Privacy Policy

The Italian-German Chamber of Commerce and the other companies of the group to which it belongs, such as DeInternational Italia S.r.l. and Dual Concept S.r.l., headquartered at Via Gustavo Fara 26, Milan (“AHK Italien”), which may be contacted by e-mail at privacy@ahk-italien.it, in their capacity as joint controllers, inform you that AHK Italien will process your personal data for the purposes and according to the procedures described below.

1. To whom does the Privacy Policy apply?

AHK Italien processes the data of the legal representatives, marketing, management and accounting heads, HR, Mobility and/or other persons specified as contact persons by AHK Italien’s customer companies (“Contact Persons”), in accordance with the agreements with AHK Italien, make use of the services (offered free of charge or subject to a fee) in connection with the posting of employees to Italy (“Agreement”).

2. What type of personal data are processed?

AHK Italien collects the following categories of personal data relating to Contact Persons: name, surname, contact details (phone number, email address), job position.

3. For what purposes are personal data processed?

AHK Italien processes Contact Persons’ personal data for the following purposes:

(a) managing the Agreement and performing the services thereunder, including managing any problems related thereto;
(b) handling complaints and disputes relating to the Agreement; (the purposes under points a) and b) are hereinafter jointly referred to as “Contractual Purposes”);
(c) fulfilling obligations arising out of applicable legislation, including the any notifications to competent authorities and supervisory bodies and the response to any requests from such authorities (hereinafter, the “Legal Purposes”);
(d) exercising or defending AHK Italien’s rights in or out of court; 
(e) carrying out activities serving the purpose of sales of companies and business units, acquisitions, mergers, demergers or other transformations of AHK Italien, and to the performance of such operations; (the purposes under points (d) and (e) are hereinafter jointly referred to as “Legitimate Interest Purposes”); 
(f) sending marketing communications about products and services offered by AHK Italien (e.g., sending newsletters, invitations to events, as well as opinion and approval surveys) via remote and traditional means; (hereinafter, the “Marketing Purposes”).

4. What are the legal bases for the processing?

The processing of Contact Persons’ personal data is necessary, as to Contractual Purposes and Legal Purposes, to:

  • perform the Agreement in relation to the services referred to in Section 3, letters (a) to (b);
  • comply with applicable legal obligations in accordance with Section 3(d)[A1] .

Should the Contact Person fail to provide the data required for the Contractual Purposes, the Agreement cannot be entered into or continued.
Processing of the Contact Person’s data for Legitimate Interest Purposes is carried out pursuant to Article 6(f) of the EU general Regulation on Data Protection, No. 2016/679 (the “Data Protection Regulation”) for the pursuit of AHK Italien’s legitimate interest, which is fairly balanced with the Contact Person’ legitimate interest, in that the data processing activity is limited to what is strictly necessary for the performance of the economic transactions requested. Processing for Legitimate Interest Purposes is not mandatory and the Contact Person may object to such processing as set out in Section 8 below; however, if the Contact Person objects to such processing, their data may not be used for Legitimate Interest Purposes.
The processing of Contact Persons’ data for Marketing Purposes is optional. However, if the Contact Person denies their consent, they will not be able to receive the marketing communications referred to in Section 3. At any time, the Contact Person may revoke any consent given, as set out in Section 8 below.

5. How are Contact Persons’ Data processed?

Data are processed by electronic and/or manual means, which guarantee security, confidentiality and prevent unauthorised access, dissemination, modification and misappropriation of data through the adoption of appropriate technical, physical and organisational security measures.

6. To whom are Contact Persons’ Data communicated?

For the purposes of Section 3 above, the Contact Persons’ data may be transferred to the following categories of recipients, located within the European Union: (a) third party providers of customer and consultancy services for AHK Italien, with reference to activities in the following fields (without limitation): technology, accounting, administration, legal, insurance, IT; (b) subjects and authorities whose right to access the Contact Persons’ data is expressly recognised by law, regulations or measures issued by the competent authorities.
Data are not transferred outside the European Union.

7. How long are Contact Persons’ Data retained?

Contact Persons’ data shall be retained for the period of time necessary to pursue the purposes for which they were collected. In any case, the following retention periods shall apply:

a. for the Contractual Purposes, Legal Purposes and Legitimate Interest Purposes referred to in Section 3, letters (a) to (e), Contact Persons’ data shall be retained for a period equal to the term of the Agreement (including any renewals) and for 10 years after termination, cancellation or withdrawal thereof, except where retention for a later period is required for litigation, requests by competent authorities or under applicable law.

b. for the Marketing Purposes referred to in Section 3, letter (f) of this Privacy Policy, the Contact Persons’ data are retained for the term of the Agreement and a period of 24 months after its termination.

8. What are the Contact Persons’ rights?

The Contact Person may, at any time and free of charge, send an e-mail to privacy@ahk-italien.it, to exercise the following rights:

a. obtain from AHK Italien confirmation of the existence or otherwise of data concerning them and be informed about the content and source of the data, verify their accuracy and request their supplementation, updating or modification;

b. obtain the erasure, transformation into anonymous form or blocking of any data processed in violation of the applicable law;

c. object in whole or in part, on legitimate grounds, to the processing; and

d. withdraw, at any time, their consent to data processing (in relation to processing for which such consent may be required), without this affecting in any way the lawfulness of the processing based on the consent given prior to withdrawal; ask AHK Italien for the restriction of the processing of their data in the event that:

  • the Contact Person challenges the accuracy of their data, for the period necessary for AHK Italien to verify such accuracy;
  • the processing is unlawful and the Contact Person objects to the erasure of their data, and instead requests that its use be restricted;
  • AHK Italien no longer needs the data for processing purposes, but the data are required by the Contact Person for the establishment, exercise or defence of a legal claim; or
  • the Contact Person has objected to the processing pursuant to Article 21(1) of the Data Protection Regulation, pending verification as to whether AHK Italien’s compelling legitimate reasons for continuing the processing prevail.

    e. object to the processing of their data; 
    f. request the erasure of data concerning them without undue delay; and
    g. receive an electronic copy of their data, should the Contact Person wish to transfer the data concerning them to themselves or to a different service provider, in cases where AHK Italien processes the data on the basis of the Contact Person’s consent, or on the basis that the processing is necessary for the provision of services and the data are processed by automated means; and
    h. lodge a complaint with the competent supervisory authority.

    9. Changes and Updates

This Privacy Policy may be subject to amendments and supplementations, including as a consequence of the applicability of the Data Protection Regulation and any subsequent regulatory changes and/or supplementations. Changes will be notified in advance and Contact Persons may view the constantly updated text of the Privacy Policy on the website www.ahk-italien.it.

***

Having read the information on the processing of my personal data, I declare that I give my consent to AHK Italien and the other companies DEinternational S.r.l. and Dual Concept S.r.l., as joint data controllers, to process my personal data (which I may also revoke at a later date in relation to the individual companies of the AHK group) in order to

  • receive information relating to the legislation on the cross-border posting of workers to Italy and other communications relating to the support service for posting to Italy.