INFORMATION STATEMENT PURSUANT TO ART. 13-14 OF THE GDPR (GENERAL DATA PROTECTION REGULATION) no. 2016/679
Pursuant to this regulation, processing will be carried out in full compliance with the principles of propriety, lawfulness, transparency and protection of your confidentiality and rights.
You have been provided with this privacy information statement (“Information Statement”) to illustrate the methods, purposes and time frames pertaining to the collection and use of your personal data. Said Information Statement also provides you details on your rights and the methods in which they can be exercised. This Information Statement is constantly updated on the basis of changes which may occur over time, also for customer satisfaction purposes, in view of our ongoing and thorough analysis of your rights and applicable legal protection.
Therefore, pursuant to article 13 of the GDPR 2016/679, we hereby inform you as follows:
PERSONAL DATA CONTROLLER: Base Protection Srl – a single-member company (hereinafter also “Base Protection” or the “Company”), with registered office in Via dell’Unione Europea, 61 – 76121 Barletta (BT) ”), in the person of its pro tempore legal representative.
Your personal data (provided by yourself, third parties or obtained from public lists, in compliance with statutory limits) may be processed for the following and explicitly declared purposes:
- to ensure compliance with legislation or a regulation, namely to fulfil requirements set forth in legislation, a regulation or European Union legislation as well as provisions established by competent Authorities or Surveillance or Control Bodies (to this effect, you consent is not necessary insofar as data processing is compulsory for ensuring compliance with said obligations/provisions).
- to fulfil a contractual or non-contractual obligation, namely to execute obligations set forth in contracts you have entered into, or in order to ensure your compliance with specific contractual requests before entering into any agreement, also by means of technical means of distance communication between a dedicated call centre (in which case your consent is not necessary, as the processing of data is functional to the relationship or for the execution of requests). The purposes of such processing also include the protection of mutual interests in legal proceedings and for taxation purposes, or compliance with other statutory requirements, such as the keeping of an anti-laundering register, if applicable.
- for direct sales purposes (proposal of services or goods to the data subject): namely to provide you with information and send you informative, sales and advertising material (also via distance communication technologies, including, by way of example: postal correspondence, phone calls, also via automated calling systems, fax, email, SMS or MMS messages or of any other type) on products, services or initiatives of Base Protection, for promotional purposes and to carry out direct sales actions. To this effect, your consent is optional and shall not compromise the continuation of your relationship with Base Protection.
- to carry out profiling: for market research, to check the quality of provided products and services (also by means of phone calls or the sending of questionnaires), for offer optimisation (also by means of focused and selected analyses), for sales communication and statistical research purposes, to apply one or more profiles to you (in order to make suitable sales decisions or to analyse or forecast your personal preferences, behaviour and attitudes, also for sales purposes); in such cases you consent is optional and shall not compromise your relations with the Company.
- for indirect sales purposes, with the transfer of data to third parties or the disclosure of your data to third parties so that they can pursue their own sales activities as specified in point 3 here above. Under such circumstances, your consent is optional and shall not compromise relations with the Company.
WHICH DATA ARE COLLECTED?
Data of a personal nature and personal information provided directly by yourself when registering on our website and upon purchasing products
The Data Controller does not normally process “special” data, also referred to as “sensitive” data, which may disclose the racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or biometric data for univocal identification purposes and data regarding your state of health, sex life or sexual orientation of a person, pursuant to art. 9 of the GDPR, or any data regarding criminal convictions and offences or relevant security measures, pursuant to art. 10 of the GDPR). Said data shall only be processed with your explicit written consent and under one of the circumstances as specified in article 9 paragraph 2 and art. 10 of the regulation. Consent is free and optional, however failure to provide your consent may compromise the pursuit of one or more of the activities you request of Base Protection, specifically regarding facts for which the processing of this type of data is indispensable.
Base Protection does not process the data of anyone under the age of 18 years, website registration requires the conveyance of truthful data.
Consent to the processing of your data may be binding in order to conclude contracts with Base Protection.
Only data for which processing is indispensable for concluding the contract shall be considered binding. You are free to provide or deny consent for any non-binding data, and specifically for profiling, sales communication and marketing purposes.
DATA PROCESSING METHODS
Your data is processed via manual instruments and will undergo manual/paper as well as electronic and automated filing, in accordance with methods strictly correlated with aforementioned purposes. Whenever you express consent to this effect, processing may also occur by means of profiling or data comparison. Base Protection has adopted suitable technical and organisation measures to prevent and limit the risk of loss, deterioration or removal of your data and to ensure remediation within a reasonable period of time, in the event of any data breaches. Processing takes place in such a way so as to guarantee the security, protection and confidentiality of your data.
WHO MAY COME INTO THE KNOWLEDGE OF YOUR DATA?
The following persons may come into the knowledge of your data, in their capacity as data processor or appointed processors: employees, managers and directors or shareholders currently or previously carrying out an administrative role, as defined by the law or by-laws, contract or sales workers subject to a freelance contract who operate within the company’s structure. The company has provided said persons with suitable training and education on safeguarding the conservation, maintenance, updating, security and confidentiality of your data. You are not requested to provide consent for processing by said persons insofar as processing is a necessary and statutory procedure. The data processor and data controller may delegate the processing of your data to sub-processors, duly informed on the correct processing methods to be applied to data.
Beyond the company, your data may be processed by:
- freelance contract workers operating outside the Company;
- suppliers of purchased services;
- freelance sales contract workers operating beyond Company facilities;
- consultants of any kind (by way of example; lawyers, doctors or chartered accountants, engineers, architects, labour consultants or other professions with or without professional registers), who on the Company’s behalf carry out technical, support (especially: legal services, IT services, shipments) and corporate control services.
TRANSFER OF PERSONAL DATA ABROAD
Your data may be transferred to a foreign country. If transferred within the European Union, data shall be processed to the same effect as in Italy. If transferred to a non-European Union country, data shall be processed in compliance with your rights as set forth in the European Regulation. If your data are transferred to a non-European Union Country, they may be processed by persons or entities which guarantee compliance with your rights as set forth in the European Regulation, by means of their voluntary adherence to provisions of a general nature. Data shall always be transferred by means of instruments which guarantee data protection from third party breaches.
DURATION OF DATA CONSERVATION AND THE RIGHT TO BE FORGOTTEN:
Your data will be conserved by the data controller, in compliance with established purposes, for the period of time required to fulfil the contract entered into, to guarantee mutual protection in legal proceedings and comply with statutory obligations, including tax obligations. Data which are not necessary for said purposes will be removed within the maximum time limit established by your guaranteed and recognised right to be forgotten, specified in this information statement, or even within a shorter period of time, unless in breach of the data controller’s rights. Therefore, all the data subject’s data which does not need to be conserved for specific statutory obligations will be deleted within 10 years.
PROFILING: The Company carries out profiling activities using supplied data, with the aim of implementing their own offer, improving provided services, monitoring the quality and efficiency of own suppliers and of activities carried out.
RIGHTS OF THE DATA SUBJECT:
You are also hereby informed of the following rights which you can exercise by contacting the Company at any time:
COMPLAINT: You have the right to submit a complaint at any time to a national authority (National Personal Data Protection Authority), if you believe your rights have been breached.
UPDATING OF DATA: the right to ensure your data are always exact and updated. To this effect, you can report or request the updating of said data at any time.
WITHDRAWAL: right to withdraw consent to data processing unless otherwise required by statutory provisions or for the protection of the data controller’s rights, also in legal proceedings. In any case, a request for withdrawal results in the right to the limitation of processing.
ACCESS: the right to access your data which are processed by the Data Controller, by means of a request which can be submitted in writing or via email. In doing so, it is important you are able to provide us with proof of your identity, perhaps also by means of accessing our data base using your unique credentials. You have the right to access the aforementioned free of charge once, whereas on any successive occasions you may be required to pay a fee. You have the right to obtain a response within thirty days from your request and receive your data in printable formats.
AMENDMENT: the right to the amendment and updating of your data. You may also request their updating and correction at any time if data in our possession is found not to be updated or erroneous. Please notify us of any changes in our data so that we can guarantee the updating of your data.
DELETION: the right to the deletion of data regarding you, on the condition that said data must not be conserved by the Data Controller due to specific statutory obligations such as: obligations set forth in tax, anti-laundering regulations, or for the data controller’s protection in legal proceedings.
OBJECTION: should you challenge the exactness of your data or the lawfulness of processing, or the Data Controller’s right to delete your data, or object to the processing of data and the data controller challenges your objection, you have the right for your data to be conserved without being processed, or processed strictly within limits necessary for the resolution of the dispute which may arise over said data.
INFORMATION: if the Data Controller modifies or deletes your data in full or in part, you have the right to be informed and object to any amendments and deletion.
PORTABILITY: you have the right to transfer your data – conserved or electronically processed, to another operator, within limits set forth in the Regulation, in such as manner as to guarantee their easy reading and acquisition by third parties. Data for which you can exercise your right to transfer (portability) also includes data generated by the automated observation of your activities carried out via the Data Controller’s IT services, such as searches and history of activities carried out
OPTIONAL CONSENT: you have the right to object to the processing of your data, profiling, the use of data for direct marketing, profiling for public interest or for scientific, historic or statistical research purposes.
AUTOMATED PROCEDURES: Under certain circumstances, Base Protection may adopt automated procedures in order to make decisions which regard you and specifically, in order to decide whether and under which conditions contracts are to be concluded with you, directly or via third parties. Under such circumstances, you have the right to request that a human operator carries out an assessment of your position, before you are required to make any binding decisions.
E – COMMERCE: given that your data may be processed for electronic sales purposes, you have the right to ensure that your data are processed in accordance with the best technologically available IT procedures. To this effect, your data may be transferred to third parties in order to carry out technical-IT procedures in full or in part, pertaining to the conclusion of the contract and its execution, such as, by way of example: third party servers, managers of logistics and shipment services. Your consent is always required to this effect and should you fail to consent to the processing of data necessary for the conclusion of any transactions, the Company may be unable to provide you with requested services. Consent to the processing of indispensable data must be provided separately from consent to the acquisition of data which is not indispensable for the conclusion of electronic sale contracts.
NEWSLETTER: Under certain circumstances, Base Protection may process your data in order to notify you of any sales of information initiatives. Under such circumstances, your consent must be explicit and provided separately from other forms of consent. You may also withdraw your consent to this effect at any time.
CONSULTATION: you have the right to receive consultation when assessing security procedures for the processing and protection of your data.
CONTACTS AND COMPLAINTS You may exercise your rights and submit any requests in writing to Base Protection Srl – a single-member company, Via dell’Unione Europea, 61 76121 Barletta (BT) or the the email address: firstname.lastname@example.org.
In any case we always invite you to directly get in touch with Base Protection, so that we can provide you with clarification, information or rapidly resolve any issues you bring to our attention, without prejudice to your right to appeal to the Data Protection Authority