1 - Who is the “data controller” (i.e, who decides the purposes and means of processing)
The data controller is Del Monte & partner Comunicazione S.r.l., VAT 13221410155, with registered office in Milano (MI), viale Bodio n. 37 – 20158, e-mail privacy@digital360.it (hereinafter, “Company”).
2 - Personal data processed and source of data
The Company processes personal data relating to natural persons for the purpose of establishing and performing the contractual relationship with its legal person supplier (hereinafter, “Supplier”), such as those of the legal representative who signs the contract in the name and on behalf of the Supplier, as well as of the Supplier's employees/consultants involved in the activities referred to in the contract (hereinafter, “Data”). In the latter case, the source of the Data is the Supplier.
3 - Data processing purposes, legal basis and data retention
|
Why is your personal data being processed by the Company?
|
What is the basis that makes the processing lawful?
|
How long do we keep your personal data?
|
|
Purposes connected with the establishment and performance of the contractual relationship between the Supplier and the Company. |
Performance of the contract, for the Data of the legal representative.
Legitimate interest, for the Data of the Supplier's employees/collaborators involved in the activities under the contract. |
For 10 years after termination of the contract. |
|
Carrying out administrative-accounting tasks. |
Need to fulfil a legal obligation to which the Company is subject. |
|
|
If necessary, to ascertain, exercise or defend the Company's rights in and/or out of court. |
Legitimate interest. |
In the case of litigation, for the entire duration of the litigation, until the time limit for appeals has been exhausted. |
Once the above data retention terms have expired, data will be destroyed or anonymized, compatibly with the technical timing required for erasure and backup.
4 - The provision of data
The provision of Data is necessary for the execution of the contract.
5 - Who processes data within Company’s organization
Data are processed by the Company’s employees and collaborators – in charge of carrying out the activities aimed at pursuing the purposes outlined above – expressly authorized and instructed to process the data.
6 - Categories of recipients to whom data may be disclosed, also outside EU
Data may be processed by third parties acting as autonomous data controllers entitled to receive the data, such as public authorities or professional firms.
Data may be processed, on behalf of the Company, by third parties, appointed as processors pursuant to art. 28 of the GDPR, such as companies providing information and administration services.
Data may be transferred to entities established in countries outside the European Union (EU) and the European Economic Area (EEA), in particular to the United States, a country deemed adequate by the European Commission according to the 'EU-US Data Protection Framework' of 10 July 2023. Where the countries have not been deemed adequate by the European Commission, the standard contractual clauses (SCC) pursuant to Article 46.2. c) of the GDPR will be used, copies of which may be obtained by contacting the Company at the contact points listed in par. 1.
7 - Rights of the data subject
You, as data subject, may exercise the rights under Articles 15-22 of the GDPR, by contacting the Company at the e-mail address privacy@digital360.it. In particular, you may:
- obtain confirmation as to whether or not personal data relating to you are being processed and, if so, request access to such data and to the information referred to in Article 15 of the GDPR (purpose of processing, categories of personal data, etc.),
- obtain the rectification of inaccurate data or the integration of incomplete data in accordance with Article 16 of the GDPR,
- obtain the erasure of data in the cases provided for by Article 17 GDPR if the Company no longer has the right to process them1,
- obtain restriction of processing (i.e., limiting it to storage operation only) in the cases provided for by Article 18 GDPR2,
- object at any time, on grounds relating to your own particular situation, to the processing carried out in the legitimate interest,
- where the processing is based on consent or contract and is carried out by automated means, receive the data in a structured, commonly used and machine-readable format and transmit those data to another controller without hindrance from the controller to which the personal data have been provided, pursuant to Article 20 GDPR (“portability right”).
Furthermore, you shall have the right to lodge a complaint with the supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement.
8 - Data Protection Officer’s contact (DPO)
You can contact the Company’s DPO at the email address: dpo@digital360.it
Last update: May 2024
