Processing and protection of personal data
pursuant to Article 13, of EU Regulation 2016/679 (“GDPR”)
With this information, the Data Controller, as defined below, wishes to illustrate the purposes for which it collects and processes your personal data, which categories of data are processed, what are your rights recognized by the legislation on the protection of personal data and how they can be exercised, also allowing you to consciously provide your consent to the processing, where necessary.
- WHO IS THE DATA CONTROLLER
S.E.I.C.A. SpA, with registered office in Via Kennedy 24, Strambino (Turin – Italy), in the person of the legal representative, is the owner of the processing of your personal data (the “Owner” or “SEICA”).
- HOW TO CONTACT THE DATA PROTECTION OFFICER
The Data Controller has appointed a data protection officer (“Data Protection Officer” or “DPO”) who can be contacted by sending an e-mail to firstname.lastname@example.org
or by writing to:
Responsabile della protezione dei dati – Data Protection Officer (DPO)
c/o SEICA S.p.A.
10019 STRAMBINO (Turin – Italy)
- WHAT DOES PERSONAL DATA MEAN
According to the GDPR, personal data means: “any information concerning an identified or identifiable natural person; an individual is identified as identifiable, either directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychological, economic, cultural or social “(the” Data “).
- WHAT ARE THE PURPOSES OF THE PROCESSING OF ITS DATA AND ITS LEGAL BASIS
4.1. SEICA collects and processes your data for communication, for carrying out commercial activities (providing or requesting information on products and services, organizing meetings, issuing and receiving offers), for administrative activities (receiving and issuing orders, billing, accounting and financial management) and for the provision and supply of the services requested from time to time.
In particular, for these purposes SEICA collects and processes the following data:
- personal and identification data (first and last name, role / title / function);
- office address, telephone number and e-mail address;
- in general, any other data and information necessary for the conduct of business relationships.
4.2. Your Data may also be processed by the Data Controller for the fulfillment of legal obligations. By way of example, SEICA may process your data for tax purposes related to the execution of the contract, for handling the Authority’s requests, as well as for obligations relating to the prevention of fraud, money laundering and terrorist financing, where applicable.
4.3. The Data Controller may process your data to send communications of a commercial nature and / or for promotional initiatives in order to offer their products and / or services. SEICA will carry out this activity in compliance with the principles of the GDPR and for the pursuit of its own legitimate interest; in any case, you may object to the receipt of such communications at any time by writing to the Data Controller at the email address email@example.com or by contacting the DPO at the addresses indicated in paragraph 2 above.
4.4. Without prejudice to the provisions of paragraph 4.3 above, with your express and specific consent, the Data Controller may also process your data for promotional initiatives (present and future) of a commercial nature, sending advertising material, carrying out market research, direct selling , commercial communication, relating to the entire range of products and / or services offered by SEICA, by Group companies to which the latter belongs (controlling, controlled and / or connected companies), by affiliated establishments and third-party partners. The sending of commercial communications can take place through the use of traditional systems (paper mail, telephone calls) and electronic (SMS, e-mail, notifications on the App).
The consent you have given on the individual issues referred to in paragraph 4.4 above may be revoked at any time by writing to the Data Controller at the email address firstname.lastname@example.org or by contacting the DPO at the addresses indicated in paragraph 2 above.
In all cases, we are committed to ensuring that the information collected and used is appropriate for the purposes described and that this does not lead to an invasion of your personal domain.
- TO WHOM WE COMMUNICATE YOUR DATA
SEICA will be able to communicate some of your data to the subjects of which it avails itself for the carrying out of activities necessary for the attainment of the purposes indicated and described in the previous paragraph 4.
Your Data may then be disclosed to external companies that offer logistics services to SEICA, or to companies that carry out technical coordination, assistance and maintenance activities in favor of the Data Controller and provide assistance in your favor on matters relating to SEICA products.
The subjects mentioned above who process your Data on behalf of SEICA are specifically appointed as Data Processors by the Data Controller. The list of Data Processors can be requested by contacting the DPO at the addresses indicated in paragraph 2 above. Finally, the Data Controller may communicate your Data to the subjects to whom the communication is due by virtue of legal obligations and to the credit institutions with which SEICA operates, for the purpose of carrying out the commercial activities and business relationships described in this document. These entities carry out their processing activities as independent data controllers.
- FOR HOW LONG WE KEEP YOUR DATA
The Data relating to you will be processed by SEICA only for the time necessary for the purposes mentioned above. In particular we report below the main periods of use and storage of your data with reference to the different purposes of treatment:
a) for the execution of the contract of which you are a part, the data referred to you will be processed by SEICA for the entire duration of the same and until there are obligations or obligations related to the execution of the contract and will be kept for a period of 11 years after the termination of the contractual relationship exclusively for purposes connected with the fulfillment of legal obligations or defending the rights of SEICA;
b) with reference to processing for marketing and commercial purposes, carried out on the basis of a legitimate interest of the Data Controller, or of your consent, your Data will be processed for the entire duration of the contract or business relationship, as long as there are obligations o obligations related to the execution of a contract, and in any case for a period of 5 years, unless you object to the processing or revoke the consent you have given;
c) in order to comply with legal obligations, the data will be processed and retained by SEICA as long as the need for processing to comply with these legal obligations persists.
- YOUR RIGHTS IN THE QUALITY OF DATA CONTROLLER
During the period in which SEICA is in possession of or is processing your data, you, as a data subject, may at any time exercise the following rights:
- Right of access. You have the right to obtain confirmation as to whether or not data concerning you is being processed and the right to receive any information relating to the same;
- The right to rectification. You have the right to obtain the correction of your data that SEICA holds, if they are incomplete or inaccurate;
- Right to cancellation (so-called “right to be forgotten”). In certain circumstances, you have the right to obtain the cancellation of your data present in the archives of Seica if they are not relevant to the continuation of the contractual relationship or required by law; • Right to limitation of processing. on the occurrence of certain conditions, you have the right to obtain the processing of your data, if it is not relevant for the continuation of the contractual relationship or necessary by law;
- Right to portability. You have the right to obtain the transfer of your data held by Seica in favor of a different owner;
- Right of opposition. You have the right to object, at any time for reasons connected with your particular situation, to the processing of data concerning you based on the lawfulness of legitimate interest or the performance of a task of public interest or exercise of public powers, including profiling, unless there are legitimate reasons for the Data Controller to continue processing that prevail over the interests, rights and freedoms of the data subject or for the assessment, exercise or defense of a right in judicial seat;
- Right to revoke consent. You have the right to withdraw consent to the processing of your data at any time, without prejudice to the lawfulness of the processing based on consent before the withdrawal;
- Right to lodge a complaint with the Supervisory Authority. In the event that SEICA refuses to satisfy your access requests, the reasons for the relative refusal will be provided. If applicable, you have the right to lodge a complaint as described in the following paragraph 8.
The above rights may be exercised against the Owner by writing
to the email address email@example.com
or by contacting the DPO at the addresses indicated in paragraph 2 above.
The exercise of your rights as Data Subject is free of charge within the meaning of Article 12 of the GDPR. However, in the case of manifestly unfounded or excessive requests, also due to their repetitiveness, the Holder may charge a reasonable fee, in light of the administrative costs incurred to manage your request, or deny the satisfaction of your request.
- HOW TO PROPOSE A COMPLAINT
At any time, you will have the right to promote the requests for the exercise of the rights referred to in paragraph 7 by writing to the email address firstname.lastname@example.org or contacting the DPO at the addresses indicated in the previous paragraph 2.
In any case, should you wish to make a complaint regarding the ways in which your data are processed by SEICA , or in relation to the handling of a complaint you have proposed, you have the right to file an application directly to the Authority of control.