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Privacy Policy
PRIVACY NOTICE PURSUANT TO EU GDPR 2016/679
Last update: 24.05.2018
PRIVACY promotional communications and newsletter via e-mail - Information document article 13 Reg.
EU 2016/679- GDPR - Information on the processing of personal data collected from the data subject Personal data that may be processed: any information concerning 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) 1. THE "DATA CONTROLLER" THE "DATA CONTROLLER", pursuant to Articles 4 and 24 of the GDPR, is Equa Srl, via E.Caldara – 44 – 20122 – Milan (MI), in the person of the legal representative pro tempore. The contact email of the controller is info@equasystem.com
In compliance with the provisions of Reg. EU 2016/679 (European Regulation for the protection of personal data) we provide you with the necessary information regarding the processing of the personal data provided. This information is provided pursuant to art. 13 of Reg. EU 2016/679 (European Regulation for the protection of personal data). The information is also inspired by Recommendation no. 2/2001 which the European authorities for the protection of personal data, gathered in the Group established by art. 29 of Directive no. 95/46/EC,, adopted on 17 May 2001 to identify certain minimum requirements for the collection of personal data online, and, in particular, the methods, timing and nature of the information that data controllers must provide to users when they connect to web pages, regardless of the purposes of the connection, as well as the provisions of Directive 2002/58/EC, as updated by Directive 2009/136/EC, regarding Cookies.
2. DATA PROTECTION OFFICER (RPD/DPO - DATA PROTECTION OFFICER)
is identified pursuant to Articles 37 – 39 of EU Regulation 2016/679. The DPO's contact email is info@equasystem.com
3. PURPOSE AND LEGAL BASIS OF THE PROCESSING
Personal data will be processed in compliance with the lawfulness conditions pursuant to Art. 6 EU Regulation 2016/679 for the following purposes:
A) receipt of communications for direct marketing activities, newsletters, market research or other sample surveys and sales through automated means such as email, MMS or SMS messages or other types, as well as through phone calls and the use of regular mail, of informational material about Equa system products, for the detection of satisfaction levels, promotional, commercial and advertising material or related to events and initiatives by the Data Controller.
The Data Controller, in order to compare and possibly improve the results of communications, uses systems for sending newsletters and promotional communications with reports. Thanks to these reports, the Data Controller can know, for example: the number of readers, openings, unique "clickers" and clicks; the devices and operating systems used to read the communication; details of the activity of individual users; details of emails sent, delivered and not delivered, and those forwarded; All this data is used for the purpose of comparing and possibly improving the results of communications:
LEGAL BASIS Data processing for the purpose A) is based on consent pursuant to Article 6, paragraph 1, letter a) GDPR.
4. RECIPIENTS OR CATEGORIES OF DATA RECIPIENTS
The personal data provided will be communicated to recipients who will process the data as data processors (art. 28 of EU Regulation 2016/679) and/or as natural persons acting under the authority of the Data Controller and the Data Processor (art. 29 of EU Regulation 2016/679), for the purposes listed above in point 3, and to third parties. Specifically, the data will be communicated to: subjects who provide services for the management of the information system used by Equa Srl and telecommunications networks (including email and platforms); - firms or companies within the scope of assistance and consultancy relationships; - companies affiliated, controlled, or contractually linked to Equa Srl and/or part of its distribution network (such as branches, importers, distributors, shippers, etc.), possibly also based in countries outside the European Union; - competent authorities for compliance with legal obligations and/or provisions of public bodies, upon request; - the sales/distribution network in the territory.
The subjects belonging to the aforementioned categories perform the function of Data Processor, or operate in total autonomy as separate Data Controllers. The list of processors is constantly updated and available at the headquarters of Equa srl via E.Caldara – 44 – 20122 – Milan (MI).
5. TRANSFER OF DATA TO A THIRD COUNTRY AND/OR AN INTERNATIONAL ORGANIZATION AND SAFEGUARDS
The personal data provided may be transferred to countries within the European Union and to non-EU countries, in order to comply with the purposes indicated above.
The data will be transferred based on Article 44 - General principle for transfer; Article 45 - Transfer on the basis of an adequacy decision; Article 46 - Transfer subject to appropriate safeguards, specifically the data will be transferred:
- to third countries or international organizations for which the Commission has intervened with an adequacy decision (Art. 45 Reg. EU 2016/679)
- to third countries or international organizations that have provided adequate safeguards and where the data subject has enforceable rights and effective remedies (Art. 46 Reg. EU 2016/679, also with contractual clauses and other provisions referred to in Article 46, paragraph 3)
- to third countries or international organizations on the basis of derogations in specific situations (Art. 49 Reg. EU 2016/679)
For information about the guarantees regarding the transfer of data outside the EU, write to info@equasystem.com.
6. DATA RETENTION PERIOD OR CRITERIA FOR DETERMINING THE PERIOD
The processing will be carried out both automatically and manually, using methods and tools aimed at ensuring maximum security and confidentiality, by individuals specifically appointed for this purpose. In compliance with the provisions of art. 5 paragraph 1 letter e) of EU Regulation 2016/679, the personal data collected will be stored in a form that allows the identification of the data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed. The retention of the personal data provided depends on the purpose of the processing: - receiving newsletters or promotional communications in general via e-mail (maximum 24 months); timing determined on the basis of criteria about which the data subject can obtain information by writing to info@equasystem.com.
7. RIGHTS OF THE DATA SUBJECTS
You may exercise your rights as expressed by EU Regulation 2016/679 by contacting the Data Controller, by sending an email to info@equasystem.com or by writing to the address of the Data Controller indicated above. You have the right, at any time, to request from the Data Controller access to your personal data (art. 15), rectification (art. 16) or erasure (art. 17) of such data, or restriction of processing (art. 18), or to object to their processing based on legitimate interest (art. 21). Finally, you have the right to data portability (art. 20).
Withdrawal of consent. If the processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
To object to the processing and to exercise other rights, you can write to info@equasystem.com
To no longer receive automated direct marketing communications (e-mail, SMS, MMS, fax), simply write an e-mail at any time to info@equasystem.com with the subject “unsubscribe from automated” or use our automatic unsubscribe systems provided for e-mails only, and you will no longer be disturbed. To no longer receive traditional direct marketing communications (calls with an operator, paper mail), simply write an e-mail at any time to info@equasystem.com with the subject “unsubscribe from traditional” and you will no longer be disturbed.
You have the right to lodge a complaint with a supervisory authority.
There is no automated decision-making process.
8. NATURE OF PROVISION AND REFUSAL
The provision of data for the purposes referred to in point
A) is optional but necessary. Any refusal to provide the data required with respect to point B) will make it impossible to use the services of the Data Controller.
9. CHANGES TO THE PRIVACY POLICY
The owner reserves the right to modify, update, add or remove parts of this privacy policy at their own discretion and at any time. The data subject is required to periodically check for any changes. To facilitate this verification, the policy will include the date of its last update. The use of the site after the publication of changes will constitute acceptance of those changes.
10. COOKIES AND PRIVACY UNDER THE NEW GDPR
The new General Data Protection Regulation (GDPR) influences how websites can use cookies and track visitors. For more in-depth information on privacy and the actions the site takes in accordance with the requirements set out by the new GDPR.
To learn more about cookies, read the Regulation.
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