's Privacy Notice for Customers Regarding the Processing of Personal Data
In compliance with the requirements set forth in Regulation (EU) 2016/679 (GDPR) and Legislative Decree No. 196 of June 30, 2003 (Personal Data Protection Code), we hereby wish to inform you of the following.
The processing of personal data, whether voluntarily provided by you or collected in any other manner, will be carried out in compliance with applicable privacy regulations; it will be based on the principles of fairness, lawfulness, and transparency, and conducted in accordance with the principles of relevance, completeness, and data minimization. The data will be collected, recorded, and stored solely for the purposes set forth in point 1).
1) PERSONAL DATA PROCESSED, PURPOSES, AND LEGAL BASIS FOR PROCESSING
“Data” refers to data relating to natural persons processed by INFO-BIT S.R.L. for the purpose of entering into and performing the contractual relationship with its clients, such as data directly attributable to the client who is a natural person or sole proprietorship, or the legal representative of the corporate client, the client’s employees/consultants involved in the activities covered by the contract, as well as any other information necessary for the performance of the contract and/or the provision of the service. In particular, such Data will be processed for the purposes indicated below.
Management of contractual/commercial relationships, including: fulfilling specific customer requests prior to the conclusion of the contract; conclusion, amendment, and performance of the contract; provision and management of related services; and handling of complaints. The legal basis for processing in relation to the aforementioned purposes is the fulfillment of contractual obligations and/or the implementation of pre-contractual measures taken at the request of the data subject.
Administrative and accounting purposes, such as: invoicing; managing payments, late payments, and non-payments. The legal bases for processing in relation to the aforementioned purposes are: – the need to comply with the legal obligation to maintain accounting records; – the fulfillment of contractual obligations.
Compliance with legal obligations under national or European Union law or under collective bargaining agreements in accordance with national law, such as: compliance with obligations under EU and national regulations, particularly regarding occupational health and safety, and the prevention of criminal offenses (anti-mafia and anti-corruption regulations, Legislative Decree 231/2001). The legal basis for the processing is the need to comply with a legal obligation to which the data controller is subject.
Exercising and/or defending rights in court and debt collection, including: handling any legal disputes, protecting and collecting debts, either directly or through third parties (lawyers/agencies/debt collection firms). The legal basis for the processing is legitimate interest.
Promotional or marketing activities, such as, for example, sending commercial/promotional communications via automated means of contact (such as email, SMS, or MMS) and traditional methods (such as phone calls with an operator and regular mail) regarding the services offered by INFO-BIT S.R.L., notifications of company events, sending newsletters and informational/promotional materials, as well as conducting market research. The legal basis for the processing is the data subject’s consent (which is optional and may be revoked at any time).
2) RETENTION PERIOD
The data will be processed for the duration of the contractual relationship and, following its termination, until the statute of limitations expires on the rights arising between the parties. In the event of a legal dispute, for the entire duration of the dispute and until the final judgment becomes binding. With regard to processing for the purposes referred to in point 1.E (promotional or marketing activities), processing will continue until the data subject revokes their consent.
3) METHODS OF DATA PROCESSING
Personal data may be processed using both analog and electronic means, or automated methods, in accordance with the methods and procedures strictly necessary to achieve the purposes described above. Processing may involve the following operations: collection, recording, organization, storage, consultation, use, processing, modification, selection, extraction, comparison, interconnection, transmission, communication, dissemination, erasure, destruction, blocking, and restriction.
4) SCOPE OF DISCLOSURE, PARTIES AUTHORIZED TO PROCESS DATA
The Data may be disclosed to external parties acting as independent data controllers, such as public or private entities authorized to process the Data (e.g., public administrations, banks and credit institutions, accountants, notaries, attorneys, and other professionals). The Data may be processed, on behalf of the data controller, by external parties designated as data processors, who perform specific activities on behalf of the data controller, such as, for example, its distribution network, companies and agents that perform debt collection activities for the data controller, and legal, tax, and administrative consultants. The Data may be processed by employees of the company departments responsible for pursuing the purposes indicated above, who have been expressly authorized to process the Data and who have received adequate operational instructions. The Data will not be disclosed.
5) DATA PROVISION
If the data subject refuses to provide personal data, this may make it impossible (either partially or entirely) to comply with legal obligations, or to enter into or properly perform the contract or service. In such a case, without prejudice to the data subject’s right not to provide their data, the Data Controller reserves the right to suspend, terminate, or refrain from entering into the contractual relationship.
6) DATA CONTROLLER
The Data Controller is INFO-BIT S.R.L., VAT No. and Tax ID 02068670161, with registered office at Via del Fabricone, 17/G – 240060 Gorlago (BG), Certified Email Address: amministrazione@pec.info-bit.com. The Data Controller may process the data directly, through its authorized employees, or by engaging external collaborators, who in such cases assume the role of Data Processors. The updated list of Data Processors is made available by the Data Controller upon request.
7) RIGHTS OF THE DATA SUBJECT
The regulations on the protection of personal data (Articles 12–22 of EU Regulation 679/2016) guarantee the data subject the right to be informed about the processing of their data and the right to access such data at any time and to request its updating, supplementation, and correction. Where the conditions set forth in the legislation apply, the data subject may also exercise the right to erasure of the data, to restriction of processing, to data portability, to object to processing, and not to be subject to decisions based solely on automated processing. If the processing of personal data is based on the data subject’s consent, the data subject has the right to withdraw the consent given. To exercise their rights, as well as for more detailed information regarding the processing of Data, the data subject may contact INFO-BIT S.R.L. by writing to the email address: amministrazione@pec.info-bit.com. If the data subject believes their rights have been infringed, they may seek redress by filing a complaint with the Data Protection Authority.
8) PROCESSING OF THIRD-PARTY DATA
The customer is hereby informed that, should they engage their own employees or collaborators (including any subcontractors) in the performance of the contractual relationship, the personal data of such individuals may be processed by INFO-BIT S.R.L., acting as the data controller, for the purposes set forth in section 1. Such processing has the same purposes, methods, and data retention periods as described in this policy; furthermore, with regard to such processing, the data subjects have the same rights as those identified in point 7. The customer is responsible for properly informing its employees and collaborators regarding the aforementioned processing, including by providing them with this policy.