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PRIVACY POLICY STATEMENT

pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data

 

1.                Data controller

NETTUNO SRL, with registered office in Castelli Calepio (BG), Viale Industria 16/18, Tax Code and VAT No. 01568950164, Phone 035.847508 E-mail: nettuno@nettuno.net, as data controller provides below, in accordance with Articles 13 and 14 of European Regulation 679/2016 on the protection of personal data (hereinafter referred to as "GDPR"), information concerning the processing of personal data of individuals who purchase, solicit or use services and/or products supplied by the Company (hereinafter referred to as the “Customer”).

 

2.                Type of data processed

Personal data processed by the Company include, by way of example and not exhaustively, the following categories of data relating to the Customer:

I.        identification, contact and access data, such as name, surname, email address, telephone number and credentials to access services and/or products provided by the Company; 

II.      navigation data, such as IP addresses, log data or domain names and other parameters relating to the computers, operating system and computer environment used;

III.     product data, such as data relating to products and services provided by the Company, 

IV.     data on preferences, such as data on the types of products purchased;

V.      payment and bank details, such as the account number or IBAN code; 

VI.     data acquired from public sources, such as data of representatives and attorneys that are collected, for example, by the Chamber of Commerce or the business information services;

(hereinafter jointly referred to as "Data").

 

3.                Purpose of processing

The processing of data is carried out by the Company in carrying out its economic and commercial activities for the following purposes:

a)      allow customers to request, obtain, access and use the services and products provided by the Company;

b)      allow the fulfillment of obligations deriving from the law, regulations or community legislation (e.g. tax and accounting obligations);

c)      assert and defend their rights, even in the context of debt collection and credit allocation procedures;

d)      complete a potential merger, sale of assets, transfer of business or business unit, disclosing and transferring the Data to the third party(s) involved;

(the purposes of letters "a" to "d" are jointly defined as "Contractual Purpose and Legitimate Business Interest")

e)      analysis and improvement of the services and products offered;

f)       e-mail marketing communication on services and products similar to those provided, provided that, at any time, it has the possibility to oppose the submission of such communications;

g)      engage in market research or other customer satisfaction initiatives through automated communication tools such as mail, automatic messages and other means of distance communication;

h)      perform an analysis of preferences, activities and purchasing habits, in order to send the marketing communications indicated above.

(the purpose referred to in letters "e" to "h" are defined as the "Marketing Purposes");

i)       handle communications for Marketing purposes in accordance with this disclosure, of non-invasive segmentation forms based, among other things, on membership categories such as the professional category to which they belong, the city/province/region in which it is based, and the type of service and/or product supplied by the Company.

(the purpose referred to in letter "i" is defined as the "Purpose of Legitimate Marketing Interest").

 

4.      Legal basis of data processing

With reference to the Legal Purposes, the processing of data is required in order to:

−                  provide the services and/or products requested concerning the cases referred to in Section 3, letter a);

−                  comply with the provisions of the applicable legislation as provided for in Section 3, letter b).

The processing of data for the Purposes of Legitimate Business Interests is made pursuant to Article 6 (f) of the GDPR for the pursuit of the legitimate interests of the Company which is fairly balanced with the interests, rights and freedoms of the Customer as the processing of the data is limited to what is strictly necessary for the execution of the operations indicated therein.

 

Should the Customer decide not to provide the Data necessary for the Contractual Purposes, the Company will be unable to provide the requested products and services.

 

The processing of data for Marketing Purposes is based on:

-  Section 3 letter f) on Article 130 of the Privacy Code, which allows sending marketing communications via e-mail regarding services and/or products similar to those provided.

-  Section 3, letters g) to i), on the consent of the Customer.

The processing of data for Marketing purposes is not mandatory therefore in the event of opposition to marketing communications or refusal to provide the consent, or revocation of the same, the Customer will not receive the marketing communications referred to in Section 3 by letters f) to i). In any case, the Customer may revoke the consent to the processing of data and oppose the submission of all marketing communications at any time, through the methods provided for in this statement.

 

The processing of data for purposes of legitimate marketing interests, is functional to:

-  the pursuit of a legitimate interest of the Company properly balanced with the interests, rights and freedoms of the Customer in light of the limits imposed in Section 3 letter i). Also in this case, the processing of data for the purposes of legitimate marketing interests is not mandatory and the customer can oppose the processing in the manner described in this statement. In the event of opposition to such processing, the customer will no longer receive any relevant communications unless the Company demonstrates the presence of compelling legitimate grounds prevailing or exercise or defense of a right under Article 21 of GDPR. In the event that the Customer wishes to obtain more information about the balancing of interests, rights and freedoms, he may contact the Company at any time in the manner indicated in this statement.

 

5.      Methods of processing

The Data will be processed by the Company with electronic and manual systems according to the principles of correctness, loyalty and transparency provided by the applicable law on the protection of personal data while protecting the privacy of the customer through technical and organizational security measures to ensure the proper level of security.

 

6.      Data retention

The Data will be kept for the period of time required for the pursuit of the purposes for which such Data were collected, as stated in this statement. In any case, the following retention terms will apply with reference to the processing of the Data for the following purposes:

a)    for the purposes of the Contractual and Legitimate Business Interest, the Data are kept for a period equal to the duration of the supply of the services and/or products requested by the Customer and for the 10 years following the cessation of supply, subject to any renewals and cases in which the conservation for a subsequent period is required for any disputes, requests by the competent authorities or in accordance with applicable law;

b)   for the Purposes of Marketing, referred to in Section 3, letters f) and g) and for the Purpose of Legitimate Marketing Interests, the Data are kept for a period equal to the duration of the provision of services required by the Customer and a period of 24 months following the last contact with the customer to be considered among others, participation in a Company event, the use of a product or service provided by the Company or the opening of a newsletter (jointly defined the "Last Contact ");

c)    for the Purposes of Marketing, referred to in Section 3, letter h), the Data are kept for a period of 12 months from registration;

d)   for the Purposes of Marketing referred to in Section 3, letter i), the Data are kept by the Company for a period equal to the duration of the supply of the services and/or products requested by the Customer and a period of 12 months following the Last Contact, while they are kept by third parties for a period of 12 months from registration.

 

7.      Communication, dissemination and transfer of data

For the purposes of the Contractual and Legitimate Business Interest, the Data may be transferred to the following third parties that perform functional activities to those who provide services and/or products requested by you, located inside and outside the European Union:

a)    third-party suppliers of assistance and consultancy services for the Company with reference to the activities of the (purely by way of example) technological, accounting, administrative, legal, insurance sectors;

b)     in cases where the provision of the requested services and/or products involves the intervention of our business partners, the Company may share certain Data with the distributors and partners in the distribution chain of the Company's products and services;

c)    individuals and authorities whose right of access to the Data is expressly recognized by law, regulations or provisions issued by the competent authorities.

 

For the Purposes of Marketing and for the Purposes of Legitimate Marketing Interests, the Data may be transferred to the following categories of recipients, located inside and outside the European Union:

a)    third parties in charge of the processing of data providing assistance and consultancy services for the Company with reference to the activities of sending marketing communications;

These recipients, depending on the case, process the Customer Data as data controllers or person in charge of processing. The complete and updated list of individuals processing the Data as data controllers is available upon request to the Person in Charge of Data Protection, according to the contact methods indicated in this statement.

 

8.      Transfer of data abroad

The Data may be freely transferred outside the national territory to countries located in the European Union.

In the event that the Customer wishes to obtain more information about the existing guarantees and request a copy of the same, he may contact the Company at any time in the manner indicated in this statement.

 

9.      Customer's rights

In relation to the processing of the Data described in this statement, the Customer may exercise at any time the rights envisaged by the GDPR (articles 15-21), including:

−                  receive confirmation of the existence of the Data and access their content (right of access);

−                  update, modify and/or correct the Data (right of rectification);

−                  request cancellation or limitation of the processing of the data processed unlawfully including those that do not need to be kept in relation to the purposes for which the Data were collected or otherwise processed (right to be forgotten and the right to limitation);

−                  object to the treatment (right of objection);

−                  revoke the consent, where given, without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation;

−                  submit a complaint to the Control Authority (Authority for the Protection of Personal Data www.garanteprivacy.it) for infringement of the rules on personal data protection; 

−                  receive an electronic copy of the Data relating to it, to transfer it to itself or to a different service provider, in the event that the Company processes such Data on the basis of its consent or on the basis that the processing is necessary for the provision of the requested services and/or products and the Data are processed using automated tools (right to data portability).

 

The Data may be freely transferred outside the national territory to countries located in the European Union.

In the event that the Customer wishes to obtain more information about the existing guarantees and request a copy of the same, he may contact the Company at any time in the manner indicated in this statement.

 

To exercise these rights, the Customer may contact the Responsible for Data Protection, by sending a request to the e-mail address nettuno@nettuno.net, or by mail to:

 

Nettuno srl

Viale Industria 16/18

24060 Castelli Calepio (Bg)

Attn.: Responsible for Data Protection

 

When contacting us, the Customer must ascertain to include their name, email/postal address and/or telephone number(s) to be sure that their request can be properly handled.

 

10.   Changes and updates

This information may be subject to changes also as a result of any changes and/or regulatory additions. Any changes will be notified in advance.