Information pursuant to Article 13 of EU Regulation 2016/679 on the Processing of Personal Data
Data Controller
We inform you that, pursuant to EU Regulation 2016/679 (hereinafter: "Regulation"), your Personal Data will be processed by Value Partners S.p.A., located at Largo Richini 6 - Milan, as the data controller ("Controller").
Types of Data Subject to Processing
The Controller will process your personal data (Article 4.1 of the Regulation), which may include, by way of example and not limitation, your first name, last name, mobile phone number, email address, and generally your contact details as the Client's representative.
Purposes, Legal Basis, and Optional Nature of Processing
Your personal data will be processed for the following purposes:
a) Execution of the Contract and/or Pre-Contractual Measures
The legal basis for processing is the execution of a contract to which the data subject is a party or the execution of pre-contractual measures taken at the request of the data subject (Article 6.1.b of the Regulation).
b) Compliance with Legal Obligations Arising from the Contract
The legal basis for processing is the fulfillment of a legal obligation to which the Controller is subject (Article 6.1.c of the Regulation).
c) Management of Disputes
The legal basis for processing is related to the pursuit of the legitimate interest of the Controller aimed at defending a right in administrative and judicial proceedings (Article 6.1.f of the Regulation).
The provision of your personal data for the purposes indicated above is optional, but failure to provide it will make it impossible to execute the contract.
For processing carried out for the purpose of direct sending of its own advertising material or for direct sales or for conducting its own market research or commercial communications regarding products or services of the Controller similar to those purchased, the Controller may use, without the consent of the data subject, email and postal addresses as permitted by Article 130, paragraph 4 of Legislative Decree 196/03 and by the provision of the Data Protection Authority of June 19, 2008.
The legal basis for processing your data for this purpose is Article 6, paragraph 1, letter f) of the Regulation. The data subject has the right to object to such processing at any time, initially or in subsequent communications, easily and free of charge, by writing to: privacy@valuepartners.com.
If, in any case, you wish to object to the processing of your data for marketing purposes carried out by the means indicated here, as well as revoke the consent given, you may do so at any time by contacting the Controller at the contact details indicated in this notice, without affecting the lawfulness of the processing based on the consent given prior to the revocation.
The provision of your Personal Data for the purpose indicated above is optional; there will be no consequences in case of refusal.
Your personal data will also be processed, upon your specific consent, for the following purposes:
d) Sending Promotional and Marketing Communications, including the sending of newsletters and market research, through automated tools (SMS, email, push notifications). It is specified that the Controller collects a single consent for the marketing purposes described here, pursuant to the General Provision of the Data Protection Authority "Guidelines on Promotional Activities and Spam Prevention" of July 4, 2013; if, in any case, you wish to object to the processing of your data for marketing purposes carried out by the means indicated here, as well as revoke the consent given, you may do so at any time by contacting the Controller at the contact details indicated in this notice, without affecting the lawfulness of the processing based on the consent given prior to the revocation.
The legal basis for processing for the purposes referred to in letter d) is the expression of consent by the data subject to the processing of their personal data (Article 6.1.a of the Regulation).
e) Profiling or Market Research, also with the aid of electronic tools, aimed at analyzing the habits or consumption choices of the data subject, to personalize messages addressed to customers.
The legal basis for processing for the purposes referred to in letter e) is the expression of consent by the data subject to the processing of their personal data (Article 6.1.a of the Regulation).
f) Communication and/or Transfer of Data to Third Parties for Marketing Purposes.
The legal basis for processing for the purposes referred to in letter f) is the expression of consent by the data subject to the processing of their personal data (Article 6.1.a of the Regulation).
The provision of your Personal Data for the purposes referred to in letters d), e), and f) is optional; there will be no consequences in case of refusal.
Recipients and Transfer of Personal Data
Your Personal Data may be shared with:
- Individuals authorized to process your Personal Data in accordance with Articles 29 and 32, paragraph 4 of the Regulation and 2-quaterdecies of the Privacy Code (e.g., employees of the Company who need to process your Personal Data in the course of their work duties, system administrators);
- Entities that, in providing services on behalf of the Company, process data on behalf of the Company and typically act as data processors (e.g., contractors in the case of outsourcing work, even partially, to external companies; third parties involved in the management of information systems and web platforms; external collaborators that the Company uses for specific technical and/or organizational services - such as IT service providers, collaborators, and external consultants; companies belonging to the Group; etc. For a complete and updated list of data processors, please write to privacy@valuepartners.com);
- Entities and authorities that normally act as independent data controllers pursuant to Article 4, no. 7 of the Regulation, to whom it is mandatory to communicate your Personal Data in accordance with applicable regulatory provisions for the Company or based on contractual obligations or in execution of pre-contractual measures.
"The Controller does not transfer your Personal Data outside the European Economic Area."
Methods of Data Processing
In relation to the stated purposes, the processing of personal data is carried out using manual, computer, and telematic tools, with methods strictly related to the purposes themselves and, in any case, in a manner that ensures the security and confidentiality of the data, as well as compliance with the specific obligations established by law.
Retention of Personal Data
Your Personal Data will be retained only for the time necessary for the purposes for which they were collected, in compliance with the principle of minimization set forth in Article 5, paragraph 1, letter c) of the GDPR. In any case, your personal data will be retained for the time necessary to fulfill the obligations set forth in the contract. Further retention may be required by applicable regulations, including that provided for by Article 2946 of the Civil Code. More information is available from the Controller.
Your Privacy Rights pursuant to Articles 15 et seq. of the Regulation
You have the right to request the Controller, at any time, access to your Data, rectification or deletion of the same, or to request the limitation of processing or to object to it, and to obtain in a structured, commonly used, and machine-readable format the data concerning you in the cases provided for by Article 20 of the Regulation.
We also inform you that you have the right to object pursuant to Article 21 of the Regulation, for legitimate reasons, to the processing of data; for example, you may object at any time to the sending of direct marketing using automated tools (SMS, email, push notifications); furthermore, you may exercise this right in part, that is, in this case, objecting, for example, only to the sending of promotional communications carried out through automated tools.
At any time, you may revoke your consent previously given pursuant to Article 7 of the Regulation, without affecting the lawfulness of the processing carried out prior to the revocation of consent. Requests should be addressed in writing to the Controller at the following address: privacy@valuepartners.com.
In any case, you always have the right to lodge a complaint with the competent supervisory authority (Data Protection Authority), pursuant to Article 77 of the Regulation, if you believe that the processing of your data is contrary to the applicable regulations.