Information on privacy and the processing of personal data pursuant to EU Regulation 2016/679
The EU Regulation 2016/679 (“Information on the processing of personal data”) provides for the protection of persons and other subjects regarding the processing of personal data.
In accordance with EU Regulation 2016/679, we provide the following information:
1) Source of the Data.
The data necessary for the performance of the contractual relationship between the Parties, as well as the data otherwise acquired as part of this activity, are collected by the Agency directly from the Data Subject and / or through third parties, as well as obtained by consulting some databases public and private external.
2) Availability of the Information.
The Agency provides the possibility to consult this information:
a) every time it collects the personal data of the Customers;
b) every time an explicit request is made to the Owner;
c) through the web consultation by accessing the home page of the website www.imperof.com.
3) Purposes of data processing.
The Agency for its own institutional purposes, connected or instrumental to the activity, processes your data for the following purposes:
a) purposes connected to the obligations established by laws, regulations and community legislation as well as by provisions issued by Authorities legitimated by the law or by supervisory and / or control bodies;
b) contractual purposes, connected and instrumental to the establishment and management of relationships with customers, such as for example the acquisition of preliminary information to the possible conclusion of a contract;
c) recognition of the degree of satisfaction with the quality of services, performed directly by the Agency or through the work of specialized companies through personal or telephone interviews, interactive questionnaires, market surveys;
d) promotion of products and services of the Agency through the sending of advertising material, telephone contracts and any other form of electronic communication (sending of e-mails, sms, mms, publication on social networks);
e) communication and / or transfer of data to third parties for the promotion and / or sale of products and services, using traditional and / or automated methods.
With reference to the purposes referred to in points c), d) and e), we inform you that, at any time, you will be free to revoke the consent expressed in the manner specified in this statement.
4) Nature of the provision of data.
You have the right to know that the provision of data may be compulsory or optional, as well as having consequences in the event of a refusal.
In this regard, I specify that:
a) the conferment of your consent for the purposes referred to in letters a) and b) of point 3 is mandatory in so far as provided by law or to follow up obligations of a contractual nature (as indicated in Article 6, paragraph 1) , letter b) of the Rules). The refusal of your consent for the purposes indicated in letter b) of point 3) will not, therefore, allow the Agency to carry out the task conferred by you or to reach the conclusion of the contract of which you are a part;
b) the refusal to process the Data for the purposes referred to in letters c) , d) and e) of point 3 is, on the other hand, optional , will not entail any prejudicial consequences and may be revoked by you at any time, limited to the purposes related to the sending of advertising material, detection of the degree of satisfaction on the quality of services, carrying out market research or commercial communication, through telephone contacts or any other form of electronic communication (sending e-mail, sms , mms, whatsapp, publication on websites, social networks, etc.), performed directly by the Agency or through the work of specialized companies through personal or telephone interviews, interactive questionnaires.
5) Specific data.
Article. 9 of the Regulations defines particular data suitable to reveal racial and ethnic origin, political opinions, religious or philosophical beliefs or union membership, as well as genetic and biometric data, data related to health or sexual life or to the sexual orientation of the person. It is possible that the Agency will be in possession of particular data in relation to the specific operations requested by the interested party. In this case, the interested party has the right to express a specific consent to the processing of their sensitive data and the Agency may use them exclusively to the extent necessary to perform the services and operations required.
6) Data Retention.
The Data will be kept for the time necessary to manage the contractual relationship and fulfill legal obligations, with particular reference also to the anti-money laundering legislation. The Data are always treated in full compliance with the principle of proportionality of the processing (Article 5, paragraph 1, letter c) of the Rules), according to which all Personal Data and the various modalities of their processing must be relevant and not exceeding the aims pursued, so as to ensure adequate security and confidentiality, also to prevent unauthorized access or use of personal data and equipment used for processing, as well as lawful and correct processing.
7) Data retention times.
By virtue of the provisions of art. 13, paragraph 2, lett. a) of the Regulations, indications are given below regarding the retention times of the Data according to the different purposes of the processing:
• with reference to letters a) and b) of point 3, the Data are kept for the period necessary to manage the contract and comply with legal obligations;
• with reference to letters c), d) and e) of point 3, storage times are set in 10 years.
8) Methods of data processing.
In relation to the purposes indicated in point 3, Personal Data may also be processed by a ” Manager ” , ie the natural person or company, even outside the Agency, which may be entrusted with specific and defined tasks of management and control of the processing of the data, and by one or more ” Distributor (s) “, who will process the data or use of the data on the basis of the instructions received from the Data Controller or the Data Processor (subjects that, if not expressly indicated in this statement, are not considered still designated, and not necessarily to be designated if the processing is occasional, and the data will be provided in the event of their designation).
Always in relation to the aforementioned purposes, the Data may be processed through manual, computerized and / or otherwise automated tools according to the logic strictly connected to the purposes of the processing and, in any case, in order to guarantee its security and confidentiality even in case of treatment through instruments of distance communication.
9) Transfer of data abroad.
The Data could be transferred to countries of the European Union and to third countries (that is not members of the European Union) exclusively for the purposes referred to in points a) and b) of point 3. In this case, the intention to the transfer of personal data must be communicated beforehand and authorized by you only if a level of data protection adequate to the European one is guaranteed.
10) Communication of Data.
The Data, by virtue of the relationship established and in order to facilitate and allow the conclusion of the deal, may be communicated to: i) external collaborators; ii) other business agents in mediation (including companies) identified by the Owner in order to collaborate for the accomplishment of the assignment entrusted by the interested party; iii) banks and other subjects operating in the banking sector; iv) counterparties and their potential technicians and consultants; v) notaries for the purpose of preparing notarial deeds and / or related activities pertaining to the assignment conferred to the Holder; vi) companies and / or professionals who perform services for the completion of technical / land / building / town planning practices; vii) insurance for the conclusion of policies relating to the assignment conferred to the Holder; viii) websites for the purpose of real estate advertising; ix) Boards of arbitrators and, in general, all those public and private subjects to whom communication is necessary for the correct fulfillment of the purposes indicated in point 3); x) Supervisory / Control bodies and other Authorities, for purposes connected to the obligations established by law (anti-usury law, anti-money laundering legislation) and / or by regulations, as well as by instructions issued by the same Authorities.
All subjects, belonging to the categories to which the Data may be communicated, will use the Data as “owners” in accordance with the law or specific consent, independently, being unrelated to the original processing carried out at the Agency, or of “external managers”. To know at any time the subjects, to which your data will be communicated, it is sufficient that you request the updated list by writing to the Data Controller at the headquarters of the Agency.
Finally, your data will be known by all employees and collaborators of the Agency, designated managers and / or in charge of processing, in relation to the performance of the duties and tasks assigned to each.
Data processed by the Agency will not be disseminated.
11) Rights of the interested party.
Within the limits and under the conditions set out in articles 15 – 23 of the Regulations, the Agency guarantees and recognizes the exercise of the following rights:
• the right to access personal data in their paper and / or electronic archives;
• the right to request rectification, updating and cancellation, if incomplete or erroneous, and to oppose their processing for legitimate and specific reasons;
• the right to obtain the correction of inaccurate personal data without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, also by providing an additional declaration;
• the right to obtain the cancellation of personal data concerning him without undue delay if there is one of the reasons set out in art. 17, paragraph 1 of the Rules;
• the right to obtain the limitation of processing when one of the hypotheses referred to in art. 18, paragraph 1 of the Rules;
• the right to portability of data within the limits and in the ways provided for by art. 20 of the Rules.
You also have at any time the right to withdraw your consent to the processing of your data without prejudice in any way to the lawfulness of the processing based on consent given before the revocation, as well as to object to processing for marketing purposes at any time ( right of opposition).
You have the right to receive information relating to the action taken concerning one of the aforementioned requests or the effects arising from the exercise of one of the aforementioned rights, without unjustified delay and, in any case, no later than one month after receipt of the request; extendable if necessary for two months; he also has the right to lodge a complaint with a supervisory authority and to bring a judicial appeal.
Without prejudice to the case in which the processing of the Data violates the general principles laid down by the Regulations, the exercise of these rights must be relevant and justified and may not imply the revocation of the consent given or the request for cancellation of the Data provided by conclusion and execution of the contract referred to in point 3) letters a) and b), in so far as and as long as the data are necessary for this purpose.
In exercising your rights, you may grant, in writing, a proxy or power of attorney to individuals, associations or organizations; may also be assisted by a trusted person. The Agency, to ensure the effective exercise of your rights, will take appropriate measures to facilitate access to data, simplify the procedures and reduce the time to respond to your request.
Finally, it should be noted that you can lodge a complaint with the supervisory authority or with the Personal Data Protection Authority through the following means:
a) registered A / R addressed to the Guarantor for the protection of personal data, Piazza di Monte Citorio n. 121 00186 Rome;
b) e-mail to the address: email@example.com, or firstname.lastname@example.org;
c) fax to the number: 06 / 69677.3785.
All related information on complaints proposed by the Interested party is available on the website of the Guarantor at www.garanteprivacy.it