Privacy Policy

/Privacy Policy
Privacy Policy 2018-11-01T16:54:19+00:00

Dear Mr/Mrs

We wish to inform you that the EU Regulation 2016/679 (“European regulation on the protection of personal data) provides for the protection of people and other subjects and respect for the processing of personal data.
In accordante with artiche 13 and 14, therefore, we provide the following information:

1.Purposes, legal basis of the processing for which the data are intended

The processing of personal data supplied by you  is aimed solely of fulfilling contractual obligations and fulfilling specific requests, as well as fulfilling regulatory obligations, in particular accounting and tax obligations.The legal basis of the processing means the source / origin / justification of the treatment in a legal provision, in the fulfillment of a contract, in the satisfaction of a request by the interested party. If there is a legal or contractual obligation, more precise information must be provided.
For the purpose of the indicated processing, the holder may become aware of data defined as “sensitive” pursuant to EU Reg. 2016/679, such as those suitable for revealing the racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations of religious, philosophical, political or trade union organizations, health status and sexual life.


2. Methods of processingIn relation to the indicated purposes, your data are processed electronically and on paper. The processing operations are carried out in such a way as to guarantee the logical, physical security and confidentiality of your personal data.


3. Legitimate interests pursued by the data controller or third parties 4. Nature of personal dataYour personal data, sensitive and judicial, concerning the performance of the service requested by you are processed.During the provision of the service it may be necessary to acquire and carry out processing operations of your sensitive and judicial personal data. You are asked to express your consent in writing.


5. Mandatory or optional nature of the contributionThe provision of your personal and sensitive data is not mandatory, but any refusal could make it impossible or extremely difficult to provide the services you requested. 6. Scope of communication and dissemination of dataYour data may be communicated to:• all the subjects to whom the right of access to such data is recognized by virtue of regulatory provisions;• to our collaborators, employees, as part of their duties;• to all those natural and / or legal persons, public and / or private, when the communication is necessary or functional to the performance of our activity and in the manner and for the purposes illustrated above;


7. Transfer of personal data to a third countryTo be completed only if the transfer of non-EU data or international organizations is foreseen. If so, it is necessary to insert whether or not an adequacy decision of the EU Commission exists. In the absence of such an adequacy decision, appropriate and appropriate safeguards must be included, and the description of the modalities for obtaining a copy of such data and of the place where they have been made available must be reported. 8. Mode and duration of personal data retentionDepending on the purpose of the processing, the organization must first define the data retention time. In case it is not possible to determine this period, it is necessary to indicate the criteria to determine it. 6. Extreme identification of the owner, manager and Privacy OfficerInsert name, surname, address and email address


  1. Rights of the interested party

7.1 Article 15 (right of access), 16 (right of rectification) of EU Reg. 2016/679

The interested party has the right to obtain from the data controller confirmation that it is or is not undergoing the processing of personal data concerning him and in this case, to obtain access to personal data and the following information:

  1. a) the purposes of the processing;
  2. b) the categories of personal data in question;
  3. c) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if recipients of third countries or international organizations;
  4. d) the retention period of the personal data provided or, if not possible, the criteria used to determine this period;
  5. e) the existence of the right of the interested party to request the data controller to rectify or delete personal data or limit the processing of personal data concerning him or to oppose their treatment;
  6. f) the right to lodge a complaint with a supervisory


  1. h) the existence of an automated decision-making process, including profiling and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the data subject.


7.2 Right pursuant to art. 17 of EU Reg. 2016/679 – right to cancellation (“right to be forgotten”)

 The data subject has the right to obtain from the data controller the deletion of personal data concerning him without undue delay and the data controller is obliged to cancel the personal data without undue delay if one of the following reasons exists:

  1. a) personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;

(b) the data subject revokes the consent on which the processing is based in accordance with Article 6 (1) (a) or Article 9 (2) (a) and whether there is no other legal basis for the processing ;

(c) the data subject opposes the processing pursuant to Article 21 (1) and there is no legitimate overriding reason to proceed with the processing, or opposes the processing pursuant to Article 21 (2);

  1. d) personal data have been processed unlawfully;
  2. e) personal data must be deleted to fulfill a legal obligation under Union or Member State law to which the controller is subject;
  3. f) personal data have been collected in relation to the information society service offer referred to in Article 8, paragraph 1 of EU Reg. 2016/679


7.3 Right referred to in art. 18 Right of limitation of treatment

The interested party has the right to obtain from the data controller the limitation of processing when one of the following hypotheses occurs:

  1. a) the interested party disputes the accuracy of personal data for the period necessary for the data controller to verify the accuracy of such personal data;
  2. b) the processing is illegal and the interested party opposes the cancellation of personal data and asks instead that its use is limited;
  3. c) although the data controller no longer needs it for processing purposes, personal data are necessary for the data subject to verify, exercise or defend a right in court;
  4. d) the interested party has opposed the treatment pursuant to article 21, paragraph 1, Reg EU 2016/679 pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party.

7.4 Right referred to in Article 20 Right to data portability

 The data subject has the right to receive, in a structured, commonly used and automatically readable form, the personal data concerning him / her provided to a data controller and has the right to transmit such data to another data controller without impediments from part of the data controller


  1. Revocation of consent to treatment

You have the right to withdraw your consent to the processing of your personal data by sending a registered letter to the following address: [ADDRESS] accompanied by a photocopy of your identity document, with the following text: << withdrawal of consent to the processing of all my personal data >>. At the end of this operation your personal data will be removed from the archives as soon as possible.

If you would like more information on the processing of your personal data, or exercise the rights referred to in paragraph 7 above, you can send a registered letter to the following address: [ADDRESS]. Before we can provide you, or change any information, you may need to verify your identity and answer some questions. An answer will be provided as soon as possible.