Dear Sir/Madam,

 

Pursuant to Articles 13 and 14 of EU Regulation 2016/679 on the use and processing of personal information, which safeguards the rights and freedoms of natural persons, we have the legal obligation to inform users about how their personal information is used and processed.

 

The present Privacy Policy provides detailed information on how our company uses the personal information collected via our online portal/website.

 

As data collector, we are responsible for collecting and using your personal information for the purpose of running our business activities. In particular, the present document will inform you about which information we use, the purpose of use of the same, how this information is shared, how long it is stored in our database, your legal rights and how you can exercise these rights.

 

  1. Name and contact details of the data collector

 

The data collector is: ELMECO SRL

The contact details are as follows:

  • e-mail: info@com
  • tel: 00-39-081.5055724

 

 

  1. Use of Personal Information

 

The use of your personal information includes any operation or series of operations indicated in Article 4, sub-section 2, of EU Regulation 2016/679 or, more precisely, any process or series of processes carried out, with or without the aid of automated processes, used to manage certain personal information or all of an individual’s (data  subject’s) personal information, such as the collection, registration, organisation, structuring, storage, adaption, amendment, extraction, consultation, use, transmission, communication and sharing, or any other form of provision, comparison or interconnection, limitation, erasure or destruction of the same.

 

More specifically, your information is collected by ELMECO SRL on its online portal/website for the following purposes:

 

  • Use of the online portal/website and its functions;
  • Use of the services provided on the online portal/website;
  • To supply the services requested during navigation of the online portal/website, including the collection, storage and elaboration of data for technical and operational purposes;
  • To supply the registration services requested by the user on the online portal/website and create your user account and profile, including the collection, storage and elaboration of said information for the operational, technical and administrative management of the commercial relationship (and the created user account and profile), to provide services and send notifications to the users about the supply of said services;
  • Management of relationships with the authorities and third-party public entities in the case of specific requests and to comply with the laws in force.

 

 

 

 

  1. Category of Personal Information Used

 

The categories of personal information we may collect are as follows:

 

  • Your identity and personal details (e.g. name, surname, place of birth, gender, photo);
  • Contact details (e.g. address, email address);
  • Navigation data (e.g. cookies).

 

The information collected on the online portal/website is handled with the support of information and telephone technologies and is protected by adequate and suitable security measures to ensure the integrity and confidentiality of the same.

 

The information will be recorded in an appropriate database and all information will be strictly and exclusively used for the purpose of navigating the online portal/website, as failure to provide this information could prevent or disable navigation of some or all of the features and services on the website

 

We will never ask you for information about your race or ethnicity, political opinions, religious or philosophical beliefs, membership of trade unions, genetic information or data that regards your sexual orientation, unless said information is required for legal purposes. It is hereby understood, that should it be necessary to request such information, we will notify you in advance, requesting your explicit consent.

 

  1. Source of Information

 

The information used is provided by the user on our online portal/website when they navigate the same or when the user enters information into any of the forms on out online portal/website.

 

 

  1. Legal Basis for the Use of Personal Information

 

We  use your information for the following purposes:

 

  • To execute any contract in relation to the services and functionalities provided on our online portal/website;
  • To comply with legal obligations, regulations and orders of the authorities;
  • To satisfy the legitimate commercial interests of the company, more specifically, to implement and develop our products or services, improve our risk management policies and to defend our legal rights;
  • Information used for marketing purposes require your explicit consent and can be withdrawn at any time.

 

 

  1. Recipients of the Personal Information

 

The information will be used by adequately qualified subjects, using both electronic and non-electronic means, which are configured is such a way as to guarantee the confidentiality of your personal information.

Your personal information may also be shared with external collaborators for the purposes outlined above.

 

 

 

  1. Transfer of Information to Another Country (where applicable)

 

We do not foresee the transfer of personal information to other countries or international organisations.

However, the company hereby reserves the right to use cloud services. In this case, the suppliers of the services will be selected according to their ability to n provide adequate security guarantees, in accordance with Article 46 of the afore cited EU Regulation.

 

 

  1. Data Retention Period

 

The time period for which your personal information will be retained, and used for the above cited purposes, will depend on the related services for which you provided your information. Your personal information, which may be recorded on protected electronic devices or in paper form, will be appropriately retained and protected. Furthermore, your personal information will not be shared.

 

 

  1. Rights of the Data Subjects

 

To provide an increased guarantee for the use of the data subject’s personal information held by the data collector, the EU Regulation (GDPR) contains a specific section about how the  data subject can exercise their rights. These rights are as follows:  –

 

  • The data subject’s right to access the information (art. 15);
  • The right to amend the information (art. 16);
  • Right to erasure (“right to be forgotten”) (art. 17);
  • Right to restrict processing of the information (art. 18);
  • The right to data portability (art. 20);
  • The right to object to the use of the personal information (art. 21).

 

To exercise your rights, the data subject can make a request to the data collector holding said personal information, which can be sent using the Data Subject Exercise of Rights Form.

The data collector must provide the data subject with information about their right to exercise these tights without undue delay and, in any case, no later than a month from receipt of the same request. If necessary, said term may be extended for another two months, depending on the complexity of the case or when there is an elevated number of requests. In this case, the data collector will notify the data subject of the extension and the reasons for the delay within one month from receipt of the request. If the requests of the data subjected are unfounded or excessive (repetitive), the data collector may ask for a financial contribution towards expenses or reject the request.

 

 

9.1       Data Subject Right of Access (art. 15)

The data subject has the right to obtain confirmation from the data collector that their personal information is being used and processed and, in said case, obtain access to the personal information, which included the following:

 

  1. The purpose for which the information is being used;
  2. The category or categories of the personal information in question;
  3. The recipients or category of recipients with which the personal information has been shared, particularly if the recipients are in another country or belong to an international organisation;
  4. The foreseen period of time that the personal information will be stored (data retention period) or, if this is not possible, the criteria used to determine said data retention period;
  5. The existence of the data subject’s rights to ask the data collector of the information to rectify or erase the personal information, restrict the use of the personal information held about them, or object to the use of the same;
  6. The right to make a complaint to a controlling body or authority;
  7. The existence of an automated, decision making process, including profiling and, at least in this case, significant information on the logic applied to its use, as well as the foreseen importance and consequences of said use for the data subject.

 

9.2       Right to Rectification (art. 16)

 

The data subject has the right to ask the data controller to rectify any inaccurate personal information without undue delay.  In consideration of the finalities for which the personal information is used, the data subject has the right to update incomplete information, even by means of a Declaration of Rectification. The data collector is also bound to notify each recipient of these changes, except in the case said notification is impossible or particularly onerous to carry out. Furthermore, the data collector is obliged to notify the recipients of the rectification of the data subject’s personal information should the latter request the same.

 

9.3       Right of Erasure (“right to be forgotten”)  (art. 17);

 

The data subject has the right to ask the data collector to erase their personal information and the data collector is obliged to erase the personal information without undue delay, in the case of the following circumstances:

 

  1. The personal information is no longer necessary for the purpose for which it was originally collected or processed;
  2. The data subject withdraws their consent for the use of the personal information and when there is no longer any legal basis for the use of the same;
  3. The data subject objects to the use of the personal information, pursuant to Article 21, paragraph 1, and when there is no longer any prevailing legitimate motive to continue with the use of the same, or there is an objection to the use of the personal information, in accordance with Article 21, paragraph 2;
  4. The personal information has been used for unlawful purposes;
  5. The personal information must be erased to comply with any legal obligations foreseen by European Union law or inn the Member State of the data collector;
  6. The personal information has been collected for the purpose of sending information about offers of services from the company holding the information (the data collector), pursuant to Article 8, paragraph 1 of EU Reg. 2016/679.

 

 

9.4       Right of Restriction (art. 18)

 

The data subject has the right to ask the data collector to restrict the use of their personal information in the following circumstance:

 

  1. The data subject disputes the accuracy of the personal information, for the period necessary for the data collector to verify the accuracy of said personal information;
  2. The use of the personal information is unlawful if the data subject objects to the erasure of the personal information and, instead, requests the restriction of the same;
  3. When the data collector no longer has any need to process the data, the personal information are necessary for the data subject to ascertain the purpose of their use, or exercise or defend their legal rights in a court of law;
  4. The interested party objects to the use of the information in accordance with Article 21, paragraph 1, EU Reg. 2016/679 whilst awaiting verification with regard to any eventual significant and legitimate reasons that the data collector uses the information of the data subject.

 

9.5       Right of Portability (art. 20)

 

Pursuant to Article  20 of EU Regulation 2016/679, in certain special cases (e.g. data collected and processed by automated means), the data subject has the right to receive the personal information held about them  from the data collector and the latter has the right to send them to another data collector. Where technically feasible, and when this does not harm the rights and freedoms of other individuals, the data subject has the right to obtain direct communication of the personal information that is sent from one data collector to the other.

 

9.6       Right to Object (art.21)

 

The data subject has the right to object  to the use and processing of their personal information, held by the data collector at any time. In this case, with the exception of specific circumstances, the data collector must immediately withhold from using the personal information.

 

In the event the personal information is used for the purpose of direct marketing, including profiling, the data subject has the right to object to the use of their personal information at any time, in the case that such processing is related  to direct marking.

 

In the event the data subject objects to the use of their personal information for direct marketing purposes, said personal information will no longer be subject to use or processing for said purposes.

 

 

 

  1. Withdrawal of Consent

 

Article 7 of the Regulation gives you the power to withdraw your consent to the use of your personal information. You can do this by sending a:

 

  • Registered letter to: ELMECO SRL – Via Circumvallazione esterna, 12 – 80025 Casandrino (NA), Italy.
  • Certified email to: elmeco@legalmail.it

 

 

  1. Automated Decision Making Processes

 

The company does not use any automated decision making processes at the present time.

 

 

  1. Use of Personal Information for Other Purposes

 

In the event that the company needs to use your personal information for purposes other than those stated in the present Privacy Policy, before proceeding with the use of information, you will be sent adequate information and, where necessary, you may be asked to give your consent.

 

 

  1. Disputes

 

With the exception of legal or administrative action, the data subject can present their complaint to the relevant governing body (www.garanteprivacy.it) for the protection of your personal information, unless the data subject does not reside in or work in another Member State of the EU. In the case of the latter, or in the case a violation of the use of the personal information occurs in another country in the EU, the claim will be governed by the governing authority of the country in which the information is used and processed.

 

 

  1. Updates to the Privacy Policy

 

Any eventual amendments to the present Privacy Policy will be promptly communicated to you using an appropriate means of communication.