POLICY FOR THE PROCESSING OF PERSONAL DATA

ATELIER VERDERAME s.r.l.s with registered office in 73100 Lecce, Via Don Bosco 9, P.IVA and C.F. 05100540755 (hereinafter, “Owner”), as owner of the treatment, informs you pursuant to art. 13 EU Regulation no. 679/2016 (hereinafter, “GDPR”) that your data will be processed in the following ways and for the following purposes:

1. Object of Treatment
The Data Controller processes personal data, identifying for example: name, surname, company name, address, telephone, email, bank and payment references (hereinafter, “personal data” or also “data”); communicated by you when concluding contracts for the services of the Data Controller.

2. Purpose of the treatment
Your personal data are processed:

A) without your express consent (art. 6 lett. b), e) GDPR), for the following Service Purposes:
• conclude contracts for the services of the Controller;
• fulfill pre-contractual, contractual and tax obligations arising from existing relationships with You;
• fulfill the obligations required by law, regulation, EU legislation or an order of the Authority (such as anti-money laundering);
• exercise the rights of the owner, such as the right of defense in court;

B) Only after your specific and distinct consent (art. 7 GDPR), for the following Marketing Purposes:
• to send you via e-mail, mail and/or sms and/or telephone contacts or instant messenger: newsletters, commercial communications and detection of the degree of satisfaction on the quality of services and/or advertising material on products or services offered by the Owner and/or Business Partners;

3. Treatment modalities
The processing of your personal data is carried out by means of the operations indicated in art. 4 n.2) GDPR and precisely: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subject to both paper and electronic and/or automated processing.

The Owner will process personal data for the time necessary to fulfill the above purposes and in any case the same data will be processed, from the termination of the relationship, for no more than 10 years for the Purposes of Service and for no more than 2 years for Marketing Purposes.

4. Access to data
Your data may be made accessible for the purposes of art. 2.A) and 2.B):
• to employees and collaborators of the Data Controller in their capacity as appointees and/or internal data processors and/or system administrators;
• to third party companies or other entities (for example, banks, professional firms, consultants, insurance companies for the provision of insurance services, etc.) that perform outsourcing activities on behalf of the Owner, in their capacity as external data processors.

5. Communication of data
Without the need for express consent (art. 6 lett. b) and c) GDPR), the Owner may communicate your data for the purposes of art. 2.A) to supervisory bodies (such as IVASS), judicial authorities, insurance companies for the provision of insurance services, as well as to those persons to whom disclosure is required by law for the fulfillment of the above purposes. These subjects will treat the data in their capacity as autonomous holders of the treatment.

6. Data transfer
Personal data are stored on servers located in Italy within the European Union. In any case, it is understood that the Owner, if necessary, will have the right to move the servers outside the EU. In this case, the Owner assures as of now that the transfer of data outside the EU will take place in accordance with applicable laws, after signing the standard contractual clauses provided by the European Commission.

7. Nature of data conferment and consequences of refusal to answer
The provision of data for the purposes of art. 2. A) is compulsory. In their absence, we will not be able to guarantee the Services of art. 2. A).
The provision of data for the purposes of art. 2. B) is optional. You can therefore decide not to provide any data or subsequently deny the possibility of processing data already provided. In this case, you will not be able to receive newsletters, commercial communications and advertising material related to the Services offered by the Owner and/or Commercial Partners.
You will however continue to be entitled to the Services as per art. 2.A).

8. Rights of the interested party
In your capacity as data subject, you are entitled to the rights set forth in art. 15 GDPR:
1. obtain confirmation of the existence or not of personal data concerning you, even if not yet recorded, and their communication in intelligible form;
2. to obtain the indication
a. the origin of the personal data;
b. the purposes and methods of processing
c. the logic applied in case of treatment with the aid of electronic instruments;
d. the identity of the owner, manager and the representative appointed under Art. 3, paragraph 1, GDPR;
e. the subjects or categories of persons to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents;
3. obtain:
a. the updating, rectification or, when there is interest, the integration of data;
b. the 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. certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
4. oppose, 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. the processing of personal data concerning you for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator by e-mail and / or through traditional marketing methods by phone and / or mail. Please note that the right of opposition of the person concerned, set out in the previous “Purposes of the treatment” art. 2 point B), for the purposes of direct marketing by automated means extends to traditional ones and that, however, remains subject to the possibility for the person concerned to exercise the right of opposition even in part.

Where applicable, also have the rights under Art. 16-21 GDPR (Right of rectification, right to oblivion, right to restriction of processing, right to data portability, right of opposition), as well as the right to complain to the Guarantor Authority.

9. How to exercise your rights
You may exercise your rights at any time by sending:
• an e-mail to help@atelierverderame.com

10. Owner, responsible and in charge
The Data Controller is Atelier Verderame S.r.l.s The updated list of data processors and persons in charge of processing is kept at the registered office of the Data Controller.

Atelier Verderame Srls
vat no 05100540755

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