INFORMATION ON THE PROCESSING OF PERSONAL DATA

S.B.S. s.r.l., Tax Code 01269540249, e-mail [email protected], with registered office in Via Mottinello, 141B – 36028 – Rossano Veneto (VI) – Italy (hereinafter, “Data Controller”), as data controller, informs you pursuant to art. 13 Decree 30.6.2003 n. 196 (hereinafter, “Privacy Code”) and art. 13 EU Regulation n. 2016/679 (hereinafter, “GDPR”) that your data will be processed in the manner and for the following purposes:

1. Object of the processing
The Data Controller processes personal data, such as name, surname, company name, address, telephone number, e-mail address, bank and payment details) – hereinafter, “personal data” or “data”) that you have communicated on the conclusion of contracts for the services of Data Controller.

2. Purpose of the processing
Your personal data is processed:
A) Without your express consent (Article 24 letter a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes::
– conclude the contracts for the services of the Data Controller;
– fulfil the pre-contractual, contractual and tax obligations deriving from current transactions with you;
– fulfil the obligations governed by law, by a regulation, by community legislation or by an order of the Authority (such as for anti-money laundering);
– exercise the rights of the Data Controller, for example the right of legal defense;

B) Only subject to your specific and distinct consent (articles 23 and 130 of the Privacy Code and article 7 of the GDPR), for the following Marketing Purposes:
– send you via e-mail, mail and / or sms and / or telephone contacts, newsletters, commercial communications and / or advertising material on products or services offered by the data Controller and survey of the degree of satisfaction on the quality of services;
– send you via e-mail, mail and / or sms and / or telephone contacts, commercial and / or promotional communications of third parties (for example, business partners, insurance companies).

Please note that if you are already a customer of ours, we may send you commercial communications relating to services and products of the data Controller similar to those you already received, unless your dissent (Article 130 paragraph 4 of the Privacy Code).

3. Processing methods
The processing of your personal data is carried out by means of the operations indicated in art. 4 of the Privacy Code and art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subjected to both paper and electronic and / or automated processing.
The Data Controller will process the personal data for the time necessary to fulfil the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the purposes of service and no later than 2 years from the collection of data for the purposes of marketing.

4. Access to data
Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):
– to employees and collaborators of the Data Controller in Italy and abroad, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators;
– to third-party companies or other subjects (as an indication, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) who carry out outsourced activities on behalf of the data Controller, in their capacity as external managers of the processing.

5. Communication of data
Without the need for express consent (pursuant to Article 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Companies (such as IVASS), Judicial Authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is mandatory by law for the accomplishment of said purposes. These subjects will process the data in their capacity as independent data controllers.
Your data will not be disclosed.

6. Data transfer
Personal data is stored on servers located in Rossano Veneto (VI), within the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers outside the EU. In this case, the Data Controller hereby ensures that the transfer of data outside the EU will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

For the purposes referred to in art. 2.B) we use the service offered by MailChimp web platform, which will store some of your personal data (name, surname, e-mail) at its servers in the United States. Although this operation involves a transfer of data abroad, it complies with European legislation on the protection of personal data and does not require consent as MailChimp guarantees compliance with EU legislation through the adoption of a specific legal addendum.

The data processed for sending the newsletters are managed by the provider MailChimp (Privacy Policy di Mailchimp).

7. Nature of the provision of data and consequences of refusal to reply
The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we cannot guarantee the services of the art. 2.A). The provision of data for the purposes referred to in art. 2.B) is optional. You can therefore decide not to give any data or to deny subsequently the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material concerning the Services offered by the Data Controller. However, you will continue to be entitled to the Services referred to in art. 2.A).

8. Rights of the interested party
In your capacity as an interested party, you have the rights set forth in art. 7 of the Privacy Code and art. 15 GDPR and precisely the rights of:
i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
ii. obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of processing carried out with the aid of electronic instruments; d) of the identification details of the Data Controller, the managers and the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the territory of the State, as managers or agents;
iii. obtain: a) updating, rectification or, when interested, integration of data; b) 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) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or spread, except in the case in which this fulfilment proves impossible o involves a use of means manifestly disproportionate to the protected right;
iv. to object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use 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. It should be noted that the right of opposition of the interested party, set out in the above point b), for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right to object even only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.

Where applicable, it also has the rights referred to in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of processing, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority

9. How to exercise rights
You can exercise your rights at any time by sending:
– a registered letter with return receipt to S.B.S. s.r.l. via Mottinello, 141B – 36028 – Rossano Veneto (VI)
– an e-mail to the e-mail address [email protected]

10. Data Controller, managers and appointees
The data controller is S.B.S. s.r.l., Tax Code 01269540249, email [email protected], +39 0424 84482, with registered office in Via Mottinello, 141B – 36028 – Rossano Veneto (VI) – Italia.
The updated list of the responsible data processors and appointees is kept at the registered office of the Data Controller.


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