Rev.00 del 05/10/18

PRIVACY POLICY

Information on the processing of personal data (pursuant to Article 13 of EU Regulation 2016/679)

The current legislation on the processing of personal data defined in accordance with the provisions contained in the EU Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data, as well as the free movement of such data (General Regulation on the protection of data, hereinafter “EU Privacy Regulation”) contains provisions aimed at ensuring that the processing of personal data is carried out in compliance with the fundamental rights and freedoms of natural persons, with particular regard to the right to protection of personal data.

1 Object of the processing and Legal Basis
The Data Controller processes personal data, identification (for example, name, surname, company name, address, telephone number) later, “personal data” or even “data” you have communicated for the following purposes:
a) Without your express consent (Article n. 6 letter b) of the GDPR), for the following Service Purposes:
– service online billing;
– paper billing service;
– management of paper submissions;
– contract management;
– management of defensive writings;
b) Only subject to your specific and distinct consent (Article 7 of the GDPR), for the following purposes:
– receive newsletters;
– marketing activities;
– management of joint conciliation;
– management of assistance practices (e-mail or telephone contact).
Treatment of personal data for fi promotional / commercial laity personal data may also be used for purposes of Customers profiling, information and commercial promotion of products and services, as well as investigations on the rating of the quality of those that you have already received and market research. In such cases, the processing of personal data will be based solely on your free and specific consent. Your consent may be revoked at any time without prejudice to the lawfulness of the processing carried out before the revocation.

2 Methods of treatment and definitions
For the sake of transparency and in compliance with the principles enucleated by art. 12 of the GDPR, it is recalled that “processing of personal data” means any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction.

The processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2 of the GDPR, namely: collection, registration, storage, consultation, processing, modification, selection, extraction, comparison, use of interconnection, blocking, communication, deletion and destruction of data. Your personal data are 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 Marketing / Promotional Purposes.
The personal data processed will be:
treated lawfully and correctly by parties authorized to perform these tasks, subjects who are constantly identified, appropriately educated and made aware of the constraints imposed by the GDPR;
collected and registered for specified, explicit and legitimate purposes, and used in other processing operations in term compatible with such purposes; exact and , if necessary, updated; relevant, complete and not exceeding the purposes for which they were collected or subsequently processed; kept in a form that allows the identification of the data subject for a period of time not exceeding that necessary for the purposes for which they have been collected or subsequently processed; processed with the support of paper, computerized or telematics means and with the use of security measures adequate to ensure the confidentiality of the data subject to which the data refer and to avoid undue access to third parties or unauthorized personnel.

3 Access to Data
Your data may be made accessible for the purposes referred to in art. 1.a) and 1.b):
To employees and collaborators of the Owner in their capacity as Authorized and / or internal processors 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) who carry out outsourcing activities on behalf of the company, in their capacity as External managers of the treatment.

4 Disclosure of data
The processing of user data with the utmost care and confidentiality is one of our fundamental values. If required by law, user data may be disclosed to third parties. We employ service providers and data processors in charge of processing data on our behalf. These services include authentication, hosting and maintenance services, data analysis services, e-mail messaging services, delivery services, payment transaction management, solvency, address control and e-mail. These third parties are our data controllers and may process personal data only to the extent necessary to provide their services. Our data controllers have a contractual obligation to treat this information with the utmost confidentiality. It is forbidden to use the data in any other way than necessary. The necessary measures are taken to ensure that our data controllers, including service providers and others responsible for our work , preserve and protect the confidentiality of your data.
Without your express consent (Article 6 paragraph 1 letter b) and c) of the GDPR, the Data Controller may communicate your data for the purposes referred to in art. 1 .a) to Supervisory Bodies, Judicial Authorities and to all the other subjects to whom the communication is mandatory by law for the performance of said activities.
Your information will not be disseminated.

5 Data transfer
The management and storage of personal data will take place on servers located within the European Union. Currently the servers are located in Italy. The data will not be transferred to outside the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the server location to another EU and / or non-EU State. In this case, the Holder, as of now, ensures that the transfer of Extra EU data will take place in accordance with the applicable legal provisions, stipulating, if necessary, agreements guaranteeing an adequate level of protection and / or adopting the standard contractual clauses provided by European Commission.

6 Nature of providing data and consequences of refusing to answer
The provision of data for the purposes referred to in art. 1 .a) is mandatory. In their absence, we cannot guarantee the registration to the site or the services of the art. 1.a).
The provision of data for the purposes referred to in art. 1.b) is optional. You can therefore decide not to give any data or to subsequently deny the possibility of processing data already provided: in this case, you will no longer receive our possible newsletters, commercial communications and advertising material concerning the services and products offered by the Data Controller. In any case, you will continue to be entitled to the Services referred to in art. 2a).

7 Rights of the interested party
In your capacity as an interested party, you have the rights set forth in art. 15 of the 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 intelligible form;
ii. 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 treatment carried out with the aid of electronic instruments; d) of the identification details of the owner, the managers and the designated representative pursuant to art. 3, paragraph 1, of the 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, managers or processor.
iii. obtain: a) the updating, correction, or when you have interest, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those 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 as regards their content, of those to whom the data have been communicated or disseminated, except in the case where this fulfilment is prove impossible or involve 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 collection; b) to the processing of personal data concerning you for advertising or direct sales purposes or for carrying out market research or commercial communication, in paper, telephone and/or telematics form. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to the traditional ones and that in any case the possibility remains of the interested party to exercise the right of opposition even if only partly. Therefore the interested party can decide to receive only traditional communications or only automated communications or none of the two types of communication.
Where applicable, it also has the rights referred to in art. 16 – 21 of the GDPR (Right of rectification, right to oblivion, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

8 How to exercise rights
You can exercise your rights at any time by sending your choice:
registered letter with return receipt to APR INSTRUMENTS S.r.l. Place of business: Coccaglio, Brescia – Via Enrico Mattei, Traversa III, n.3, CAP 25030;
a certified email: apristruments@pec.buffetti.it

9 Minors
This site and the services of the Owner are not intended for minors under the age of 18 and the Data Controller does not intentionally collect personal information about minors. In the event that information on minors were unintentionally registered, the Data Controller will delete them in a timely manner, at the request of users.

10 Owner, manager and Processor
The Data Controller is APR Instrument S.r.l. The updated list of the responsible and the persons in charge of processing is kept at the headquarters of the Data Controller.

11 Changes to this Information
This information may change. Therefore, it is advisable to regularly check this Informative to refer to the most updated version.