PURSUANT TO REGULATION (EU) 2016/679 ON THE PROTECTION OF PERSONAL DATA ("G.D.P.R.") AND REQUEST FOR CONSENT TO THE PROCESSING OF PERSONAL DATA
1. 1 INTRODUCTION
o 1.1 Dear Customer, in accordance with the obligations imposed by Regulation (EU) 679/2016 (General Regulation on data protection - so-called "G.D.P.R." TMB Europecom s.r.l. (henceforth, the "Company") intends to inform you about how your personal data, including those of a particular nature, are processed and request your consent should this be necessary and make you aware of your rights as well as the procedures for to be able to exercise them easily.
or 1.2 This information is also issued as a supplement to the previous one. Any further information relating to specific processing or information provided on behalf of third-party data controllers remains unaffected.
2. 2 DATA CONTROLLER AND CONTACT DATA
or 2.1 The data controller is TMB Europecom s.r.l., in the person of its legal representative pro tempore, Mr. CIRO ERCOLE, with registered office in Naples in Piazza Dei Martiri 58 email: firstname.lastname@example.org
3. 3 SOURCES OF COLLECTION OF PERSONAL DATA
or 3.1 The Company collects the personal data that concerns You directly from you, both in its own sales office and outside (for example at events or fairs: in this case the consent must be provided before the communication of the data itself) and also through remote communication techniques (for example through its own websites, for which reference should be made to the specific information published there; third-party sites and platforms; etc.). You can provide us with your personal data at the time of requesting information, during business negotiations, at the time of signing contracts or during the course of their performance, as well as at the time of admission / provision of services and / or services, however qualified or named.
or 3.2 If necessary, the Company accesses public registers, lists or databases (available to anyone, eg C.C.I.A.A., etc.). Furthermore, in view of the commercial supply, it reserves the right to verify the reliability and financial solvency of the Customer.
4. 4 METHOD OF TREATMENT
or 4.1 Your personal data is processed either manually, in paper format, or by electronic, computerized, telematic and / or automated means, with logic strictly related to the purposes indicated.
or 4.2 Your personal data is entered in our management systems and in a Customer Relationship Management system ("C.R.M.") in a "cloud" environment. In the presence of specific consents, the data entered in the C.R.M. they may also be processed for the purposes further specified below.
or 4.3 In any case, your personal data is protected by adequate technical and organizational measures, so as to guarantee the security and confidentiality of the same, in compliance with the regulations in force. The Company has implemented specific security measures to prevent the loss or destruction of data, unauthorized access, unauthorized processing or non-compliance with the purposes for which it was collected.
5. 5 PURPOSE OF THE TREATMENT AND LEGAL BASES
or 5.1 The Company processes personal data for multiple purposes, some of which require your specific and optional consent. To facilitate your understanding and ensure greater clarity, we have deemed it appropriate to explicitly distinguish the individual purposes, as better described below:
or) OPERATIONAL MANAGEMENT PURPOSE (PRIMARY PURPOSES): by this term we mean the performance of all those activities strictly functional to the fulfillment of your requests, both in the pre-contractual phase and to execute a specific contract of which you are a part, as well as for all the activities connected to them or instrumental, functionally linked to the Company's operations or to the protection of its rights. These purposes include all the activities necessary to provide you with the information, assistance, services, services requested or of your interest, which for greater clarity are listed by way of example and are not exhaustive: the management of the negotiations - phase pre; negotiation and conclusion of the contract; provision of services and / or services generally required; the fulfillment of administrative and accounting charges; payment management. We also believe that these activities are connected and instrumental, for example: the verification of internal quality through checks, controls and audits, including those of a third party; the performance of audits, including third parties, aimed at ensuring compliance with the current legislation on the processing of personal data; the fulfillment of legal, accounting, fiscal, administrative obligations deriving from law, regulation or legislation; credit recovery; credit risk protection; the protection of company assets; the protection of the Company's rights in the courts or in the most appropriate forums. The aforementioned treatments are lawful since they are necessary for the execution of a contract of which you are a party or for the execution of pre-contractual measures adopted on your request, to allow the Company to fulfill a legal obligation to which it is subject or, finally, for a his legitimate interest. As better explained in the following dedicated paragraph, the processing of any particular data is carried out by virtue of Your explicit consent and even such data may be used, where strictly necessary, for the protection of the Company's rights.
or b) after obtaining your consent, your data is processed for Marketing Purposes, ie for sending commercial and promotional communications, including the sending of related communications, services and accessories. Unless You show a different preference, this can be done both through Traditional Contact Modes, such as sending paper mail and phone calls, and through Automated Contact Mode and, therefore, through the use of automated call systems. , of call communication without the intervention of an operator or via e-mail, even periodically (Newsletter), fax, MMS (Multimedia Messaging Service) or SMS (Short Message Service) messages, instant messaging systems, chat , social networks or other types of computer platforms and tools.
or c) with your prior consent, your data is processed for the purpose of profiling, consisting in identifying preferences and consumption choices by processing personal data such as, for example
illustrative and not exhaustive: data relative to the possible registration to the company websites and the use of the same; services purchased; sustained spending level; active services; frequency of use. This allows the creation and definition of your profile, useful for processing market analyzes and statistics, even with data in aggregate form or once rendered anonymously; to improve services offered and make them more responsive to your needs; furthermore, subject to the specific consent as per point 5.1, lett. b) (Marketing Purpose), to direct our activity of sending communications of a promotional, advertising or commercial nature, customizing them, with the means indicated therein. This treatment will be carried out directly by the Company. Personal data will be processed both individually and in aggregate and may be enriched, compared, cross-referenced and / or integrated over time with further data in legitimate possession of the Company. We inform you that any manifestation of consent for the purpose of profiling referred to in this point necessarily involves the use of all the functions specifically provided for by the C.R.M., which otherwise will not be used.
6. 6 REVOCATION OF CONSENT
or 6.1 If you have given your consent to authorize a specific treatment, we inform you that you can revoke it at any time by contacting the Owner in the manner indicated in the following paragraph "Rights of the interested party". This revocation, in any case, does not affect the lawfulness of the processing based on the consent given before the revocation.
7. 7 DATA TRANSFER
or 7.1 The provision of your personal data is always left to your free will.
or 7.2 However, the provision of personal data for the Primary Purposes, if necessary also of a particular nature, is necessary and indispensable to allow the Company to fulfill your requests. Failure to provide personal data may, therefore, make it impossible for the Company to start pre-contractual negotiations / relationships, to establish contractual relations, to manage the post-contractual phase and / or, in any case, to provide you with services or required performance.
or 7.3 The provision of your personal data is, however, absolutely free and optional for the Marketing Purpose, the Purpose of Profiling and the Purpose of Customer Satisfaction. Any failure to provide your personal data for one or more of the aforementioned purposes will not have any consequence for you, if not the impossibility for the Company to carry out the above described.
8. 8 UNDERSTANDING OF DATA AND THEIR COMMUNICATION
or 8.1 Your personal data, if processed electronically, can be accessed from any location
or 8.2 Your personal data is processed by subjects specifically authorized or designated by the Data Controller within its structure (employees and collaborators, however named), due to the performance of the tasks and tasks assigned to each.
or 8.3 Your personal data may also be processed by other external parties operating on behalf of the Company by virtue of specific contractual obligations or, in any case, duly
authorized or appointed as data controllers. By way of example, where necessary your personal data may be processed by: computer, telematic and technological service providers, including hosting and maintenance services; business partners of the Company; companies that offer maintenance, updating and development services for internet sites and related functions; quality control and / or certification bodies or related activities; auditor; supervisory bodies; subjects that deal with the printing, transmission, enveloping, transport and sorting of communications; subjects that deal with document archiving and preservation; subject to your consent, companies specialized in marketing activities, commercial information, research, surveys and / or market analysis, analysis of consumption habits. The updated list of managers is available on site and can be consulted upon request.
or 8.4 For the pursuit of Primary Purposes, your personal data may, if necessary, be communicated to the following categories of recipients: factoring companies; banks and credit institutions; debt collection company; credit insurance company; insurance companies, brokers and other subjects in the insurance sector; financial companies; commercial information company, detection and analysis of financial risks / customer solvency and fraud prevention; professionals, experts, consultants, studies or consultancy companies in the administrative, accounting, tax, technical and legal fields; sector and / or category associations; companies operating in the shipping and transport sector.
or 8.5 We inform you that your personal data may in any case always be communicated to third parties, public and private, to comply with legal obligations, to comply with orders from public authorities or to exercise a right in court or in any other place.
or 8.6 Your personal data are not transferred and are not subject to disclosure.
9. 9 TRANSFER OF DATA ABROAD
or 9.1 The Company processes its data mainly within its own premises or, in any case, within the U.E.
or 9.2 By virtue of the IT applications used, the Company may also transfer outside the U.E. your personal data. In any case, the transfer is carried out in full compliance with the conditions imposed by G.D.P.R. (art. 44 and following).
10. 10 SPECIAL CATEGORIES OF DATA AND TREATMENTS
or 10.1 In pursuit of the Primary Purposes, the Company may become aware of Your personal data classified as particular, or is that data which "reveals the racial or ethnic origin, political opinions, religious or philosophical convictions, or trade union membership , as well as to treat genetic data, biometric data intended to uniquely identify a natural person, data relating to health or sexual life or sexual orientation of the person ". Such data may be disclosed to third parties only where it is strictly necessary.
or 10.2 For the processing of particular data, your explicit consent is required, pursuant to art. 9 of the G.D.P.R. In default, the Company would not be able to fulfill your requests, as better specified in the previous paragraph 7.2.
or 10.3 We inform you that for purposes of security and protection of the corporate assets the Company carries out the processing of personal data (images) also through systems of
video surveillance: the information relating to these types of processing is available at the premises where the systems are installed.
11. 11 DURATION OF TREATMENT
or 11.1 In accordance with the laws that impose document retention obligations for accounting purposes and the general rules relating to the ordinary limitation period for contractual actions, we will delete your personal data relating to the Primary Purposes after ten years have elapsed, starting from time of termination of the contract.
or 11.2 Personal data processed for additional optional purposes (Marketing Purposes; Profiling Purposes; Customer Satisfaction Purposes) will be deleted after ten years, a term deemed to be reasonable given that the data are connected to the sale of goods with a low frequency of purchase and consider the sector statistics.
12. 12 RIGHTS OF THE INTERESTED PARTY
or 12.1 In application of the G.D.P.R., we inform you that you can exercise at any time
or - obtain confirmation that your personal data is being processed and is not being processed and, in this case, obtain access to personal data and to all the information required by the art. 15 of the G.D.P.R., possibly obtaining a copy where this does not link the rights and freedoms of others;
or - obtain the rectification of inaccurate personal data that concerns you without undue delay. Taking into account the purposes of the processing, you have the right to obtain the integration of incomplete personal data, even providing a supplementary statement;
or - obtain the deletion of your personal data without unjustified delay, or - obtain the limitation of the processing when one of the hypotheses envisaged by art.
18 of the G.D.P.R.;
o - data portability, or is to receive in a structured format, commonly used and readable by automatic device, the personal data concerning you provided to the undersigned Company;
or not be subjected to a decision based solely on the automated processing, which produces legal effects that concern you or that significantly affects your person. This right does not apply in the cases governed by art. 22, paragraph 2 of the G.D.P.R ..
.2 12.2 To exercise the above rights, you can contact the Company at any time. To be able to more correctly manage your requests, we invite you to write to us by registered mail or by sending an email to the following address: email@example.com
.3 12.3 The request for deactivation and cancellation of the subscription to the Newsletter Service may be made by the Interested Party at any time by sending ("Cancellami") present on site.
13. 13 RIGHT OF OPPOSITION
In accordance with the requirements of art. 21, paragraph 4 of the G.D.P.R., the Company brings your right of opposition to your attention. In particular, you will be entitled to:
or - object at any time, for reasons connected with your particular situation, to the processing of your personal data pursuant to Article 6, paragraph 1, letters e) of) of the GDPR In this case the Company will refrain from processing further personal data except for the existence of legitimate cogent reasons for processing that prevail over the interests, rights and freedoms of the data subject or for the verification, exercise or defense of a right in court;
or - object at any time to the processing of your personal data carried out for direct marketing purposes, including profiling to the extent that it is connected to such direct marketing. In this case, personal data are no longer processed for these purposes.
13.1 You can contact the Company at any time to exercise your right to object. To be able to more correctly manage your requests, we invite you to write to us by registered mail or by sending an email to the following address: firstname.lastname@example.org
14. 14 RIGHT TO PROPOSE A CLAIM
or 14.1 If, furthermore, You believe that the processing of data by the Company is
illegitimate, you can lodge a complaint with the competent supervisory authority.
15. 15 CHANGES AND UPDATES
or 15.1 As the regulatory framework is constantly evolving, we will communicate to you any changes or updates to this information through the same channels used to contact you. We trust that you will appreciate our commitment to transparency and our willingness to make you fully aware of what we do with your personal data.