POLICY FOR THE PROCESSING OF PERSONAL DATA
LAST TECHNOLOGY S.r.l., with registered office in via Sagree 9 – 33080 Prata di Pordenone (PN), Fiscal Code and VAT IT-01747780938 (hereafter, “Controller”), as the controller of processing, informs you that, in accordance with art. 13 D.Lgs. 30.6.2003 n. 196 (hereafter, “Privacy Code”) and with art. 13 Regulation UE n. 2016/679 (hereafter, “GDPR”), your data will be processed with the following procedures and purposes:
1. Processing subject
The Controller processes the personal identification data (for example, name, surname, business name, address, phone, e-mail, bank and payment reference, interests, other personal data, web site use) – hereafter, “personal data” or also “data”) collected on the current web site, through app, or as a result of the assistance and pre- and post-selling activities.
2. Information collected through automated means
a) Information of Analytics
We use web analysis services of third parties (like the ones of Google Analytics) on our Web site to collect and analyze the use information through cookies and similar instruments and assist the fraud prevention.
b) Online advertisement
We can allow to third parties, including advertisement companies (like Facebook, Google, Twitter, LinkedIn), to insert cookies on our web site. These cookies permit to aforementioned societies to trace your activity on various sites that display ads and to record your activities in order to show you ads that they believe be relevant for you while you surf the web.
c) Information collected from social media and other content platforms
3. Processing purposes
The collected data are finalized for the fulfillment of the following purposes:
• conclusion of contracts and assignments;
• management of the archive and mailing;
• fulfillment of pre-contractual, contractual and fiscal obligations deriving from relations with you;
• fulfillment of legal obligations, regulations, and Community legislation or other obligations provided by the Authorities;
• download of documents related to products of your interest;
• fulfillment of all the provided communications resulting from above-mentioned activities.
Only prior to your specific and distinct agreement (Article 23 and 130 Privacy Code and Article 7 GDPR), for the following Marketing Purposes:
• Customer Satisfaction surveys;
• Sending to you through e-mail, newsletters, commercial communications and/or ads about products or services given by the Controller and detection of the degree of satisfaction with the quality of services;
• Communication of initiatives and events through e-mail.
Your agreement can be cancelled in any moment by writing to the following e-mail address: firstname.lastname@example.org
4. Processing procedures
In relation to the specified purposes, the data are subject to computer (electronic and automated) and paper processing. The processing operations are carried out so as to guarantee the logical, physical and confidential security of the data.
Where we have provided you with a password that grants you access to our website, applications or services we supply, you will be responsible for the confidentiality of this password and for compliance with any other security procedure that we may disclose. We ask you not to share your password with anyone.
The Controller will process your personal data only for the necessary time to fulfill the aforementioned purposes or for any other legitimate related purpose. However, we will no longer process personal data for those purposes whose retention period has failed.
5. Nature of Personal data
The data related to the performance of the contract and/or assignment between the parties is subject to processing. If it is necessary to acquire and carry out processing operations of sensitive and judicial personal data during the execution of the contract and/or assignment, you will be specifically requested to express the relevant consent by writing it.
The Controller will process personal data for the time necessary to fulfill the aforementioned contractual and operational purposes and in any case for no more than 10 years from the termination of the relation and for no more than 24 months from the collection of data for Marketing Purposes.
6. Mandatory or non-mandatory nature of the contribution
The data contribution has not mandatory nature, but the eventual refusal of communication, or an incorrect communication, could make it difficult to perform the contract and/or assignment and fulfill the obligations imposed by the fiscal, administrative or labour legislation which it is subject to.
7. Data accessibility and communication
Personal data may be communicated in Italy or abroad for the purposes set out in the “Processing Purpose” paragraph and may be made available to:
• All the subjects whom faculty of access to such data is recognized under regulatory provisions,
• Our collaborators, employees and consultants in relation to their duties and activities;
• Third companies or other subjects (professional firms, consultants, etc.) who carry out outsourcing activities on behalf of the Controller, acting as external data processing managers;
• Service providers for the management of the information system and telecommunication networks;
• Service providers for the management of paper or computerized documents archiving (MailChimp);
The above mentioned subjects will process the data acting as managers for Last Technology srl or as independent controllers in compliance with the legal provisions.
Without the need for an express consent (ex.art.24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Controller might communicate your data for the purposes referred to in point 2 to judicial authorities, as well as to those subjects whom the communication is obligatory by law for the accomplishment of said purposes.
8. Data transfer
Personal data management takes place on servers located in Prata di Pordenone, Via Sagree 9, or in the availability of the process controller and/or third companies in charge, duly mentioned as processors, as well as in the cloud.
9. Identification details of the controller, managers and people in charge of data processing
The data processing controller is Last Technology srl, with premises in Prata di Pordenone (PN), Via Sagree, 9 (Italy).
The updated list of managers and people in charge of processing is kept at the registered office of the processing controller.
For further questions about the processing of your personal data by our part, you can write to email@example.com.
10. Rights of the involved person
Acting as an interested party, you have the rights referred to in Article 7 of the Privacy Code and Article 15 of the GDPR, and specifically the rights to:
• obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
• obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of treatment carried out with electronic instruments; d) of the identification details of the Controller, the managers and the appointed representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects whom the personal data might be communicated or who may become aware of it acting as designated representatives in the territory of the State, managers or appointees;
• obtain: a) updates, rectifications that is, when interested, data integration; b) the cancellation, transformation into anonymous form or blocking of data processed in infringement of law, including data whose conservation is unnecessary in relation to the purposes for which the data were collected or later processed; c) the attestation that the operations referred to letters a) and b) have been brought to the attention, also as regards their content, of those whom the data have been communicated or spread, except in the case where such fulfillment is proved to be impossible or involves a use of means which are clearly unproportioned to the protected rights;
• object, whole or in part: a) for reasons legitimate to the processing of personal data concerning you, although pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communications, by e-mail and/or through traditional marketing methods.
Where applicable, you have also the rights referred to in Articles 16-21 GDPR (Right of rectification, right of oblivion, right of limitation of processing, right of data portability, right of opposition), as well as the right of complaint to the Competition Authority.
Competition authority for the protection of personal data,
Piazza di Montecitorio n. 121,
00186, Roma (RM).
Telephone: (+39) 06.696771 – Fax: (+39) 06.69677.3785
Certified e-mail: firstname.lastname@example.org