Privacy policy
sito web: www.foxpatton.com
INFORMATION REGARDING THE COLLECTION OF PERSONAL DATA
PURSUANT TO ART. 13 OF EU REGULATION 2016/679
In compliance with the provisions of EU Regulation no. 679/2016 (hereinafter the "Regulations") to article 13 - Information to be provided if personal data are collected from the interested party - FOX & PATTON ADVISOR Srl CF-VAT: 07199990016, with registered office in Turin, Via Galluppi 5 (hereinafter the "Company"), provides the following information on the processing of personal data of its Customers, Suppliers, Employees and Collaborators (hereafter the "Data") made by the Company, as Data Controller.
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Identity of the Data Controller and methods of contact
Pursuant to Article 4 of the Regulation, the Company is the data controller of its Customers, Suppliers and Collaborators. For communications or requests, the Company can be reached via e-mail at the address:privacy@foxpatton.com
- Categories and types of Data collected and processed::
I Dati trattati dalla Società possono includere dati personali, non facenti parte di categorie particolari (art. 9 del Regolamento) raccolti ai fini della conclusione del contratto col Cliente, Fornitore, Dipendente e Collaboratore nell’ambito dell’esecuzione e/o della stipula dello stesso. Altresì, è possibile il verificarsi di un trattamento di dati personali di terzi soggetti comunicati dal Cliente, Fornitore, Dipendente e Collaboratore alla Società.
With respect to this hypothesis, the Customer, Supplier and Collaborator stands as an independent data controller and assumes the consequent legal obligations and responsibilities, relieving the Company from any objection, claim and / or request for compensation for damage from treatment that should reach the Company from interested third parties.
- Purpose and legal basis of the processing and nature of the provision of data
Nel rispetto della normativa vigente in materia di protezione dei dati personali e senza necessità di uno specifico consenso da parte dell’Interessato, i Dati saranno archiviati, raccolti e trattati dalla Società per i seguenti fini:
a) fulfillment of contractual obligations, execution and / or conclusion of contracts and / or management of any pre-contractual measures;
b) fulfillment of any regulatory obligations, tax and fiscal provisions deriving from the performance of the business activity and obligations related to administrative and accounting activities;
c) sending, directly or through third-party providers of marketing and communication services, newsletters and communications for the purpose of direct marketing through email, sms, mms, push notifications, fax, paper mail, telephone with operator, in relation to products supplied;
d) communication of data to third-party companies for the sending of newsletters and communications for marketing purposes through e-mail, sms, mms, push notifications, fax, paper mail, telephone with operator. The legal bases of processing for the purposes a) and b) above are the articles. 6.1.b) and 6.1.c) of the Rules. The provision of data for the aforementioned purposes is optional, but any failure to provide the data and the refusal to supply them would make it impossible for the Company to execute and / or stipulate the contract and provide the services requested by the same.
The legal basis for processing personal data for purposes c) and d) is art. 6.1.a) of the Rules as the treatments are based on consent; it is specified that the Data Controller may collect a single consent for the marketing purposes described herein, in accordance with the General Provision of the Guarantor for the protection of personal data "Guidelines on promotional activities and the fight against spam" of 4 July 2013. The giving consent to the use of data for marketing purposes is optional and, should the interested party wish to oppose the processing of data for marketing purposes performed with the means indicated herein, as well as revoke the consent given, he may at any time do so without no consequences (except for the fact that you will no longer receive marketing communications) by following the instructions in the "Rights of Interest" section of this Notice.
Finally, please note that for processing carried out for the purpose of sending direct advertising material or direct sales or for carrying out market research or commercial communications in relation to products or services similar to those used by the Customer, Supplier and Collaborator, the Company may use e-mail addresses pursuant to and within the limits permitted by art. 130, paragraph 4 of the Privacy Code (Legislative Decree No. 196/2003) and the provision of the Authority for the protection of personal data of June 19, 2008 even in the absence of explicit consent.
The legal basis of data processing for this purpose is art. 6, paragraph 1, lett. f) of the Regulations, without prejudice to the possibility of opposing this treatment at any time, following the instructions in the "Rights of the Interested" section of this Notice.
- Methods of data processing
In relation to the aforementioned purposes, the data are processed using manual, computerized and telematic tools with logic strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security and confidentiality of the Data, in addition to compliance with the specific obligations established by the legislation. The Data will be processed in compliance with the principle of lawfulness, correctness, relevance and non-excess, in accordance with the provisions on the protection of personal data. The treatment will be carried out by staff who are formally appointed and adequately trained.
- Scope of communication and dissemination of data, recipients and data transfer and data processors
For the aforesaid purposes, the Data may be disclosed to other Group companies and to third parties appointed as data controllers pursuant to Article 28 of the Rules and in particular to banking institutions, companies active in the insurance field, to strictly necessary service providers to the carrying out of the business activity, that is to consultants of the company and / or databanks where this proves necessary for fiscal, administrative, managerial and contractual reasons or for needs protected by the current regulations. Furthermore, the other Group companies will be able to access the Data for administrative and / or accounting purposes, pursuant to Articles 47 and 48 and Article 6 of the Rules. Finally, the Data may be shared with authorities, entities and / or subjects to whom the Data must be communicated pursuant to legal provisions or orders of authority. These authorities, bodies and / or subjects will act as independent data controllers. Data will not be disclosed. The updated periodically and complete list of data processors appointed for data processing may be requested by sending an e-mail to the Data Controller at the addresses indicated above.
- Data transfer to international organizations and / or countries outside the EEA (European Economic Area)
Any transfer of the Data to international organizations and / or non-EEA countries will take place according to the methods permitted by the current legislation, such as the consent of the interested party, the adoption of Standard Clauses approved by the European Commission, the selection of subjects adhering to international programs for free circulation of data (eg EU-USA Privacy Shield) or operating in countries considered safe by the European Commission. On request, it is possible to have more information from the Company to the above mentioned contacts.
- Data Retention:
The Data will be stored on paper and / or computer for only the time necessary for the purposes for which it was collected, respecting the principles of limitation of conservation and minimization referred to in Article 5, paragraph 1, letters c) and e) of Regulation. The Data will be kept to comply with regulatory obligations and to pursue the above-mentioned purposes, in compliance with the principles of indispensability, non-excess and relevance. The Company may retain Data after termination of the contractual relationship to fulfill regulatory and / or post-contractual obligations; subsequently, after the aforementioned reasons for the processing have been lost, the Data will be deleted, destroyed or simply stored anonymously. On request, it is possible to have more information from the Company to the above mentioned contacts.
- Rights of the interested party
In relation to the aforementioned processing, each interested party can exercise the rights referred to in articles 15 to 22 of the Regulations. In particular, the Data Subject has the right to ask the Company for access to its Data, correction or cancellation of the same, has the right to oppose the processing or to request the limitation of processing in the cases provided for in Article 18 of the Regulation and to obtain, in a structured format, in common use and readable by an automatic device, its Data, in the cases provided for in Article 20 of the Rules. The Interested Party may also revoke the consent granted pursuant to Article 7 of the Regulations at any time, as well as propose a claim by the Guarantor for the protection of personal data pursuant to Rule 77 of the Rules of Procedure, if it considers that the processing of its Data is contrary to the legislation in force. In cases of opposition to the processing of data pursuant to Article 21 of the Rules, the Company reserves the right to assess the application, which will not be accepted if there are legitimate reasons to proceed to the processing that prevail over the interests, rights and freedom of the 'Interested. Requests should be sent in writing to the Company at the above addresses.
May 24, 2018