and VAT number 01084730199 as data controller (hereinafter called “Data Controller”) informs you in accordance with Article 13 Legislative Decree 30.6.2003 n. 196 (hereinafter called “Privacy Code”) and Article 13 of EU Regulation no. 2016/679 (hereinafter called “GDPR”) that your data will be processed in the following manner and for the following purposes.
Subject of the treatment
The Data Controller processes personal, identifying and non-sensitive data (in particular, name, surname, tax code, VAT number, email address, phone number – hereinafter referred to as “personal data” or even “data”) communicated by you upon request for information on the products or services offered by the Data Controller or completion of the contact form on our website.
Purposes of processing
The data will be processed for purposes related to the implementation of the following obligations, related to legislative or contractual obligations and for further purposes:
- Mandatory obligations by law in the fiscal and accounting fields;
- Management of customers and suppliers;
- Scheduling of activities;
- Archived invoicing of customers and suppliers;
- After-sales assistance;
- Disputes management;
- Credit recovery activities;
- Quality management;
- Detection of customer satisfaction;
- Communication of new services and / or products offered by the Data Controller.
The processing of functional data for the fulfillment of these obligations is necessary for a proper management of the relationship and their provision is mandatory to implement the purposes indicated above. Any incorrect or non-communication of one of the mandatory information, may cause the Data Controller’s inability to guarantee the adequacy of the processing itself.
Method of processing
The processing of your personal data is carried out by means of the operations indicated in article 4 of the Privacy Code and article 4 n. 2) GDPR and precisely:
– collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.
Your personal data is subjected to both paper and electronic processing.
The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the Service Purposes and for no more than 5 years from the collection of data for Marketing Purposes.
Each treatment is carried out in compliance with the methods set out in articles 6, 32 of the GDPR and through the adoption of the appropriate security measures.
The data will be processed only by personnel expressly authorized by the Data Controller and by external subjects expressly appointed by the Data Controller.
Third parties who carry out processing operations on behalf of the Data Controller are expressly appointed as External Managers for the relevant treatments.
Access to data
The data may be made accessible for the purposes referred to in the section Purposes of processing:
- to employees and collaborators of the Data Controller, in their capacity as persons in charge and/or internal managers of the processing and/or system administrators;
- to partners or suppliers of the Data Controller (for example, for activities of technical management of services, for the storage of personal data, etc.) or to third parties (for example, providers for the management and maintenance of the website, suppliers, credit institutions, professional studios, etc.) that carry out outsourcing activities on behalf of the Data Controller, in their capacity as external managers of the treatment.
Communication to third parties
The data will be communicated exclusively to the competent subjects for the fulfilment of the services necessary for correct management of the relationship, with guarantee of protection of the rights of the interested party:
- Consultancy company in accounting, administrative and tax matters;
- IT structure management company (IT)
- Consultants, freelancers and also affiliates;
- Credit recovery companies;
- Banks and credit institutions;
- Other public and/or private entities for which the communication of data is mandatory or necessary in compliance with legal obligations or is in any case functional to the administration of the relationship;
Personal data will not be disclosed in any way.
Storage time of personal data.
Your data will be stored in our archives or by authorized Managers only for the time necessary for the purposes of treatment, subject to compliance with the storage times.
The management and storage of personal data will be carried out on servers located within the European Union of the Data Controller and/or third-party companies designated and duly appointed as Data Processors.
Currently the servers are located in Italy.
The data will not be transferred outside the European Union.
In any case, it is understood that the Data Controller, where necessary, will have the right to move the server location within Italy and/or to the European Union and/or to non-EU countries. In this case, the Data Controller hereby ensures that the transfer of data outside of the EU will take place in accordance with the applicable legal provisions, stipulating – if necessary – agreements that guarantee an adequate level of protection and/or adopting the standard contractual clauses provided by the European Commission.
Method of treatment
Personal data are processed using paper / IT tools for the time strictly necessary to achieve the purposes for which they were collected.
Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.
Rights of the interested party
In his capacity as an interested party, he has the rights set forth in article 7 of the Privacy Code and article 15 GDPR and precisely the rights of:
- obtain confirmation of the existence or not of personal data concerning them, even if not yet registered, and their communication in an intelligible form;
- obtain the indication:
– of the origin of personal data;
– of the purposes and methods of processing;
– of the logic applied in case of treatment carried out with the aid of electronic instruments;
– of the identification details of the Data Controller, the managers and the designated representative pursuant to article 5, paragraph 2 of the Privacy Code and article 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 it in their capacity as designated representative in the territory of the State, managers or agents;
- the updating, rectification or, when there is interest, the integration of data;
- the cancellation, transformation into anonymous form or the blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
- the attestation that the operations referred to in subparagraphs a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which such fulfilment is revealed impossible or involves a use of means manifestly disproportionate to the protected right;
oppose, in whole or in part:
- for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;
- to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator through email and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right to object even only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.
Where applicable, the interested party also has the rights set forth in articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.
How to exercise rights
The interested party may at any time exercise the rights:
by e-mail, at the address: firstname.lastname@example.org
by fax: (+39) 0372.7233220
by registered letter at the following address: S.S. 234 km 58.250 – 26023 Grumello Cremonese (CR)