Privacy policy statement pursuant to art. 13, Regulation (EU) 2016/679 for contacts form
Reference legislation:
- Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “EU Regulation”)
- Italian Legislative Decree no. 196 of 30 June 2003 as amended (hereinafter the “Italian Data Protection Code”)
- Guidelines issued on 4 July 2013with regard to marketing activities and the prevention of spam (hereinafter “Italian Data Protection Authority Guidelines”)
- Recommendation no. 2 of 17 May 2001 on certain minimum requirements for collecting personal data on-line in the European Union, adopted by the European Authorities for the protection of personal data, forming the Working party on the Protection of Individuals with regard to the Processing of Personal Data pursuant to article 29 of Directive 95/46/EC (hereinafter “Recommendation of the Article 29 Working Party”)
The companies belonging to the Var Group S.p.A. group of businesses (hereinafter the “Joint Data Controllers” or “Parties”), or the parent Var Group S.p.A. and its subsidiary and/or associated companies pursuant to article 2359 of the Italian Civil Code, as listed here, hereby provide information to users with regard to the methods and conditions applied by the companies to processing performed on personal data. Specifically, this privacy policy statement is issued with regard to the personal data contributed by users who fill in the “contacts form” on this website. The Parties act in the capacity of “Joint Data Controllers”, defined as “the natural or legal persons, public authorities, agencies or other bodies which jointly determine the purposes and means of the processing”. In concrete terms, processing of personal data may be carried out by parties duly authorised and appointed by the Joint Data Controllers to perform processing on users’ personal data. In application of regulations governing the processing of personal data, users who view and use this website are classified as “data subjects”, meaning the natural persons to whom the data being processed refer.
1. Purpose and legal basis of the processing of personal data
The personal data processed by the Joint Data Controllers are contributed directly by users when they fill in the contacts form provided in order to request information or receive assistance. In this case, processing is based on the fulfilment of specific requests and on compliance with precontractual measures; explicit user consent is therefore not required. On the basis of optional, specific consent supplied by users, the Joint Data Controllers may process personal data in order to send commercial and marketing communications relating to the Joint Data Controllers’ services and products and messages informing users about their corporate activities. Finally, on the basis of optional, specific consent supplied by users, personal data may be disclosed to third-party companies belonging to the product/service categories ATECO J62, J63 and M70 relating to IT and business consultancy products and services). Uses who have already consented to the processing of personal data may withdraw this consent at any time; withdrawal of consent does not affect the lawfulness of any processing performed prior to such revocation. Consent already given to the Joint Data Controllers may be withdrawn at any time using the form accessible via the communications sent to the user’s email address or by emailing digitallaw&[email protected]
2. Methods and duration of processing of personal data
Users’ personal data are processed by company staff specifically authorised by the Joint Data Controllers; all such staff are designated and instructed in writing. Processing may be performed through the use of IT, telematic or also hardcopy media and tools, pursuant to provisions intended to guarantee the security and confidentiality of the personal data, as well as ensuring that the data are accurate, up to date and relevant to the declared purposes. Personal data contributed by users will be stored in a form which enables their identification for a period of time not exceeding that necessary for the pursuance of the purposes, as stated in point 1 of this privacy policy statement, for which the said data are collected and processed. In all cases the storage period is determined in accordance with the terms permitted by the relevant legislation. With regard to marketing and sales promotion purposes, if the optional consents requested are given, the personal data collected will be stored for the time strictly necessary for management of the aforesaid purposes, in accordance with criteria of legal compliance and ethics, and the balancing of the Joint Data Controllers’ legitimate interest with users’ rights and freedoms. Therefore, unless specific norms impose different storage periods, the Joint Data Controllers will ensure that personal data are used for marketing and sales promotion purposes for an appropriate time. In all cases, the Joint Data Controllers will take great care to ensure that personal data are not used for an indefinite period by performing regular checks that processing for marketing and sales promotion purposes is still in users’ interest.3. Nature of the contribution of personal data
The contribution of personal data is optional but necessary in order to enable a response to requests for information or assistance submitted by users. In particular, users who fail to fill in the fields of the contacts form will be unable to send requests for information or assistance to the Joint Data Controllers. In this case, consent to the processing is “compulsory” as it is a necessary precondition for responding to requests for information or assistance submitted to the Joint Data Controllers. In all the other cases covered by point 1 of this privacy policy statement, the processing is based on specific or optional consent; as already stated, consent can be withdrawn at any time.4. Recipients of personal data
Users’ personal data may be disclosed, in Italy or abroad, within the European Union (EU) or the European Economic Area (EEA), in order to fulfil an obligation imposed by law, regulations or EU directives; in particular, personal data may be disclosed to public authorities and public administrations for the performance of their institutional functions. Finally, on the basis of optional, specific consent supplied by users, personal data may be disclosed to third-party companies belonging to the product/service categories ATECO J62, J63 and M70 relating to IT and business consultancy products and services). Personal data will not be transferred outside the European Union (EU) or European Economic Area (EEA). Personal data will not be published or disseminated, i.e. divulged to the public or an unlimited number of parties.5. Rights pursuant to articles 15, 16, 17, 18, 20 and 21 of the EU Regulation
Users, as data subjects, can exercise their rights to access their personal data provided for by article 15 of the EU Regulation and the rights provided for pursuant to articles 16, 17, 18, 20 and 21 of the same Regulation regarding rectification, erasure, restriction of the processing, portability (where applicable), and the right to object to the processing of your personal data, by the procedures established by art. 12 of the EU Regulation and within the limits established by art. 2-undecies of the Italian Data Protection Code. Your rights may be exercised in relation to each of the Joint Data Controllers in accordance with art. 26 of the EU Regulation by writing to: digitallaw&[email protected]6. Right to lodge a complaint with the Italian Data Protection Authority under art. 77 of the EU Regulation
Users who believe that the processing of personal data concerning them through the “contacts form” on this website breaches the provisions of the Regulation are entitled to lodge a complaint with the Italian Data Protection Authority. The contact details for the Italian DPA are:Garante per la Protezione dei Dati Personali
Piazza Venezia n. 11 - 00187 Roma (Italy)
Fax: (+39) 06 69677 3785
Telephone: (+39) 06 69677 1
Email: [email protected]