INFORMATION PURSUANT TO ART. 13 OF EU REGULATION 2016/679
A – Owner, managers and persons authorized to process personal data
Proconsul Group S.r.l, based in via dei Magazzini Generali n ° 10 – 00154 Rome, is the holder of the processing of your personal data. The Data Controller informs you that the data you provide in relation to the existing and / or future legal relationships (user / interested party) that will be processed in compliance with the aforementioned legislation.
Said treatment will take place in a lawful way and according to the principles of art. 5 of EU Regulation 2016/679. Further communications may be disclosed later, even verbally.
The updated list of data processors and persons authorized to process is kept at the headquarters of Proconsul Group S.r.l.
B – Data object of the treatment
“Personal data processing” means any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as the collection, registration, organization, structuring , storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or the destruction. Specifically, these are data you voluntarily provided for the execution of the legal relationships in place with the Data Controller.
Article. 4 of EU Regulation 2016/679 defines “personal data” any information concerning an identified or identifiable natural person (“data subject”); the natural person who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity is considered identifiable, physiological, genetic, psychic, economic, cultural or social.
The data subject to processing, summarized below, in a completely exemplary but certainly not exhaustive form, will be voluntarily provided by you for the execution of existing legal relationships:
Name and surname, registered residence or tax domicile, telephone number, fax number, e-mail address or PEC, VAT number / tax code.
Added to this are the navigation data, the IT systems and the software procedures used to operate this website, which could acquire, during their normal operation, your personal data, the transmission of which is implicit in the use of protocols of Internet communication. However, this is information that is not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the addresses in URI (Uniform Resource Identifier) ??notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site or requests from the authorities.
C – Particular categories of personal data and data relating to criminal convictions and crimes
On the occasion of some communications from interested parties, Proconsul Group S.r.l. may process particular categories of personal data (“sensitive data”) and data relating to criminal convictions and crimes.
Article 9 of EU Regulation 2016/679 includes in the “special categories of personal data” data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or union membership, as well as genetic data , biometric data intended to uniquely identify a natural person, data relating to the health or sexual life or sexual orientation of the person. As part of the existing and / or future legal relationship, the data you provide will have or may have a sensitive nature, if they are essential for the performance of the relationship itself or for fulfilling legal obligations.
Within the limits described above, we would like to inform you that data relating to criminal convictions and crimes (criminal records and pending charges) or related security measures will also be processed.
D – Purpose of data processing
The personal data you provide will be processed for the following purposes:
- management of existing and / or future legal relationships;
- fulfillments related to the obligations deriving from the aforementioned legal relationships;
- organizational management of any legal relationship in place or in the definition phase;
- fulfillment of regulatory, accounting and / or tax obligations;
- protection of contractual rights;
- functional purposes for carrying out statistical analyses;
- promotion of marketing and commercial communication activities via e-mail, or by telephone, regarding the services provided by the Owner, also through partners.
E – Legal basis of the processing
With reference to the purposes referred to in numbers 1 to 6 of Paragraph D, processing is necessary for the execution of a contract of which you are a part or for the execution of pre-contractual measures adopted at your request. The treatment is therefore lawful (art.6, co. 1, letter b), EU Regulation 2016/679).
With reference to the purpose referred to in number 7, the processing is subject to your consent (art.7 EU Regulation 2016/679).
F – Duration of treatment
Personal data relating to the purposes 1, 2, 3, 4, 5 and 6 of paragraph D will be processed for a period of time not exceeding the achievement of the purposes for which they are processed, and in any case within the terms established by law. Such data, upon expiry of said term, will be destroyed.
The personal data contained in documents relevant for administrative-accounting purposes will in any case be kept in compliance with legal obligations.
On the other hand, with regard to the data provided for the purposes referred to in point 7 of the same paragraph, the same will be processed for a maximum period of 2 (two) years and, with reference to customers only, this period can only be extended to continuation of contract renewal. It is possible to withdraw consent to such treatment at any time.
G – Nature of data provision
Consent to the processing of data is mandatory in relation to purposes 1 – 6, that is, to fulfill legal obligations regarding an established relationship and for any other purpose related to legal obligations, regulations and community regulations; the refusal to communicate the data will prevent the Data Controller from fulfilling these obligations and consequently the inability to provide you with the services requested by you. The sending of communications for the purpose referred to in point 7 will take place by email or on paper. The interested party may exercise the rights referred to in art. At any time 7, par. 3, and to the articles 15 and following of EU Regulation 2016/679 or the cessation of such communications, also expressing the will to receive communications exclusively through other contact methods, where applicable. The provision of your data and consent to the processing for the purposes referred to in point 7 are entirely optional. Failure to provide your personal data for the purposes indicated above will make it impossible to carry out activities relating, for example, to sending newsletters by paper / electronic mail relating to the promotion of institutional activities.
H – Data processing methods
The data will be processed and stored exclusively for the purposes indicated above through the use of both paper and computerized media, inserted in relevant databases and processed with suitable tools to guarantee the integrity, security and confidentiality of the data, in compliance with the provisions of EU Regulation 2016/679. All the appropriate technical and organizational measures will be taken to guarantee a level of data protection compliant with the provisions of EU Regulation 2016/679. Access will be allowed only to people authorized in writing to process personal data. The data may also be communicated to and / or collected / by third parties (as in the case of data acquisition from processing centres or from other companies). The same will be appropriately designated as Data Processors and will be involved in the fulfilments required by the existing legal relationship, as well as by specific legal obligations.
I – Social platforms
L – Cookies
M – Communication to third parties and / or dissemination of data
For the purposes referred to in numbers 1 to 6, Proconsul Group S.r.l. informs you that your data could be communicated to external subjects, designated in writing, if this is necessary to fulfill an obligation under the law, to perform obligations deriving from a contract of which you are / will be a part, as well as to fulfill, before the conclusion of the contract, to your specific requests.
The recipients of the personal data communications of the interested party can also be identified in the following categories of recipients:
- Supervisory bodies, judicial authorities, agencies, professionals, companies, public administrations or other structures designated for the execution of treatments related to the fulfillment of the administrative, accounting and management obligations related to the ordinary performance of the economic activity of the Data Controller (legal obligations);
- banks, financial institutions, freelancers, professional firms and consultants to whom the communication of the aforementioned data is necessary for the performance of the activity of the Data Controller and, in particular, in relation to the fulfillment of the contractual obligations assumed towards the interested party (contractual obligations);
The collected data will not be disclosed in any way.
O – Intention to transfer data abroad
The data may be transferred to third countries (not belonging to the European Union). Proconsul Group S.r.l., in compliance with the provisions of Chapter V of EU Regulation 2016/679, ensures that the transfer will not affect the level of protection of natural persons required by the European legislator.
In particular, the following conditions may apply:
- Transfer based on an adequacy decision (art.45 of EU Regulation 2016/679);
- Transfer subject to adequate guarantees (art.46 of EU Regulation 2016/679);
- Consent expressed in the absence of the previous guarantees or transfer necessary pursuant to art. 49 of EU Regulation 2016/679.
Further information may be acquired, subject to prior and / or explicit request, to the Personal Data Protection Officer (DPO) at the indicated contacts.
P – Rights pursuant to EU Regulation 2016/679
The interested party can, at any time, exercise the rights referred to in art. 7, par. 3, and to the articles 15 and following of EU Regulation 2016/679:
- right of access to personal data;
- right to obtain the correction or cancellation of the same or the limitation of the treatment;
- right to object to the treatment;
- right to data portability;
- right to withdraw consent, where provided (the withdrawal of consent does not affect the lawfulness of the treatment based on the consent given before the revocation);
- right to lodge a complaint with the supervisory authority (Privacy Guarantor).
Q – Identifying details of the Data Controller
The interested party can exercise the rights described above, by calling the telephone number 06.51964514, sending a fax to 06.62298263 or sending an email to the email address firstname.lastname@example.org.
The Data Controller is Proconsul Group S.r.l. with headquarters in Via dei Magazzini Generali n ° 10 – 00154 Rome.
The list of external managers will be kept updated and will be sent to the interested party upon specific request.
Further information relating to the processing of personal data may also be communicated verbally at the time of data collection.
Place and Date Data Controller
Rome, 1 January 2019 Proconsul Group S.r.l.