BUYERS - CUSTOMERS POLICY FOR THE PROCESSING OF PERSONAL DATA
Palumbo S.r.l. (P.I.: 03917590758), with registered office in Seclì (Le), via Largo Stazione n. 12, in the person of its pro-tempore legal representative and sole director, Mr. Fabio Palumbo (hereinafter, "Data Controller"), in its capacity as data processor, hereby informs you pursuant to Art. 13 EU Regulation no. 2016/679 (hereinafter, "GDPR") that it may process, as appropriate, the following data referring to you and/or the relevant personnel (employees or collaborators) and/or the partners or directors of the company, firm or entity it represents, to whom it is required to communicate this information:
1. LEGAL BASIS AND GROUNDS FOR PROCESSING
The processing is necessary for the management of ongoing contracts with you; for these purposes, the Controller is in possession of your data qualified as personal data within the meaning of the GDPR (e.g., name, surname, company name, address, telephone number, e-mail, bank and payment references - hereinafter, "personal data" or also "data") communicated by you when concluding contracts for services to the Controller, including during pre-contractual negotiations.
In accordance with the conditions set out in Art. 6(1)(b), (c), (d), (e) GDPR, we inform you that the provision of your Data is aimed at pursuing the purposes set out in point 2) below.
2. PURPOSE OF PROCESSING
Your personal data are processed even without your express consent (Art. 6 lett. b), e), f) GDPR), for the following purposes
to conclude contracts for supply such as (e.g. sale of aluminium profiles) or services rendered by the Controller also by means of its own machines or machinery (such as hot and cold hire/leasing);
fulfilling pre-contractual, contractual and tax obligations arising from existing relations with you;
to fulfil the obligations laid down by law, regulation, EU legislation or an order of the Authority (such as anti-money laundering)
exercise the rights of the Controller, such as the right of defence in court
3. METHODS OF PROCESSING
The processing of your personal data is carried out by means of the operations indicated in Article 4 no. 2 GDPR and precisely: collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.
Your personal data are subject to both paper and electronic and/or automated processing.
The Data Controller will process your personal data for the time necessary to fulfil the above purposes and in any case for no longer than ten years from the termination of the relationship established in relation to the purposes of the Service/Supply provided by the supplier.
Your data may be made accessible for the purposes set out in point 2 of this information notice
to employees and collaborators of the Data Controller, in their capacity as persons in charge and/or internal or external data processors and/or System Administrators and Data Processors
to third party companies or other entities (by way of example, credit institutions, factoring companies, professional firms, consultants, insurance companies for the provision of insurance services, etc.) that perform outsourcing activities or provide services of various kinds on behalf of the Data Controller, in their capacity as external data processors.
5. COMMUNICATION OF DATA
Without the need for your express consent (Art. 6 letters b), c) and f) GDPR), the Data Controller may communicate your data for the purposes set out in Art. 2.A) to supervisory bodies, judicial authorities, insurance companies for the provision of insurance services, as well as to those subjects to whom communication is obligatory by law for the fulfilment of the aforementioned purposes. These subjects will process the data in their capacity as autonomous data controllers.
Your data will not be disseminated.
6. DATA TRANSFER
Personal data are stored on servers located in Seclì (Le), via Largo Stazione n. 12.
It is in any case understood that the Data Controller, should it become necessary, will have the right to move the servers to another location in Italy .
7. NATURE OF DATA CONFERMENT AND CONSEQUENCES OF REFUSAL TO ANSWER
The provision of data for the purposes set out in point 2 is compulsory. In their absence, we will not be able to guarantee you the contractual services of point 2.
In your capacity as data subject, you have the rights set out in Article 15 GDPR and specifically the rights to
obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet recorded, and its communication in intelligible form;
to obtain information on: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with the aid of electronic instruments; d) the identification details of the data controller and of the data processors as per Art. 3, paragraph 1 of the 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, data processors or persons in charge of processing;
object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning you, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct selling or for the performance of market or commercial communication surveys, by automated calling systems without the intervention of an operator, by e-mail and/or by traditional marketing methods using telephone and/or paper mail.
Please note that you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you pursuant to Article 6(1)(e) or (f) of the GDPR, including profiling on the basis of these provisions.
Your personal data are not processed for direct marketing purposes. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you carried out for such purposes, including profiling insofar as it is related to such direct marketing.
9. METHODS OF EXERCISING RIGHTS
You may at any time exercise your rights pursuant to Art. 15 GDPR by sending
a registered letter with acknowledgement of receipt to Palumbo S.r.l. (P.I.: 03917590758), with registered office in Seclì (Le), via Largo Stazione n. 12;
an e-mail (OR PEC) to [email protected]
the appropriate form, which can be downloaded from the website garanteprivacy.it
10. OWNER, MANAGER AND APPOINTEES
The Data Controller is Palumbo S.r.l. (P.I.: 03917590758), with registered office in Seclì (Le), via Largo Stazione n. 12, in the person of its pro-tempore legal representative and sole director, Mr Fabio Palumbo.
The updated list of data processors and persons in charge of processing is kept at the registered office of the Data Controller.