Customer Privacy Policy
Our terms and conditions of useInformation document Article 13 of EU Reg. 2016/679 - GDPR - Information on the processing of personal data collected from the data subject
In compliance with the provisions of EU Reg. 2016/679 (European Regulation for the protection of personal data) we provide you with the necessary information regarding the processing of personal data processed. This information is provided pursuant to Article 13 of EU Reg. 2016/679 (European Regulation for the protection of personal data).
DATA CONTROLLER, pursuant to art. 4 and 24 of EU Reg. 2016/679 is Seco Tools Italia Spa a socio unico - Registered office: Via Roma, 2 – 22070 Guanzate (Como) – Italy, in the person of its pro-tempore legal representative. Telephone 031 978111 and e-mail it.privacy@secotools.com
Processing personal data
'personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; (C26, C27, C30).
PURPOSE OF THE PROCESSING
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LEGAL BASIS
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Purpose A)
- Processing necessary under a contract or for the purpose of concluding a contract and related administrative, accounting and pre-contractual activities;
- SOFT SPAM: commercial/promotional information activities, newsletters by e-mail to the e-mail address provided during the sale, concerning the same type of product and/or service (Soft Spam) similar to the product/service being sold and improvements also through satisfaction – art. 130, paragraph 4 of Legislative Decree 196/03 - legitimate interest (art. 6 letter f) EU Reg. 2016/679), unless oppositioned.
In order to compare and possibly improve the results of communications, the Data Controller uses systems for sending newsletters and promotional communications with reports. Thanks to the reports, the Data Controller will be able to know, for example: the number of readers, openings, unique "clickers" and clicks; the devices and operating systems used to read the communication; details on the activity of individual users; the details of emails sent, emails delivered and not, those forwarded; All this data is used for the purpose of comparing, and possibly improving, the results of the communications.
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Contract or pre-contract
Art. 6 lit. b) GDPR the processing is necessary for the pursuit of the performance of a contract to which the data subject is a party or for the execution of pre-contractual measures adopted at the request of the same.
Legitimate interest
Article 6(f) and recital 47: the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that the interests or fundamental rights and freedoms of the data subject which require the protection of personal data do not prevail, taking into account the reasonable expectations of the data subject on the basis of his or her relationship with the controller.
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10 years or other legal obligation
Art. 2220 of the Italian Civil Code
Until opposition
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RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE DATA
The personal data provided will be communicated to recipients, who will process the data in their capacity as data processors (art. 28 of EU Reg. 2016/679) and/or as natural persons acting under the authority of the Data Controller and the Data Processor (art. 29 of EU Reg. 2016/679), for the purposes listed above. Precisely, the data will be communicated to: - parent company and companies belonging to the group; entities that provide services for the management of the information system and communication networks (including e-mail); - firms or companies in the context of assistance and consultancy and satisfaction relationships; - competent authorities for the fulfilment of legal obligations and/or provisions of public bodies, upon request; - in the case of administrative accounting purposes, the data may be transmitted to commercial information companies for the assessment of solvency and payment habits and/or to subjects for debt collection purposes. The subjects belonging to the aforementioned categories perform the function of Data Processor, or operate in total autonomy as separate Data Controllers.
DATA TRANSFER TO A THIRD COUNTRY AND/OR AN INTERNATIONAL ORGANISATION AND SAFEGUARDS
Personal data will be transferred to non-EU countries, in order to comply with the related purposes indicated above. The data will be transferred on the basis of art. 44 s.s. EU Reg. 2016/679, and specifically to third countries that have provided adequate guarantees (art. 45) or on the basis of art. 46 EU Reg. 2016/679. The interested party can obtain information about the guarantees for data transfer by writing an email to the address it.privacy@secotools.com
NATURE OF PROVISION AND REFUSAL
The provision of data for purpose A) of this policy:
- conclusion of the contract: it is necessary for the purpose of stipulating the contract between the parties and for the purpose of managing the fulfilment of administrative/accounting obligations always with respect to the existing contract, the refusal of the contribution will not allow the conclusion of the contract;
- Soft Spam: with regard to the activity of Soft Spam, the data subject has the right to object to the processing of data at any time. Objection even after these e-mail communications will not affect the contract;
RIGHTS OF THE DATA SUBJECTS
Data subjects have the right to obtain from the Data Controller, in the cases provided for, access to personal data and the correction or erasure of the same or the limitation of the processing concerning them or to object to the processing (Articles 15 et seq. of EU Regulation 2016/679). You may object to processing based on legitimate interest at any time.
To exercise your rights, you can contact the Data Controller by writing to it.privacy@secotools.com To stop receiving automated direct marketing communications (e-mail), simply write an e-mail at any time to the address it.privacy@secotools.com with the subject "unsubscribe from automated" or use our automatic cancellation systems provided for e-mails only. Data subjects who believe that the processing of personal data relating to them is carried out in violation of the provisions of the Regulation have the right to lodge a complaint with the Italian Supervisory Authority (https://www.garanteprivacy.it/), as provided for in Article 77 of the Regulation, or to take action before the appropriate courts (Article 79 of the Regulation).
Date of update: 29 January 2019
THE OWNER
Seco Tools Italia Spa a socio unico