Privacy Policy
BUYERS - CUSTOMERS INFORMATION FOR THE TREATMENT OF PERSONAL DATA
Palumbo S.r.l. (VAT: 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 n. 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 you represent, to whom you are required to communicate this information:
1. LEGAL BASIS AND BASIS FOR PROCESSING
The processing is necessary for the management of ongoing contracts with you; for these purposes, the Data Controller is in possession of your data qualified as personal data under the GDPR (e.g. name, surname, company name, address, telephone, e-mail, bank and payment references - hereinafter, "personal data" or also "data") communicated by you on the occasion of the conclusion of contracts for services to the Data Controller, also during pre-contractual negotiations.
In accordance with the conditions laid down in Article 6, paragraph 1, letters 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:
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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/rental);
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fulfil pre-contractual, contractual and fiscal obligations arising from existing relations with you;
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to fulfil the obligations provided for by law, by a regulation, by Community legislation or by an order of the Authority (such as, for example, anti-money laundering)
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to exercise the rights of the Controller, such as the right of defence in court.
3. PROCESSING METHODS
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 shall be subject to both paper and electronic and/or automated processing.
The Data Controller shall process 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.
4. ACCESS TO DATA
Your data may be made accessible for the purposes set out in point 2 of this policy:
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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
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to third party companies or other entities (for 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 Owner, in their capacity as external data processors.
5. COMMUNICATION OF DATA
Without the need for express consent (art. 6 lett. b), c) and f) GDPR), the Data Controller may communicate your data for the purposes of 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 required 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 disclosed.
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, if 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 referred to in point 2 is compulsory. Without them, we will not be able to guarantee the contractual services of point 2.
8. RIGHTS OF THE DATA SUBJECT
In your capacity as data subject, you have the rights set out in Article 15 GDPR and specifically the rights to:
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obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet recorded, and its communication in intelligible form;
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to obtain information on: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the event of processing carried out with the aid of electronic instruments; d) the identity of the owner and managers referred to in Article 3, paragraph 1, GDPR; e) the subjects or categories of persons to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents;
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obtain: a) the updating, rectification or, when interested, the integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary for the purposes for which the data were collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
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to oppose, in whole or in part: a) for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of collection; b) the processing of personal data concerning you for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or mail.
Where applicable, he/she also has the rights under Articles 16-21 GDPR (Right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to complain to the Supervisory Authority.
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 those 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 processing of personal data concerning you carried out for such purposes, including profiling insofar as it is related to such direct marketing.
9. HOW TO EXERCISE YOUR RIGHTS
You may at any time exercise your rights under Article 15 GDPR by sending at your choice
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a registered letter with return receipt to Palumbo S.r.l. (VAT: 03917590758), with registered office in Seclì (Le), via Largo Stazione n. 12;
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an e-mail to (or CEN) [email protected]
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the appropriate form, which can be downloaded from the website garanteprivacy.it
10. DATA CONTROLLER, DATA PROCESSOR AND PERSONS IN CHARGE OF PROCESSING
The Data Controller is Palumbo S.r.l. (VAT: 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.