DISCLOSURE ABOUT THE PROCESSING OF PERSONAL DATA
pursuant to articles 13 and 14 of Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data
I.VAR. Industry S.r.l. (hereinafter also “Owner” or “Licensor”), with registered office in Via San Pierino, 4 Z.A.I. – 37060 Trevenzuolo (VR) ITALY and tax code / VAT number 02835480233, as holder of the processing of personal data informs you, pursuant to art. 13 and 14 of the European Regulation 679/2016 concerning the protection of personal data (“GDPR”) as follows.
1 TYPES OF DATA PROCESSED
The Licensor is the holder of the processing of personal data communicated at the time of signing the Contract and subsequently provided on the occasion of the execution of the Contract.
The personal data that the Licensor collects in relation to the management of the contractual relationship and in the eventual pre-contractual phases can be provided directly by the interested party (as defined below) or by the Customer, in the case of internal referents to the Customer assigned to the management of the Contract.
The personal data processed by the Licensor may be, by way of example and not exhaustively, the names, qualifications, telephone numbers, tax code, payment and bank details, eventually the company name and e-mail addresses of natural persons and legal representatives of companies as contractual parties to the Contract as well as internal referents for the management of contracts (hereinafter, the “Interested parties” and “Data”).
Some information, relating for example to the data of representatives and prosecutors or to financial statements or customer custody, are also acquired from public sources (for example Chambers of Commerce, or commercial information services).
2 PURPOSE OF THE TREATMENT
Data processing is performed by the Licensor in the performance of its economic and commercial activities for purposes related to the establishment, management and execution of business relationships, including the management of the pre-contractual relationship.
In particular, the Data provided by the Interested parties will be processed, mainly through IT tools, for the following purposes:
a) the execution of obligations strictly related to the management of the Contract, including the administrative and accounting management of contracts, the management of payments and invoices, the release of services and the management of customer support services. The provision of data for these activities is essential for the correct management of the Contract and does not require the consent of the Interested party (Article 6(1)(b) of the GDPR);
b) the execution of instrumental activities to the management of the Contract, including the planning of activities, the protection of the management of any contentious and credit recovery for which the provision of data, where necessary, is optional and whose processing is based on the legitimate interest of the Licensor;
c) the fulfillment of obligations deriving from the law, regulations or community legislation (eg fiscal and accounting obligations) for which the provision of data is mandatory and the processing does not require the consent of the Interested party (Article 6(1)(c) of the GDPR);
3 METHODS OF THE TREATMENT
The Data will be processed by the Company with electronic and manual systems according to the principles of correctness, loyalty and transparency provided by the applicable law on the protection of personal data and with protecting the confidentiality of the Interested party through technical and organizational security measures to ensure a level of adequate security.
4 DATA CONSERVATION
The Data necessary for the management of the Contract and the fulfillment of the charges (as per letter (a) and (b) of point 2 of this statement) will be retained by the Owner in their archives for 10 years after the registration of operations in compliance with the civil and tax obligations imposed by current legislation. Similarly, the Data referred to in letter (c) of point 2 required for protection in the event of a dispute or controversy will be retained for 10 years from the termination of the Contract.
5 COMMUNICATION, DIFFUSION AND DATA TRANSFER
The Data will be processed, to the extent necessary, by the authorized personnel, adequately learned and trained, of Owner, as well as by the personnel of third parties who provide services to the Owner and process data on behalf and on the latter’s instruction as responsible of treatment.
These are those who provide IT services (eg hosting providers), call center services, credit recovery activities, customer support services (eg ticketing management), support services for marketing activities (eg direct email marketing) and third-party companies, including companies of I.VAR. Industry S.r.l., which provide complementary activities. The complete and updated list of data processing parties is available on request to the Data Protection Officer.
In cases where the contractual relationship provides for the intervention of our business partners, the Owner may share some Data with distributors, resellers and partners in the supply chain of products and services I.VAR. Industry S.r.l..
In carrying out its ordinary corporate activities, the Data may be communicated to subjects that carry out control, revision and certification of the activities carried out by the Owner, consultants and freelancers in the context of tax assistance services, judicial assistance and in the case of corporate transactions.for which it is necessary to evaluate the company assets, to other companies of COMPANY NAME where this is necessary for the purposes of group coordination and control, public entities and public administrations, including tax authorities where necessary, as well as to persons legitimated by law to receive such information, Italian and foreign judicial authorities and other public authorities, for the purposes connected with the fulfillment of legal obligations, or for the fulfillment of the obligations assumed and arising from the contractual relationship, including for the need of defense in court. The contact details could be communicated for very occasional needs to customers and / or suppliers of the Owner, for example if they must collaborate with such subjects for the purpose of providing the services.
The Data will in no case be disseminated nor will they generally be transferred outside the European Union. However, for specific needs connected to the location of the third party with which the Data may be shared, as described above, some Data may be transferred outside the European Economic Area to countries that offer adequate protection. In cases where the third country does not offer adequate protection, the Owner undertakes to ensure adequate levels of protection and safeguard, including contractual ones, including the stipulation of standard contractual clauses (a copy of the commitments assumed by third parties can be requested in the context of these clauses by request to be sent to the Data Protection Officer).
6 MARKETING AND PROFILING
With the consent of the Interested party, the Data may be processed by the Owner for the following purposes:
a) sending by e-mail and automatic or telephone messages, of offers and commercial initiatives relating to products or services of the I.VAR. Industry S.r.l. as well as the conduct of market research or other customer satisfaction initiatives promoted by the Owner. Should the provision of any data for this purpose be required, an entirely residual hypothesis, such conferment will be optional. It is understood that the processing of data for this purpose will only be possible with the consent of the Interested party (Article 6(1)(a) of the GDPR). The consent may be revoked at any time, freely in the manner indicated in the following point 7 or through the cancellation link available in each electronic communication. Any failure to issue or revoke the consent does not prejudice in any way the execution of the Contract;
b) the analysis of the use habits of the products and services of I.VAR. Industry S.r.l. by the Interested party on the basis of what may be considered of his interest both in order to improve its products and services with features that may result more interest to customers both to offer to the interested party products that could respond in a more timely manner to its need. Should the provision of any data for this purpose be required, an entirely residual hypothesis, such conferment will be optional. It is understood that the processing of data for this purpose will only be possible with the consent of the Interested party (Article 6(1)(a) of the GDPR). Any use of information relating to the use of the products or services attributable to the Customer as a legal person can be made by the Owner even without specific consent, unless otherwise provided for by law. The consent may be revoked at any time freely in the manner indicated in the following point 7; any failure to issue or revoke the consent does not prejudice in any way the execution of the Contract.
With the consent of the interested party, in order to receive promotions and commercial initiatives, the Licensor may also communicate the Data to the companies of I.VAR. Industry S.r.l. who deal with software development and partner training and suppliers of I.VAR. Industry S.r.l. for sending, by them, of promotions and commercial initiatives.
Without prejudice to the hypotheses for the exercise of the data cancellation rights and the rights of opposition and limitation of the processing referred to in paragraph 7 of this statement, the Data processed for the purposes referred to in this point will be stored and treated in compliance with the applicable legislation for the protection of personal data for the entire period of time necessary to fulfill the aforementioned purposes for a maximum of 24 months or the maximum maximum period allowed by law for profiling as per letter a) of this point; otherwise, for the purposes referred to in letter b) of this point, the processing will be carried out until the consent of the interested party is revoked.
7 WHAT ARE THE RIGHTS OF THE INTERESTED
The Interested party may exercise, in relation to the processing of the data described therein, the rights provided by the GDPR (articles 15-21), including:
• receive confirmation of the existence of the Data and access their content (access rights);
• update, modify and / or correct the Data (right of rectification);
• request the deletion or limitation of the processing of Data processed in violation of the law including those that do not need to be kept for the purposes for which the Data were collected or otherwise processed (right to be forgotten and the right to limitation);
• oppose the treatment (right of opposition);
• revoke the consent, where provided, without prejudice to lawfulness of the treatment based on the consent given before the revocation;
• propose a complaint to the supervisory Authority (Guarantor for the protection of personal data www.garanteprivacy.it) in case of violation of the regulations regarding the protection of personal data;
• receive an electronic copy of the Data concerning him / her as Interested, when such Data have been yield in the context of the contract and request that such Data be transmitted to another Owner (right to data portability).
To exercise these rights, the interested party may contact the Data Protection Officer by sending his request to the address firstname.lastname@example.org or directing the communication via mail to:
I.VAR. Industry S.r.l.
Via San Pierino, 4 Z.A.I. – 37060 Trevenzuolo (VR) ITALY