This is an English translation provided for convenience. In case of any discrepancy, the Italian version shall prevail.
INFORMATION NOTICE AND CONSENT TO THE PROCESSING OF PERSONAL DATA
PURSUANT TO ART. 13 OF ITALIAN LEGISLATIVE DECREE NO. 196 OF 30 JUNE 2003 AND ARTS. 13 AND 14 OF EU REGULATION 2016/679 OF 27 APRIL 2016 In accordance with art. 13 of Italian Legislative Decree no. 196 of 30 June 2003 (“Personal Data Protection Code” – hereinafter the “Privacy Code”) and arts. 13 and 14 of EU Regulation 2016/679 of 27 April 2016 (“General Data Protection Regulation” – hereinafter the “EU Regulation”), we inform you that NOON SRL holds data relating to you that qualify as “personal data”. Since the above regulations require data subjects to be informed about which data are processed and how they are processed – which must in any case be done fairly, lawfully and transparently, protecting your confidentiality and your rights – we hereby provide the following information:
- Nature and source of the data processed
We process your personal and tax details (relating to the business and/or company and its shareholders and directors), as well as economic and commercial data and your email addresses, both ordinary and certified (PEC). We also process sensitive data that may reveal racial and ethnic origin, but only where this can be inferred from your identity documents. The data we process are provided directly by you or obtained from publicly accessible sources (e.g. the Chamber of Commerce).
- Purposes and duration of processing
Your data are processed for the following purposes:
A – To carry out the pre-contractual and contractual relationships in place with you and to fulfil the resulting administrative, legal and tax obligations, as well as to enable effective management of financial and commercial relationships and to exercise or enforce our rights. Your data may also be processed for internal purposes such as statistical indicators, customer satisfaction and the effectiveness of managing commercial relationships with customers and suppliers.
B – To send commercial and promotional information, direct sales and market research on products, services and events (collectively “marketing activities”). The data will be processed for the entire duration of the contractual relationship and afterwards to fulfil legal obligations and for the purposes indicated above, and in any case for no longer than 10 years from the end of the relationship for the purposes under letter A and no longer than 2 years for the purposes under letter B.
- Processing methods
All processing complies with arts. 5 and 6 of the EU Regulation and arts. 11, 31 et seq. of the Privacy Code, and adopts the minimum security measures set out in the technical specifications (Annex B to the Code). Data are processed using tools and procedures that ensure their security and confidentiality, and may be processed both on paper and with the aid of IT and electronic tools, by persons specifically authorised to do so. Processing includes:
- entering or updating data in our electronic and paper databases;
- archiving received documents electronically or on paper;
- automated processing by computer;
- manual processing using paper archives.
Processing for “marketing activities” will be carried out by traditional means (post) and by remote communication techniques such as telephone (including automated calls), email and messaging.
- Scope of communication and disclosure
Data are processed in relation to the direct needs of the relationships in place and the resulting administrative, legal and tax obligations, to exercise or enforce our rights, and for the “marketing activities” indicated above. Your data may also be processed for purely internal purposes and will not be disclosed to unspecified parties in any way, including by making them available or accessible for consultation. Your data will be processed internally by the company’s staff in the following categories of authorised persons:
- Administration office;
- Sales office;
- Accounts office;
Your data may, however, be disclosed by us to one or more specified parties, always within the European Union, as follows:
- to persons within our Company authorised to process your data, in particular staff in the customer administration, purchasing, accounts and secretarial offices;
- to parties entitled to access the data under the law, regulations or EU legislation, within the limits laid down by such rules;
- to parties who need to access your data for purposes ancillary to the relationship between you and us, strictly as needed to carry out the ancillary tasks entrusted to them (for example, banks and shipping companies);
- to professionals we engage to carry out activities relating to the contractual relationship between you and us (e.g. lawyers, accountants);
- to our consultants, as needed to carry out their assignment for our Company, subject to our letter of appointment imposing a duty of confidentiality and security in processing your data;
- to the parties indicated in the “Information Sheet”, for the purposes specified therein.
Your data will be stored at the company’s premises or at the premises of external professionals or consultants as indicated above.
- Nature of the provision of data
A – With regard to the purposes under point 2 A, without prejudice to your right to consent to the processing of your data, for the data we are required to know in order to fulfil the obligations arising from our pre-contractual and contractual relationships, from laws, regulations and EU legislation, or from instructions issued by competent authorities, failure to provide, or incorrect provision of, any mandatory information will result in:
- the impossibility of establishing and continuing the contractual relationship to the extent that such data are necessary for its performance;
- the possible failure of the processing to meet the tax, administrative and employment obligations it is intended to fulfil.
B – With regard to the purposes under point 2 B, providing the relevant data is optional.
- Your rights
You may exercise your rights as provided for by arts. 7 et seq. of the Privacy Code and arts. 15 et seq. of the EU Regulation by contacting the Data Controller. In particular, you have the right to obtain information on:
- the existence of any ongoing processing of personal data concerning you;
- the origin and categories of the personal data;
- the purposes and methods of processing;
- the intended retention period of the personal data;
- the existence of automated decision-making (including profiling) and the logic applied where processing is carried out with electronic tools;
- the parties or categories of parties to whom the personal data may be communicated;
- the parties or categories of parties who may become aware of the personal data as designated representative in the territory of the State, processors or persons in charge of processing;
- the identification details of the controller and, where appointed, of the processors, designated representatives and persons in charge of processing;
- where personal data are transferred to a third country or an international organisation, information on the existence of adequate safeguards under art. 46 of the EU Regulation.
You have the right to:
- obtain the updating, rectification or, where you have an interest, the integration of the data;
- obtain the erasure, restriction, anonymisation or blocking of data processed unlawfully, including data whose retention is not necessary for the purposes for which they were collected or subsequently processed;
- obtain certification that the above operations have been brought to the attention of those to whom the data were communicated, including as regards their content, unless this proves impossible or involves a manifestly disproportionate effort compared with the right protected;
- request data portability, in accordance with art. 20 of the EU Regulation;
- request a copy of the personal data being processed;
- withdraw your consent to the processing of your data, without prejudice to art. 5 letter A of this notice and to the lawfulness of processing based on consent given before withdrawal;
- lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) to protect your rights.
You have the right to object, in whole or in part:
- on legitimate grounds, to the processing of personal data concerning you, even if relevant to the purpose of collection;
- to the processing of personal data concerning you for the purpose of sending advertising material or direct sales, or for market research or commercial communications.
- Data Controller
The Data Controller of your personal data is NOON SRL, based in Palermo (PA), via Lucio Piccolo, 7 – represented by its legal representative, domiciled at the registered office – tel. 091.5556851, email INFO@MYNOON.IT
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