Privacy Policy or Privacy Policy
We inform you that, for the execution of the contractual relationships with you in progress, our Company is in possession of data relating to you, acquired also verbally, directly or through third parties, qualified as "personal data" by RE 679/2016 (so-called "RE of security and data protection"). The legislation in question provides first of all that those who process personal data are required to inform the person concerned about what data are processed and about certain elements that qualify the processing, which, in any case, must be carried out correctly, legally and transparently, protecting your privacy and your rights.
Therefore, according to the provisions of art. 13 of R.E 679/2016, we provide the following information:

A) Nature of the processed data
It is our intention to process your personal and fiscal data, as well as the economic data that are necessary for the performance of existing contractual relationships with your company.
To carry out certain treatments of some of your data, it is foreseen that you will give us the consent to the treatment: if it were your intention to grant it to us, please return the signed declaration to us, which you will find at the bottom of this information.

B) Purpose of the processing
Your data is / will be processed in relation to contractual requirements and to the consequent fulfillment of legal and fiscal obligations, as well as to allow an effective management of financial, operational and maintenance relationships.
The data will be processed for the entire duration of the contractual relationship and also subsequently (3 years beyond the expiry of the contractual relationship or the performance of the assignment), for the fulfillment of legal obligations and for administrative and commercial purposes.

C) Processing methods
The processing of data takes place / will take place through the use of tools and procedures that guarantee security and confidentiality and can be carried out both by paper and by electronic means.

D) Obligation or right to provide data and consequences of any refusal
As regards the data that we are obliged to know, in order to fulfill the obligations provided for by laws, regulations and Community legislation, or by provisions issued by Authorities legitimated by law and by supervisory and control bodies, their failure to Your contribution will make it impossible to establish or continue the relationship, to the extent that these data are necessary for the execution of the same.
With regards to the data that we are not obliged to know, we will not evaluate their non-achievement, from time to time, and will determine the consequent decisions related to the importance for us of the data requested and not supplied by you.

 

E) Personal data processing for commercial profiling purposes
It is possible that for marketing and service improvement purposes the Company will process the so-called "profiling" data.
For these treatments, and for the purposes of complete information, reference is made to the definition in art. 4, paragraph 1, no. (4) of the EU Regulation: «profiling»: any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or provide aspects concerning professional performance, the economic situation, health, personal preferences, interests, reliability, behavior, location or movements of said natural person ".
The profiling activity may concern "individual" personal data or "aggregated" personal data deriving from detailed individual personal data. To clarify what "profiling" consists of, you can refer to the following parameters by way of example:
• the data is structured and coordinated based on predefined parameters identified from time to time, depending on the company's needs (regardless of the marketing, contractual, administrative, etc. purposes);
• only after profiling (ie structuring according to predetermined parameters) it is possible to deduce further indications referable to each interested party, further indications (ie the "profile", for example, market segment, active marketing communication services, commercial aptitude, etc. .) that would not derive from the mere informational attitude of the data individually or separately considered.
In other words, from the profiling in the strict sense can obtain the availability of an information heritage that goes far beyond the information considered individually and relating to each interested person; moreover, profiling in the strict sense provides an added value given by the multiple correlations that it is possible to establish between the single data collected, in order to obtain useful additional information. As for the Company's obligations to provide - pursuant to art. 13, paragraph 2, letter f) of the Regulation - information on the logic of the profiling treatment as well as the importance and consequences of such treatment further clarifies the following. Fundamental elements of the profiling treatment will be:
1) the predetermination of the parameters for structuring the data considered individually;
2) the comparison, the crossing, the linking of these data with each other and the comparative analysis carried out based on the predefined parameters, also through automated processes;
3) obtaining a profile through the activities that precede and identifying a client company profile.
The treatments illustrated above will be defined as a whole "Profiling Treatment".

To proceed with a Profiling Treatment it is mandatory to obtain a specific, express, documented, preventive and completely optional consent. Consequently, where the interested party decides to give specific consent, he must be previously informed and aware that the purposes of the processing pursued are of a specific commercial, advertising, promotional and marketing nature in a broad sense based on a Profiling Treatment. With a view to absolute transparency, the Company therefore informs that the data collected on the basis of specific consent may be subject to a Profiling Treatment for the same purposes as set out in paragraph B of this information, while the scope of communication it will eventually be the same already explained for Marketing Treatments in paragraph E.

We draw particular attention to the fact that the provision of personal data to the Company and the provision of consent for Processing for Profiling Purposes for the purposes and with the methods described above are absolutely optional and optional (and in any case revocable without formalities even after the service) .
The data subject to the Profiling Treatment and the related authorized profiles will not be subject to any dissemination.

 

F) Communication and dissemination
Your data will not be "disseminated" by us, with this term meaning the giving of information to undetermined subjects in any way, even through their provision or consultation.
Your data may instead be "communicated" by us, with this term meaning giving knowledge to one or more specific subjects, in the following terms:
• to subjects who can access the data according to the law, regulation or community legislation, within the limits set by these rules (public bodies in charge);
• to subjects who need to access your data for purposes auxiliary to the relationship between you and us, within the limits strictly necessary to perform the auxiliary tasks entrusted to them (for example: credit institutions, shippers, etc.);
• to our consultants, to the extent necessary to carry out their duties in our Company, subject to our letter of assignment which imposes the duty of confidentiality and security in the processing of your data (for example, accountant, labor consultant).

G) Exercise of rights by the interested party.
Pursuant to articles 13, paragraph 2, letters (b) and (d), 15, 18, 19 and 21 of the Regulation, the interested party is informed that:
a) he has the right to ask the Company as the data controller for access to personal data, the correction or cancellation of the same or the limitation of the processing that concern him or to oppose their treatment, in the cases provided;
b) he has the right to lodge a complaint with the Guarantor for the protection of personal data, following the procedures and instructions published on the official website of the Authority on www.garanteprivacy.it;
c) any adjustments or deletions or limitations of the processing carried out at the request of the interested party - unless this proves impossible or involves a disproportionate effort - will be communicated by the Company to each of the recipients to whom the personal data were transmitted. The Company may communicate such recipients to the interested party if the data subject requests it.
The exercise of rights is not subject to any form restrictions and is free.

H) Data controller and data processor
The owner of the processing of your personal data is Modotive, in the figure of the legal representative Mr. Bonaventura Jacopo.