This is a courtesy translation of the Italian privacy policy. In the event of any discrepancy, the Italian version shall prevail.
INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA
Pursuant to Article 13 of Regulation (EU) 2016/679 laying down provisions on the processing of personal data (hereinafter also the “GDPR”), we provide you below with information regarding the processing of your personal data.
- Data controller
The data controller is: Havant S.r.l. – Viale Forlanini, 38 – 20024 Garbagnate Milanese (MI), IT
1.1 Data Protection Officer (DPO)
The Data Protection Officer (DPO) can be contacted at the following address:
Havant S.r.l. – Viale Forlanini, 38 – 20024 Garbagnate Milanese (MI)
email: DPO@havant.com.
- Categories of personal data processed
2.1. Personal data you provide voluntarily
As part of the processing of personal data, the personal data you provide directly will be processed.
Personal data means “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”, as well as images (Art. 4(1) GDPR).
2.2 Browsing data
The IT systems and software procedures used to operate this website acquire, in the course of their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified data subjects, but by its very nature it could allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and IT environment. This data is used solely to obtain anonymous statistical information on the use of the site and to check that it is working properly, and is deleted immediately after processing. The data may also be used to establish liability in the event of hypothetical computer crimes against the site.
- Purposes of the processing of personal data
3.1. Purposes related to the contractual relationship between the Customer/Supplier and the Company.
The purposes related to the contractual relationship, where one exists, involve processing for the registration of personal details in the company management system and for administrative/accounting purposes such as the management of accounts and treasury, as well as invoicing (for example the checking and recording of invoices), in accordance with the requirements of current legislation
3.2 Marketing purposes
Marketing purposes include:
- sending commercial/promotional communications through automated (e.g. e-mail) and traditional (e.g. telephone calls with an operator and ordinary mail) means of contact regarding the Company's products/services;
- measuring customer satisfaction, market research, profiling and statistical analysis;
4. Legal basis for the processing of personal data
The legal basis for the processing of personal data for the purpose referred to in paragraph 3.1 is the contract to which you are a party, in order to allow the performance and management of the Services.
The legal basis for the processing for the purposes referred to in paragraph 3.2 is your specific consent.
Providing your personal data for the above purpose is optional, and failure to provide it will only mean that we cannot send you advertising and promotional messages or carry out profiling and market research. The performance and management of the Services agreed under the contract will not be affected.
We would also point out that, where you have given your consent for the purposes referred to in paragraph 3.2, you will remain free at any time to withdraw your consent and/or object to the processing of data for those purposes, by sending, without any formality, a clear written communication to that effect to the contact details specified in paragraph 9 “Rights of the data subject – complaint to the supervisory authority” below.
With particular regard to the exercise of the right to object for the above purposes, we inform you that, if you exercise it, it will apply to all means of contact, both electronic/automated and traditional, without prejudice to your right to exercise your right to object only for certain contact channels. For example, at any time, by contacting the data controller at the contact details specified in paragraph 9 “Rights of the data subject – complaint to the supervisory authority” below, you may object only to the sending of promotional communications by automated means (i.e. contact by e-mail, SMS, MMS, etc.) and therefore consent only to receiving communications by traditional means (i.e. paper mail or telephone contact with an operator).
Following receipt of such a request for withdrawal and/or objection, Havant S.r.l. will promptly carry out the request and update its database.
- Methods of processing personal data
Your personal data will be processed using manual, IT and telematic tools, as well as on paper.
- Recipients of personal data
The Data may be disclosed to external parties acting as data controllers, for example supervisory and control authorities and bodies and, in general, public or private entities entitled to request the Data. The Data may be processed, on behalf of the controller, by external parties designated as data processors, who carry out specific activities on behalf of the controller, for example accounting, tax and insurance obligations, mailing of correspondence, management of collections and payments, etc…
6.1 Persons authorised to process data
The Data may be processed by employees of the company departments responsible for pursuing the purposes indicated above, who have been expressly authorised to process the data and have received appropriate operating instructions.
- Transfer of personal data outside the EU
Your personal data and that of other data subjects will not be transferred outside the European Union.
- Retention periods of personal data
For the processing purposes referred to in paragraph 3.1, the retention period is 10 years after the termination of the contract. In the event of legal proceedings, for the entire duration of the proceedings, until the time limits for appeals have expired.
For processing for the purposes referred to in point 3.2, the retention period is 5 years.
Once the retention periods indicated above have expired, the Data will be destroyed or anonymised, in accordance with technical deletion and backup procedures.
- Rights of the data subject – complaint to the supervisory authority
By contacting the data controller by e-mail at privacy@havant.com, the data subject may ask the Company for access to the Data concerning them, their erasure, the rectification of inaccurate Data, the completion of incomplete Data, the erasure of the Data, the restriction of processing in the cases provided for by Art. 18 GDPR, and may object to processing carried out on the basis of the controller's legitimate interest.
In addition, where the processing is based on consent or on a contract and is carried out by automated means, the data subject has the right to receive the Data in a structured, commonly used and machine-readable format and, where technically feasible, to transmit them to another controller without hindrance.
The data subject has the right to lodge a complaint with the competent supervisory authority in the Member State in which they habitually reside or work, or in the State where the alleged infringement occurred.
The data subject has the right to withdraw their consent at any time for marketing purposes and to object to the processing of Data for the same purposes. A data subject who prefers to be contacted for the above purpose only by traditional means may still object only to receiving communications by automated means.
Last updated: 17 May 2019