Pursuant to the provisions of article 13 of European Regulation 2016/679 on the protection of personal data (“GDPR”) and of Italian data protection legislation, we would like to inform you that your personal data will be processed using electronic and manual means and social media, in Italy and abroad. This privacy policy has been drawn up on the basis of the principle of transparency and all the other requirements specified in the GDPR and is divided into individual sections. Each section deals with a specific top for faster reading and better understanding (hereinafter the “Policy”).

WHO IS THE DATA CONTROLLER?

The Data Controller (hereinafter “Data Controller”) is Minuterie di precisione s.n.c., with registered office i Via Postumia di Sala 1 31040 Gorgo al Monticano (TV) - +39 (0)422 800081.

DATA PROTECTION OFFICER

The Data Controller has not appointed a DPO under article 38, however you may contact the privacy office for all matters relating to the processing of your personal data and if you wish to exercise your rights as set forth in the GDPR at the following email address:
info@minuterieprecisione.com

WHAT IS THE LEGAL BASIS FOR THE PROCESSING?

The legal basis for the processing of your personal data is:

• Contractual obligations and execution;
• Legal obligations.

FOR WHAT PURPOSES WILL YOUR PERSONAL DATA BE PROCESSED?

a) Your personal data will be processed for the purposes of managing the service and fulfilling legal obligations:

1. Execution of the supply contract or supply order.
2. Invoicing the amounts due and any additional services.
3. Compliance with regulatory obligations, including accounting, administrative and tax obligations.
4. Dealing with any complaints or disputes that may arise.
5. Fraud prevention and dealing with delayed or missed payments.
6. Debt protection and collection if necessary, either directly or through third parties (debt collection agencies/companies, law firms) to which your data necessary for these purposes will be communicated.
7. Transfer of receivables to authorised companies.
8. Preservation and use of accounting data related to the punctuality of payments for reward polices and to reject future contractual relationships.
9. Reporting, quality control and certification.

b) Furthermore, you can give your optional consent to your personal data being processed for:

1. Commercial communications: communication and/or sending (by email, SMS, post, notifications, telephone contact, etc.), also using automated means, of information, sales offers, advertising and promotional material about own services and/or third-party services.

The provision of your data is necessary to achieve the purposes referred to in point a). Failure to provide your data or partial or incorrect provision of the same could result in the impossibility of activating and providing the requested service or executing the maintenance and/or assistance contract. Furthermore, provision of your data for the purposes set out in point b) is optional but should you not consent to it, Minuterie di precisione s.n.c. will not be able to carry out your request and contact you. In any case and as explained below, you may withdraw your consent, even in part, for example consenting to receive notification about events but not commercial information.

WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA?

Your personal data will be processed exclusively by authorised persons and by persons designated as Data Processors in compliance with the GDPR in order to perform all the processing activities necessary to pursue the purposes set out in this Policy. Your personal data may be disclosed to public organisations or judicial authorities, where required by law or to prevent or suppress the commission of criminal offences and in any case to:

• the legitimate recipients of communications required by law or regulations (such as, for example, offices and public authorities);
• the recipients of necessary communications for the fulfilment of obligations arising from the supply and from the contract stipulated;
• third-party companies specialised in the management of commercial and credit information (such as, for example, call centres, data processing centres, banks, etc.);
• companies and/or collaborators in order to carry out the administrative services necessary to fulfil their legal or contractual obligations;
• other subjects (businesses, companies and physical persons) who collaborate with the Data Controller in providing the services and supplies proposed by the same.

MINORS

The personal data of minors under the age of 16 will not be processed, unless consent is given by the child’s parent or legal guardian.

HOW LONG WILL YOUR PERSONAL DATA BE RETAINED?

Your personal data will be kept for the time necessary to fulfil the purposes referred to in point a) above. In particular, your personal data will be processed for the minimum time necessary, that is until the termination of the contractual relations between you and the Data Controller without prejudice to a further retention period that may be imposed by law. Furthermore, should you decide to give your optional consent to processing for commercial purposes set forth in point b), unless you withdraw your consent, your data will be stored for a period of time that does not exceed that necessary to fulfil the purposes. Data concerning the spontaneous submission of Curriculum Vitae will be retained for no longer than two years from the date of receipt. Your data will be kept for a further period in the case of claims or disputes.

HOW CAN YOU WITHDRAW YOUR CONSENT ONCE GIVEN?

You are entitled to withdraw your consent given to the Data Controller at any time totally and/or in part without prejudice to the legitimacy of the processing based on consent-based processing before this consent was revoked. To withdraw your consent, please contact the Data Controller at the addresses given in this information notice.

HOW WILL YOUR DATA BE PROCESSED?

Your data will be processed for the aforesaid purposes using both automated means, on electronic and magnetic instruments, and non-automated means on hardcopy, in accordance with the law and consequent regulations which are formulated to guarantee their confidentiality, security, accuracy, updating and relevance with regard to the stated purposes. There is no automated decision-making procedure, including profiling.

WHERE WILL YOUR DATA BE PROCESSED?

Your personal data will be processed by the Data Controller in Italy. If, for matters of a technical or operational nature, it becomes necessary to use parties outside the European Union, we inform you forthwith that these parties will be appointed Data Processors pursuant to article 28 of the GDPR; the transfer of your personal data to these parties will be restricted to the performance of specific processing activities and will be governed by a special appointment contract in accordance with the guarantees and protections required by the GDPR. All necessary precautions will be taken to ensure the full protection of your personal data, subjecting the transfer to the provision of appropriate safeguards including, for example, decisions by the European Commission on the adequacy of recipient third-party countries; appropriate safeguards provided by the recipient third party pursuant to article 46 of the GDPR. You may obtain further details from the Data Controller if your personal data have been processed outside the European Union, requesting evidence of the specific safeguards adopted.

WHAT ARE YOUR RIGHTS?

We would like to remind you that you can exercise your rights under the GDPR and in particular you have the right to:

• obtain confirmation whether personal data concerning you are being processed and obtain access to the data and the following information (purposes of the processing, types of personal data, recipients and/or categories of recipients to whom the data have been and/or will be communicated, retention period);
• obtain rectification of inaccurate personal data concerning you and/or that incomplete personal data be completed, also by providing an additional statement;
• obtain erasure of personal data, in accordance with the cases envisaged by the GDPR;
• obtain restrictions to the processing in the cases envisaged by current data protection legislation;
• obtain the portability of the data concerning you, if feasible and relevant to the service provided;
• object, at any time, on grounds relating to your situation, to the processing of your personal data in accordance with current data protection legislation.

To exercise your rights, please contact the email address info@minuterieprecisione.com, attaching a copy of your ID. You are always entitled to lodge a complaint with the Data Protection Authority pursuant to article 77 of the GDPR, if you believe the processing of your data is in breach of current data protection legislation.