PRIVACY INFORMATION POLICY
In this page Faentia Consulting S.r.l.describes its data processing policy in regard to the mailing of its newsletter (the "Newsletter").
For any doubts please contact us at firstname.lastname@example.org.
WHY THIS INFORMATION POLICY?
On 25 May 2018 new privacy rules were introduced according to the EU Regulation no. 2016/679 (General Data Protection Regulation, hereinafter GDPR), which will apply in all the member States of the European Union alongside national laws.
GDPR provides for increased protection of users and for new obligations and responsibilities for those who process personal data, also obtained through websites.
To learn more about GDPR you can refer to the useful and detailed specific section by the Italian Data Protection Authority: it will help you better understand the new rules and learn about your rights.
A key principle is that of transparency: users must be informed in advance, in a clear and exhaustive manner, of what personal information concerning them will be collected, who will handle it, for what reasons and for how long, if it will be used for commercial purposes, or for profiling purposes, if it will be disclosed to third parties, etc. and be able to control their data management in a straightforward and effective manner.
This information policy is established in accordance with Article 13 of GDPR and is also based on the Group Guidelines, Article 29 on Transparency.
This information notice is intended for users who subscribe to the Newsletter, supplying their e-mail contacts to Faentia Consulting S.r.l.
Since, for subscription to the newsletter, personal data will be acquired and processed according to GDPR, you will find here below detailed information on how Faentia Consulting S.r.l. is going to process your personal data.
DATA CONTROLLER AND CONTACTS
Your Data Controller is Faentia Consulting S.r.l., tax code and VAT 02005380395, Economic and Administrative Index REA RA-163827, which can be contacted at:
- Registered Office: Via Firenze, 3 - 48018 Faenza (RA)
- Mail: email@example.com
- PEC (certified e-mail): firstname.lastname@example.org
DATA PROTECTION OFFICER (DPO)
Faentia Consulting S.r.l. hereby informs users that it has not appointed a Data Protection Officer (DPO), as it does not carry out any data processing that requires it by law, and in particular, it does not carry out processing of data which, due to its nature, scope and/or purpose, requires large-scale regular and systematic monitoring of data subjects, or large-scale processing of special categories of personal data referred to in Article 9 of GDPR or of data relating to criminal convictions and offences referred to in Article 10 of GDPR.
TYPES OF PROCESSED DATA
Faentia Consulting S.r.l. will ask you to send your name, surname and e-mail address - the submission of this information being necessary to send you the Newsletter. No additional personal data will be required.
Faentia Consulting S.r.l. will ask you to confirm that you are over the age of 16 and will only allow you to subscribe to its Newsletter after you have confirmed this requirement.
Faentia Consulting S.r.l. will treat the submitted data with the utmost confidentiality, in compliance with the current legislation and exclusively for the purposes specified below.
PURPOSE AND LEGAL BASIS OF DATA PROCESSING
Your personal data submitted for subscription to the Newsletter will be processed by Faentia Consulting S.r.l. exclusively for the purpose of sending you the Newsletter.
The legal basis for processing your data is your consent as the data subject, obtained in accordance with the GDPR.
You may, at any time, decide to withdraw your consent. In this case, Faentia Consulting S.r.l. will no longer send its Newsletters in the future.
Withdrawing your consent will be possible in the same, simple manner in which consent was provided.
RECIPIENTS OF PERSONAL DATA
Your personal data acquired and processed by Faentia Consulting S.r.l. for the management and sending of the Newsletter will be processed exclusively by:
- employees and partners of Faentia Consulting S.r.l. duly authorised
- suppliers of IT services related to the management and operation of the Faentia Consulting S.r.l. website and of its mailing list service (currently MailChimp, designated in writing as the Data Processor)
- hosting service providers
- any personnel appointed to carry out occasional maintenance and repair operations.
Your data may also be forwarded to the competent Authorities where necessary or required by law.
Your data will not be generally disseminated in any way.
INTENTION TO TRANSFER DATA TO A THIRD-PARTY COUNTRY OR AN INTERNATIONAL ORGANISATION
Your personal data acquired by Faentia Consulting S.r.l. for the management and sending of its Newsletter will be processed and kept on servers located in Italy.
Your personal data may also be transferred to servers located in other European and non-European countries as providers of IT service and software used by Faentia Consulting S.r.l. - previously listed as recipients (e.g. mailing list service)
- if this is specified in their Terms and Conditions of Use and due to the use of cloud computing technology which by its very nature cannot determine with certainty the location of data.
Please note that according to the law, presently the European Commission has provided for an adequacy decision only for a limited number of States (Andorra, Argentina, Australia, PNR, Canada, Faer Oer, Guernsey, Isle of Man, Israel, Jersey, New Zealand, Switzerland, Uruguay) and that therefore, your personal data could be transferred by the Services used also to Countries for which such an adequacy decision has not been published, and also that in the current state of things, Faentia Consulting S.r.l. is unable to autonomously provide adequate guarantees.
However, please be reminded that Faentia Consulting S.r.l. has carefully selected only service providers able to offer a high level of security and protection of personal data.
DATA STORAGE PERIOD
Your personal data acquired and processed by Faentia Consulting S.r.l. for the management and sending of the Newsletter will be stored throughout the subscription time.
When you decide to unsubscribe from the Newsletter, your e-mail will be automatically moved to a black list of contacts no longer to be used. This is an automatic procedure established by the mailing list service providers. Faentia Consulting S.r.l., to guarantee and protect your rights and your personal data, will periodically manually destroy the blacklisted database. This will be done every two weeks.
YOUR RIGHTS AS A DATA SUBJECT
Please be informed that, as the data subject, you will enjoy all the rights provided by the GDPR i.e.:
- Right of Access (art. 15)
- Right to Rectification (art. 16)
- Right to Erasure (a.k.a. "Right to be Forgotten" (art. 17)
- Right to Restriction of processing (art. 18)
- Right to have the Controller notify the recipients of the rectification or erasure (art. 19)
- Right to data portability (art. 20)
- Right to object (art. 21)
You also have the right to withdraw at any time the consent given to the processing of your data; such withdrawal shall be effective as soon as Faentia Consulting S.r.l. becomes aware of it.
Please be reminded that according to GDPR terms, withdrawal will not affect the lawfulness of processing based on previously given consent.
Finally, the data subject has the right to file a complaint with a control authority, as specified below. The national Authority is the Italian Data Protection Authority, which can be contacted by following the link http://www.garanteprivacy.it/web/guest/home/footer/contatti.
In all the cases described, the exercise of your rights is brought to the knowledge of those to whom your data had been notified, except for any exemptions provided by the GDPR, referring to the link http://www.garanteprivacy.it/regolamentoue/diritti-degli-interested for any data subject rights content.
In some cases (erasure, restriction, objection) the exercise of your rights may make it not possible, in whole or in part, to meet your requests submitted in the Form, nor to provide any of the requested actions and/or services for your benefit.
All the above-described rights are exercised by submitting an informal request to Faentia Consulting S.r.l., or by mail to the address email@example.com also through a person in charge who will be given prompt feedback.
RIGHT TO WITHDRAW CONSENT
The data subject may at any time withdraw the consent previously granted, in the same way in which it had been expressed, or in any case, by e-mail, sending the withdrawal notice to the following address firstname.lastname@example.org.
The e-mail will be effective on reaching its recipient, therefore, upon its receipt it will allow to suspend any processing and to notify all recipients of your data (e.g. the mailing list service) that they must conform to its requirements.
Please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
Each party concerned has the right, in case of violation of its rights and freedom, to submit a web-based complaint to the Protection Authority, by filling out the special form, available on the website www.garanteprivacy.it.
OBLIGATION TO SUBMIT PERSONAL DATA
Aside from what is specified for navigation data, as a data subject you are free to submit, or not, your personal data to Faentia Consulting S.r.l.
If you wish to subscribe to the Newsletter, however, you will be requested to provide to us your name, surname and your e-mail address.
Failure to submit your requested data, i.e. name, surname and e-mail address, will make it impossible to subscribe to our Newsletter.
PROFILING AND AUTOMATED DECISION MAKING PROCESSES
The personal data freely and voluntarily submitted by you for subscription to our Newsletter will not be used for profiling purposes, nor for activating automated decision-making processes.
The Data Controller shall adopt appropriate technical and organisational security measures, in accordance with the provisions of GDPR, in order to minimise the risks to your personal data, such as destruction or loss, including accidental, unauthorised access or processing in manners not allowed or not in accordance with the collection purposes, as defined in this Information policy.
Data processing will be carried out in compliance with the provisions of art. 32 of GDPR and will take place via IT and web-based means, as well as manual and paper media.
The data will be stored in electronic and paper archives, for a time not exceeding the processing duration and requirements as defined in this information policy regarding the collection of your personal data.
With periodic checks, the Controller will verify that the collected data are strictly relevant to and not exceeding the processing obligations and purposes.
INFORMATION POLICY CHANGES
This information notice may be amended if new functions are added to the Website Services of Faentia Consulting S.r.l. and/or to integrate feedback sent by our users in the form of comments and suggestions.
This Information notice may be changed at any time by publishing an updated version on the Faentia Consulting S.r.l. website - effective from the publishing date of same.
Should this information change during the period of time in which we are in contact with you, we will see to informing you thereof.