Information on the processing of personal data (pursuant to Article 13 EU Regulation 2016/679)
The current legislation on the processing of personal data defined in accordance with the provisions contained in the EU Regulation 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, hereinafter “EU Privacy Regulation”) contains provisions aimed at ensuring that the processing of personal data is carried out in accordance with the fundamental rights and freedoms of natural persons, with particular regard to the right to protection of personal data.
1. Purpose of Processing and Legal Basis
The processing of personal data is aimed at:
- Selling services through e-shop.
- computer fraud and spam prevention
- billing service.
- receive newsletters.
- marketing activities.
- Service file management (via email or telephone contact);
Personal data may also be used for purposes of Customer profiling, information and commercial promotion of products and services, as well as satisfaction surveys about the quality of those you have already received and market research. In such cases, the processing of personal data will be based exclusively on your free and specific consent. Your consent may be revoked at any time without affecting the lawfulness of the processing carried out before revocation.
All the data in 2 below will be kept for:
- 5 years for data collected for the purposes of: requesting and purchasing services; billing service; receiving newsletters;marketing activities; sending information request; handling service practices (via email or telephone contact).
- 18 months for data collected for the purposes of: computer fraud and spam prevention
Any processing of sensitive data by the Controller is based on the prerequisites set forth in Article 9.2(a) of the GDPR.
2. Types of personal data processed
Within the limits of the above purposes, the Controller will process the following categories of personal data:
- Common personal data regarding biographical data; residence; domicile; behavior in using services; e-mail address
3. Data processing.
For the sake of transparency and in compliance with the principles enunciated in Art. 12 of the GDPR, please note that “processing of personal data” means any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, comparison or interconnection, restriction, erasure or destruction.
The processing of personal data may be carried out with or without the aid of electronic or otherwise automated means and will include, in accordance with the limits and conditions placed by the GDPR, also the communication towards the subjects referred to in point 6 below.
4. Methods of data processing
The personal data being processed are:
- processed lawfully and in accordance with fairness by individuals authorized to perform such tasks, individuals who are constantly identified, properly trained and made aware of the constraints imposed by the GDPR;
- collected and recorded for specified, explicit and legitimate purposes, and used in other processing operations in terms compatible with those purposes;
- accurate and, if necessary, updated;
- relevant, complete and not excessive in relation to the purposes for which they were collected or subsequently processed;
- kept in a form which permits identification of the data subject for no longer than is necessary for the purposes for which they were collected or subsequently processed;
- processed with the support of paper, computer or telematic means and with the use of security measures to ensure the confidentiality of the data subject to whom the data refer and to prevent undue access to third parties or unauthorized personnel.
5. Nature of conferral
The provision of certain personal data is necessary. In case of failure to provide the requested personal data or in case of opposition to the processing of the given personal data, it may not be possible to process the request and/or the management of the requested service and/or the management of the related contract.
Subject to your express consent, the personal data you provide may be used to carry out marketing activities, i.e. to carry out automated activities aimed at profiling and analysis of the use of services; failure to consent to the processing of data and contact details for the purposes indicated does not, however, prevent the contractual relationship from being carried out.
As provided by the Data Protection Authority, consent given for the conduct of marketing activities with automated contact modes (e.g., texting, mms, fax, phonics, e-mail, web applications) also extends to traditional contact modes (paper mail or telephone call with operator). Similarly, your objection to the conduct of marketing activities using automated contact methods also extends to traditional contact methods. This is without prejudice to your right to provide consent or to exercise your right to object in relation to only one of the two ways of carrying out marketing activities.
6. Data Communication and Data Transfer Abroad.
The personal data collected are processed by the staff in charge who need to have knowledge of them in the performance of their activities and by external parties who may act as Joint Data Controllers or Data Processors as appropriate.
The data will not be disseminated.
7. Rights of the data subject.
Pursuant to Articles 15-20 of the GDPR you will be able to exercise specific rights, including to obtain access to your personal data in an intelligible form, rectification, updating or deletion of the same. You will also have the right to obtain from the Company the restriction of processing, you may also object for legitimate reasons to the processing of the data. In the event that you believe that the processing operations concerning you violate the rules of the GDPR, you have the right to lodge a complaint with the Data Protection Authority under Article 77 of the GDPR.
8. Data controller
The data controller, in accordance with Article 4.1.7 of the GDPR, is Hypergrid S.r.l., with registered office in Pavia, Viale Golgi 63.
You will be able to exercise your rights under the Personal Data Protection Code and therefore access your data in order to know them, verify their use, have them corrected and deleted or revoke the authorization for their processing, by writing to:
HyperGrid srl – Data Processor
Viale Golgi 63/A, 27100 Pavia
or by sending an email to privacy@hypergrid.it or by calling +39-0382-528875 or by sending a fax to +39-0382-049303.