INFORMATION FOR THE TREATMENT OF PERSONAL INFORMATION
Privacy code – D.lgs. 30.6.2003, n. 196 – Art. 13 – Regolamento UE 679/2016 sul trattamento dei dati personali – Art. 13
Eurolink Business Consulting Geie – Rev. February 20th, 2022 3:30 p.m.
Eurolink Business Consulting Geie, with registered office in Via C. Percoto 11, Udine – Italy, and operative headquarters in Piazza XX Settembre, 3 – Cividale del Friuli, UD – Italy CF e P.IVA 02781130303 (hereinafter, “owner”), in its capacity as data processor, pursuant to Article 13 of Legislative Decree no. 196 of 30.6.2003 (hereinafter, “Privacy Code”) and Article 13, EU Regulation no. 2016/679 (hereinafter, “GDPR”), informs you that your data will be processed in the following ways and for the following purposes.
The processing of personal information means any operation or set of operations, carried out with or without the aid of automated processes and applied to personal information or sets of personal data, even if not registered in a database, such as the collection, recording, organization, structuring storage, processing, selection, blocking, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form used to make it available, comparison or interconnection, restriction, cancellation or destruction.
Data will be processed with the following purposes, manually and/or with the support of computer or telematic means.
Processing object and legal basis
The owner processes personal, identification data (e.g., name, surname, company name, address, telephone, e-mail, bank and payment references) – hereinafter, “personal data” or also “data” – communicated by you, on the occasion of the conclusion of contracts or for registrations to the services of the owner via the Web.
Purpose of the processing
Your personal data are processed:
- A) without your explicit consent (art. 24 lett. a), b), c) Codice Privacy e art. 6 lett. b), e) GDPR), for the following Service Purposes:
- conclude contracts for the owner’s services and products;
- fulfill pre-contractual, contractual and fiscal obligations arising from relations with you;
- to fulfil the obligations provided for by the law, by a regulation, by the Community legislation or by an order of the Authority (such as, for example, in the field of anti-money laundering);
- to exercise the rights of the owner, for example the right of defence in court.
- B) Only with your specific and separate consent (artt. 23 e 130 Codice Privacy e art. 7 GDPR), for the following Marketing purposes:
- send via e-mail, mail, sms or telephone contacts, newsletters, commercial communications and information on services and products offered by Eurolink Business Consulting Geie or to detect your degree of satisfaction.
- We inform you that if you are already our customers, we may send commercial communications relating to services and products of the owner, similar to those already used, unless otherwise expressly dissent (art. 130 c. 4 Privacy Code).
Methods of processing
The processing of your personal data is carried out by means of the operations indicated in art. 4 Privacy Code and art. 4 n. 2 GDPR and, in detail: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subject to both paper and electronic and/or automated processing.
The owner will process personal data for the time necessary to fulfil the above purposes and also subsequently in fulfilment of legal obligations regarding the conservation of accounting records. For the processing for Marketing Purposes the same data will be kept in accordance with the principle of proportionality and in any case until the purposes of the processing have been pursued or until the revocation of the specific consent by the interested party.
Data access
Your data may be made accessible for the purposes of art. 2.A) and 2.B):
- to employees and collaborators of the owner, in their capacity as appointees and/or internal data processors and/or system administrators;
- to third party companies or other entities (i.e., credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, personal finance companies, Internet Service Providers, etc.) which carry out activities in outsourcing on behalf of the owner, in their capacity as external data processors;
- providers/supplying of funded projects (Region, Institutions).
Data communication
Without the need for express consent (ex art. 24 lett. a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR, the owner may communicate your data to third party companies or other entities (for example, banks, professional firms, consultants, insurance companies for the provision of insurance services, companies for personal financing, Friuli Venezia Giulia Region, Interprofessional Funds, Internet Service Provider, etc.), for the purposes of art. 2.A), to supervisory bodies (such as IVASS), judicial authorities, insurance companies for the provision of insurance services, as well as to those persons to whom the communication is mandatory by law for the fulfillment of the purposes mentioned above.
Such entities will process the data in their capacity as autonomous holders of the treatment.
The owner may also communicate your data to employees and collaborators, as managers or agents, also temporarily assigned to their use.
Your data will not be disclosed.
Data transfer
Personal data are stored on servers by the office located in Piazza XX Settembre, 3 – Cividale del Friuli, UD – Italy, in the European Union or by the Internet Service Provider appointed by Eurolink Geie. It is in any case understood that, if necessary, the owner will have the right to move the servers outside the EU. In this case, the owner assures as of now that the transfer of data outside the EU will take place in accordance with applicable laws, subject to the stipulation of standard contractual clauses provided by the European Commission.
Nature of data provision and consequences of refusal to answer
The provision of data for the purposes of art. 2.A) is mandatory. In their absence, we will not be able to guarantee the Services of art. 2.A).
The provision of data for the purposes of art. 2.B) is instead optional. You may therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material related to the Services offered by the owner. However, you will continue to be entitled to the services referred to in art. 2.A).
Rights of the interested party
In your capacity as data subject, you have the rights under Art. 7, Privacy Code and Art. 15 GDPR, and specifically the rights to:
- obtain confirmation of the existence or absence of personal data concerning you, even if not yet recorded, and their communication in intelligible form;
- obtain the indication of: a) the origin of personal data; b) the purposes and methods of treatment; c) the logic applied in case of treatment with the aid of electronic instruments; d) the identity of the owner, manager and the representative appointed under Art. 5, paragraph 2 Privacy Code and Art. 3, paragraph 1, GDPR; e) the subjects or categories of persons to whom the data may be communicated or who can learn about them as appointed representative in the State, managers or agents;
- obtain: a) the updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) certification that the operations as per letters a) and b) have been notified, also in accordance to their contents, to the entities to whom or which the data were communicated or diffused, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
- oppose, in whole or in part: a) to the processing of your personal data for legal reasons, even if related to the collection target; b) to the processing of your personal data relating to the forwarding of promotional material or direct sale or for the implementation of market researches or marketing communication, by means of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail.
We would like to point out that the right of the interested party to object, as set out in point b) above, for the purposes of direct marketing by means of automated methods is extended to traditional methods and that, in any case, the possibility remains open for the interested party to exercise the right to object, even only in part. Therefore, the data subject may decide to receive only communications by traditional means or only automated communications or neither type of communication. Where applicable, he/she also has the rights under Articles 16-21 GDPR (Right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to complain to the Supervisory Authority.
How to exercise the rights
You can exercise your rights at any time by sending
- a registered mail with return receipt to a Eurolink Business Consulting Geie – Piazza XX Settembre, 3 – Cividale del Friuli, UD – Italy
- an e-mail to: eurolinkgeie@legalmail.it
Owner, Manager and Appointees
The owner is Eurolink Business Consulting Geie with registered office in Via C. Percoto 11, Udine – Italy and operational headquarters in Piazza XX Settembre, 3 – Cividale del Friuli, UD – Italy
The updated list of data processors and persons in charge of processing is kept at the registered office of the owner.