DEinternational Italia Srl, services company of the German-Italian Chamber of Commerce - AHK Italien, based in Via Gustavo Fara 26, Milan (“DEinternational”) which can be contacted by email at the address firstname.lastname@example.org, in the capacity of data controller, hereby informs you that it will process your personal data for the purposes and by the methods reported below.
DEinternational Italia Srl, in the capacity of data controller, processes the data of legal representatives, heads of marketing, events, administration and accounting areas and/or other persons indicated as representatives by client companies of DEinternational Italia Srl (“Representatives”) in conformity with the provisions of the contract signed between DEinternational Italia Srl and the company to which the Representatives belong (“Contract”).
2. WHAT TYPES OF PERSONAL DATA ARE PROCESSED?
DEinternational Italia Srl collects the following categories of personal data relating to the Representatives:
a) name, surname, contact details (telephone number, email address), employment position;
b) identity card and tax code (for fulfilments that require the same, such as anti-money laundering, etc.);
3. FOR WHAT PURPOSES ARE THEY PROCESSED?
DEinternational Italia Srl processes the personal data of the Representatives for the following purposes:
a) to manage the Contract and perform the services indicated in the same, therein including the handling of any related issues;
b) to manage complaints and disputes relating to the Contract; and
c) to comply with applicable legal obligations;
(the purposes indicated in points a) to c) are known jointly as the “Contractual Purposes”);
d) to send marketing communications on products and services offered by DEinternational Italia Srl (by way of example, sending newsletters, invitations to events and opinion and approval surveys) by remote and traditional methods;
e) to send marketing communications by the methods indicated above on products and services offered by other companies of the group to which DEinternational Italia Srl belongs, such as the German-Italian Chamber of Commerce and Dual Concept S.r.l., to which the data will be communicated.
(the purposes indicated in points d) and e) are known jointly as the “Marketing Purposes”).
4. WHAT ARE THE LEGAL BASES OF PROCESSING?
The processing of the personal data of the Representatives is necessary, with reference to the Contractual Purposes, to:
● perform the Contract in relation to the services indicated in Section 3, letters a) to b);
● comply with the applicable legal obligations in conformity with Section 3, letter c).
If the Representatives do not provide the data necessary for the Contractual Purposes, it will not be possible to establish or continue the Contract.
processing activity is restricted to what is strictly necessary to execute the requested economic operations. The processing for the Legitimate Interest Purposes is not mandatory and the Representatives may object to that processing by the methods indicated in Section 8 below; however, if the Representatives object to that processing, their data may not be used for the Legitimate Interest Purposes.
5. HOW ARE THE REPRESENTATIVES’ DATA PROCESSED?
The data are processed using electronic and/or manual tools, suitable to guarantee their security and confidentiality and to avoid unauthorised access, dissemination, modification and theft of data thanks to the adoption of appropriate technical, physical and organisational measures.
6. TO WHOM ARE THE REPRESENTATIVES’ DATA COMMUNICATED?
For the Contractual Purposes indicated above, the Representatives’ data may be transferred to the following categories of recipients, located within the European Union: (a) third party providers of assistance and consulting services for DEinternational Italia Srl with reference to activities of the technological, accounting, administrative, legal, insurance and IT sectors (merely by way of example); (b) other companies of the group of which DEinternational Italia Srl is part, such as the German-Italian Chamber of Commerce and Dual Concept S.r.l.; (c) entities and authorities whose right of access to the Representatives’ data is expressly recognised by law, regulations or measures issued by competent authorities.
For the Legitimate Interest Purposes indicated above, the Representatives’ data may be transferred to the following categories of recipients, located within the European Union: (a) third party providers of assistance and consulting services for DEinternational Italia Srl; (b) other companies of the group of which DEinternational Italia Srl is part, such as German-Italian Chamber of Commerce and Dual Concept S.r.l.; (c) competent authorities.
For the Marketing Purposes indicated above, the Representatives’ data may be transferred to the following categories of recipients, located within the European Union: (a) third party providers of assistance and consulting services for DEinternational Italia Srl with reference to activities of sending sales communications; (b) other companies of the group of which DEinternational Italia Srl is part, such as German-Italian Chamber of Commerce and Dual Concept S.r.l.. The data are not transferred outside the European Union.
A complete list of processors is available, upon request, by the methods indicated in Section 8 below.
7. For how long are the Representatives’ data stored?
The Representatives’ data are stored for the period of time necessary to pursue the purposes for which the data were collected. In any case, the following storage times apply:
a. for the Contractual Purposes and the Legitimate Interest Purposes indicated in Section 3, letters a) to c), the Representatives’ data are stored for a period equal to the term of the Contract (therein including any renewals) and for 10 years after the conclusion, termination or withdrawal of the same, subject to cases where storage for a longer period is required for any disputes, requests of the competent authorities or in accordance with applicable legislation;
8. WHAT RIGHTS DO THE REPRESENTATIVES HAVE?
The Representatives may, at any time and free of charge, by sending an email to the address email@example.com, exercise the following rights:
a. obtain from DEinternational Italia Srl confirmation of the existence or otherwise of data relating to them and be informed of the content and source of the data, verify their accuracy and request their supplementation, update or modification;
b. obtain the erasure, transformation into anonymous form or block on data processed in violation of the applicable law;
c. object, in whole or in part, for legitimate reasons, to the processing; and
d. withdraw, at any time, the consent to data processing (in relation to processing for which such consent is necessary), without prejudice to the lawfulness of the processing based upon consent provided before the withdrawal.
In addition to those rights, from the time the Privacy Regulation becomes effective on 25 May 2018, the Representatives will have the right, which can be exercised at any time, to:
i. request from DEinternational Italia Srl the restriction of processing of their data if:
• the Representatives dispute the accuracy of their data, for the period necessary for DEinternational Italia Srl to verify the accuracy of those data;
• the processing is unlawful and the Representatives object to the erasure of their data and instead ask for the use of their data to be restricted;
• although DEinternational Italia Srl no longer requires them for the processing purposes, the data are required by the Representatives for the establishment, exercise or defence of legal claims; or
• the Representatives have objected to processing in accordance with Article 21, paragraph 1 of the Privacy Regulation in anticipation of the check of any prevalence of compelling legitimate grounds of DEinternational Italia Srl to continue the processing.
ii. object to the processing of their data;
iii. request the erasure of data relating to them without undue delay;
iv. receive a copy in electronic format of their data, if the Representatives wish to transfer the data relating to them to another service provider, in circumstances where DEinternational Italia Srl performs data processing based upon the consent of the Representatives or based upon the fact that the processing is necessary for the provision of the services and the data are processed using automated tools; and
v. lodge a complaint with the competent data protection supervisory authority.
9. MODIFICATIONS AND UPDATES