INFORMATION ON THE PROCESSING OF PERSONAL DATA Francesco Zingarelli, with registered office in Verona Via Valverde 46 p.iva 02705660237 (hereinafter, "Owner"), as data controller, informs you pursuant to art. 13 Legislative Decree 30.6.2003 n. 196 (hereinafter, "Privacy Code") and art. 13 EU Regulation n. 2016/679 (hereinafter, "GDPR") that your data will be processed in the following manner and for the following purposes: 1. Subject of Processing The Owner processes personal, identifying data (for example, name, surname, company name, address, telephone, e-mail, bank and payment references) - later, "personal data" or even "data" communicated by you at the time of the conclusion of contracts for the services of the Owner. 2. Purpose of processing Your personal data is processed: A) without your express consent (art. 24 letter a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes: - conclude the contracts for the owner's services; - fulfill the pre-contractual, contractual and fiscal obligations deriving from existing relationships with you; - to fulfill the obligations provided for by the law, by a regulation, by EU legislation or by an order of the Authority (such as in the field of anti-money laundering); - exercise the rights of the Owner, for example the right to defend in court; B) Only with your specific and distinct consent (Articles 23 and 130 of the Privacy Code and Article 7 of the GDPR), for the following Marketing Purposes: - send you via e-mail, post and / or text message and / or telephone contacts, newsletter , commercial communications and / or advertising material on products or services offered by the Data Controller and detection of the degree of satisfaction with the quality of services; - send you commercial and / or promotional communications via e-mail, post and / or text message and / or telephone contacts. We inform you that if you are already a customer of ours, we will be able to send you commercial communications relating to the services and products of the Data Controller similar to those that you have already received, unless you disagree (Article 130 c. 4 of the Privacy Code). 3. Processing methods The processing of your personal data is carried out by means of the operations indicated in art. 4 Privacy Code and to the art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subject to both paper and electronic and / or automated processing. The Data Controller will process the personal data for the time necessary to fulfill the aforementioned purposes and in any case for not more than 10 years from the termination of the relationship for the Service Purposes and for no more than 2 years from the collection of data for the Marketing Purposes. 4. Access to data Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B): - to employees and collaborators of the Data Controller in their capacity as appointees and / or internal processors and / or system administrators; - to third-party companies or other subjects (as an indication, credit institutions, professional offices, consultants, insurance companies for the provision of insurance services, etc.) that carry out activities in outsourcing on behalf of the Owner, in their capacity as external managers of the treatment. 5. Data communication Without the need for express consent (pursuant to art. 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Owner may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies (such as IVASS), Judicial Authorities, insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is obligatory by law for the accomplishment of the said purposes. These subjects will treat the data in their capacity as independent data controllers. Your information will not be disseminated. 6. Data transfer Personal data is stored on servers located at its headquarters, within the European Union. In any case, it is understood that the owner, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller now ensures that the extra-EU data transfer will be in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses envisaged by the European Commission. 7. Nature of data provision and consequences of refusal to answer Providing data for the purposes set forth in art. 2.A) is mandatory. In their absence, we cannot guarantee the Services of art. 2.A). The provision of data for the purposes referred to in art. 2.B) is instead optional. He may therefore decide not to give any data or subsequently deny the possibility of processing data already supplied: in this case, he will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Data Controller. However, he will continue to be entitled to the Services pursuant to art. 2.A). 8. Rights of the interested party In your capacity as interested party, you have the rights referred to in art. 7 Privacy Code and art. 15 GDPR and precisely the rights of: i. obtain confirmation of the existence or not of personal data concerning you, even if not yet recorded, and their communication in intelligible form; ii. obtain the indication: a) of the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with the aid of electronic instruments; d) of the identification data concerning the data controller, data processors and the representative designated pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or appointees; iii. obtain: a) updating, rectification or, when interested, integration of data; b) the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including data which does not need to be kept for the purposes for which the data was collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the event that such fulfillment occurs it proves impossible or involves a manifestly disproportionate use of resources with respect to the protected right; iv. object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by phone and / or mail. Please note that the interested party's right of objection, set out in the previous point b), for direct marketing purposes by automated means, extends to the traditional ones and that the possibility for the interested party to exercise the right of opposition also remains valid only partially. Therefore, the interested party may decide to receive only communications using traditional methods or only automated communications or none of the two types of communication. Where applicable, it also has the rights set forth in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right to limit treatment, right to data portability, right to object), as well as the right to complain to the Guarantor Authority. 9. How to exercise the rights You may at any time exercise your rights by sending: - an e-mail to privacy@lowsi.com 12. Data Controller,and Data ProcessorData Processors The Data Controller is Francesco Zingarelli based in Verona Via Valverde 46 The updated list of data processors and data processors is kept at the registered office of the Data Controller.
