INFORMATION ON THE PROCESSING OF PERSONAL DATA OF USERS WHO FILL-IN THE “CONTACT” FORM pursuant to Article 13 of Regulation (EU) 2016/679 – GDPR
Definitions
The definitions of the terms used in this Policy are to be understood as per Article 4 of Regulation (EU) 2016/679 (hereinafter also referred to as “GDPR” for brevity).
Identification details of the Data Controller
Identity of the Data Controller:
The Data Controller is Drafinsub S.r.l., VAT number 02627860105, a single-member company subject to the management and coordination of Sparrows Holding S.r.l., with registered office in Milan, Corso Concordia no. 11, postcode 20129 (MI), in the person of its pro tempore legal representative (hereinafter also referred to as the ‘Data Controller’).
Contact details of the Data Controller:
The Data Controller may be contacted:
- by e-mail, at [email protected]
- by mail, writing to the operational headquarters in Genoa, Via Molo Giano sn, postcode 16128 (GE) – Italy.
Purpose of the Policy
With this document, Drafinsub S.r.l. provides the information referred to in Article 13 of the GDPR regarding the processing of personal data provided by you by filling in the form in the “Contacts” section of the Data Controller’s institutional website. (www.drafinsub.com ).
Processing methods
Your personal data will be processed using manual, computerised and telematic tools with logic strictly related to the purposes of processing indicated below, using security measures to ensure the confidentiality of the data in accordance with current regulations and to prevent unauthorised access by third parties or unauthorised personnel.
The data is processed by authorised persons, i.e. employees or collaborators of the Data Controller, who have been previously identified, trained and made aware of the constraints imposed by law and who have been granted specific access to the data for the performance of their duties.
Purpose of processing
The personal data you provide by filling in the form on this website will be processed by the Data Controller in order to respond to your request for information.
Legal basis for processing
The legal basis that legitimises the processing of your personal data for the above-mentioned purpose is Article 6, paragraph 1, letter b) of the GDPR, namely the implementation of pre-contractual measures taken at your request or the execution of a contract to which you are a party.
Retention period for personal data
Your personal data, processed for the above purposes, will be retained in accordance with the principles of proportionality and necessity, for the period necessary to process your request for information.
In the event of the establishment of a contractual relationship, your personal data will be retained in accordance with the legal terms for the retention of contractual documents (usually 10 years).
Mandatory provision of personal data and consequences of failure to provide such data
Pursuant to Article 13, paragraph 2, letter e) of the GDPR, we inform you that the provision of your personal data in the fields marked with an asterisk (*) in this form is mandatory.
Failure to provide your personal data will make it impossible for the Data Controller to receive your request for information and, consequently, to respond to your request or contact you.
Recipients or categories of recipients of personal data
Third parties who provide IT and system support on behalf of the Data Controller and who have been specifically appointed by the Data Controller as data processors pursuant to Art. 28 of the GDPR may have access to the areas where your personal data is stored.
Given the variable nature of the relationships, the updated list of data processors is available at any time by sending a request to: [email protected].
Rights of the Data Subject
The Data Controller informs you that, as a data subject, pursuant to Article 15 et seq. of the GDPR and within the limits prescribed therein, you have:
| Article | Right | Description and Details |
|---|---|---|
| Art. 15 | Right of Access | The right to obtain data and information on the processing, in particular in relation to the type of personal data processed, the purposes for which the personal data are processed, the period of processing and the subjects to whom the data are communicated. |
| Art. 16 | Right to Rectification | The right to obtain the rectification or integration of inaccurate personal data concerning you. |
| Art. 17 | Right to Erasure – ‘Right to be Forgotten’ | The right to obtain the erasure of personal data concerning you in cases where: data are no longer necessary; consent is withdrawn; you object to the processing; or processing is unlawful. Note: Storage is lawful if necessary for legal obligations or legal claims. |
| Art. 18 | Right to Restriction of Processing | The right to obtain that personal data be only stored without being used if: accuracy is contested; processing is unlawful but you oppose erasure; data is needed for legal claims; or you have objected and are awaiting verification. |
| Art. 20 | Right to Data Portability | The right to receive personal data in a commonly used, machine-readable format and/or to request transmission to another controller, where processing is based on contract or consent and is feasible. |
| Art. 21 | Right to Object | The right to object at any time to the processing of your personal data. |
| Art. 22 | Right not to be subject to automated decision-making | The right not to be subject to a decision based solely on automated processing (including profiling) and the right to request human intervention to express your opinion and contest the decision. |
The aforementioned rights may be exercised upon request, to be sent to the Data Controller at the dedicated email address [email protected] or by writing by mail to Drafinsub S.r.l., Via Molo Giano sn, 16128 Genoa (GE) – Italy.
| Article | Right | Description and Details |
|---|---|---|
| Art. 77 | Right to lodge a complaint with the supervisory authority | Without prejudice to any other administrative or judicial remedy, if you, as the data subject, believe that the processing of your personal data by the Data Controller is in breach of Regulation (EU) 2016/679, you have the right to lodge a complaint with the Data Protection Authority (GPDP).
Italian Data Protection Authority: |
| Art. 79 | Right to effective judicial remedy | Without prejudice to any other administrative or non-judicial remedy available, including the right to lodge a complaint with a supervisory authority pursuant to Article 77, every Data Subject shall have the right to an effective judicial remedy where they consider that their rights under the GDPR have been infringed as a result of processing. |
The Data Controller reserves the right to update or amend this policy at any time in the event of regulatory, organisational or technological changes. Any changes will be published on the website.
The Data Controller
Drafinsub S.r.l.