Information to data subjects pursuant to Regulation (EU) 2016/679 (GDPR) and to the Italian applicable legislation (Italian Legislative Decree 196/03)

1.   General information

AGF88 HOLDING SRL (hereinafter referred to for short also as the “Company”) informs you (and hereinafter you are referred to also as “User”) that, pursuing the purposes stated herein, the Company will process your personal data (or the data of the company/firm that you represent in chase you are acting on its behalf) provided by you. Only the data that are necessary to pursue the purposes stated herein will be requested and processed. Please, bear in mind that you must provide only your data and/or data of the firm/company that your represent. If you are acting on behalf of a company/firm, the activities represented herein will be carried out having regard to said company/firm using the data provided by you and based on the consent given by you to their processing (where consent is required) on behalf of the company/firm that you represent.

 

2.   Purposes and legal basis

The data will be processed by the Company:

  1. After obtaining your consent, in order to be able to respond to your request for information and to do everything that is necessary to comply with your request or requests; the legal basis for the processing is the consent given by you.
  2. In order to comply with any obligation laid down by the applicable law, regulations or EU legislation; the legal basis for the processing is complying with legal obligations;
  3. To pursue legitimate interests, such as that of enforcing or defending a right of the Company; the legal basis is the pursuance of legitimate interests.
  4. In order for the Company to be allowed to send you advertisements and/or information about products/services/initiatives of the Company and of its partners to the e-mail address provided by you in the form (please, be informed that the e-mails may be sent also using automated tools). The legal basis of the processing is: consent

 

3.   Mandatory provision of data

The provision of data for the purposes stated in point 2 letter A of the information to data subjects is optional; nonetheless, any failure to provide them will entail the impossibility to respond to the request. The consent to the data processing for the purposes stated in point 2 letter A of the information to data subjects is optional; nonetheless failure to give consent (specifying that consent may be withdrawn at any time and with no obligation to state the reason, notifying its withdrawal to the Company) will entail the impossibility to respond to the request. The provision of the data that are necessary for the purposes stated in point 2 letters B and C of this information to data subjects is necessary and any failure to provide them will entail the impossibility to process said data and therefore to respond to the request.

It is up to you to decide whether to provide your personal data/the data of the company/firm that you represent for the purposes stated in point 2 (D) of this information to data subjects as well as to decide whether to give your consent or not; therefore, your decision not to provide the data or not to give your consent will have no consequences other than that of not receiving advertisements and information from the Company (so with no consequence whatsoever on the other purposes) or that of not receiving them to any addresses that you have not given. Furthermore, please bear in mind that, if you give your consent to the processing for the purposes stated in point 2 (D) of this information to data subjects, you will always have the right to withdraw your consent at any time and with no obligation to give any reason (and therefore the right to object to the processing and activities under said point) notifying the Company of it.

 

4. Categories of data recipients

For the purposes stated in points 2 (A) and 2 (B) your data will not be communicated to any third party. For the purposes stated in point 2 (B) of this information to data subjects, the data may be communicated, only where necessary, to public administration bodies, judicial authorities and the police.

For the purposes stated in point 2 (C) of this information to data subjects, the data many be communicated, only where necessary, to lawyers-legal advisors, public administration bodies, judicial authorities, the police, and the postal service (as the postal service would see the address to which any written notices are sent by post)

The Company will communicate only the data that are strictly necessary to pursue the individual purposes stated in this information to data subject. 

The Company may appoint all the persons specifically tasked with the processing of strictly necessary data as persons in charge of data processing on its behalf (and therefore said persons in charge will come to know the data and may be persons working in the sector the request is addressed to, persons engaged in the website management, also external to the Company, and consultants, also external to the Company - e.g., legal advisors, IT engineers, persons working with the information systems, also external to the Company, persons engaged in managing the relations with the public, also external to the Company). The Company has also identified some Data Processors (and it has appointed them) that may come to know only the data that as strictly necessary to perform the tasks assigned to them (such as companies from which IT and website management services are outsourced, the parent company, call centers and, mote in general, companies and firms that perform activities instrumental to those of the Company, such as consulting companies and firms). The list of data processors can be obtained from the Company sending the related request to the addressed given in point 6 of this information to data subjects.

 

5. Storage of the data

The data may be stored and processed by the Company for the time necessary to pursue the purposes stated in this information to data subjects. The period for which the data are stored is as follows:

  • To comply with obligations laid down by the applicable law, regulations and EU legislation, the data may be stored for the time required by said applicable law, legislation and regulations;
  • To pursue the purposes stated in point 2 (A) of this information to data subjects, the data may be stored until response is given to the request for information;
  • To pursue the purposes stated in point 2 (D) of this information to data subjects, the data may be stored until consent is withdrawn or their erasure is requested, without prejudice to any longer period required by law the data shall be stored for as evidence
  • In any case, all the data may be stored for the time necessary to enforce or defend a right of the Company in accordance with the Italian and EU applicable legislation.

 

6. Data Controller and Data Protection Officer

The Data Controller is: AGF88 HOLDING SRL, having its registered office at Via del Palù, 7/D, 35018 – San Martino di Lupari (PD – Italy), phone +39 049 99888 e-mail [email protected].

For the time being, the applicable law does not require that the Company has a Data Protection Officer; should the appointment of a Data Protection Officer become required, that will be stated and the Data Protection Officer’s contact details will be given on the Company’s website https://www.agf88holding.it, which users are invited to periodically visit for any updates to this privacy policy and information to data subjects.

 

7.  Rights

Please, be informed that, in accordance with the GDPR, the data subject has the right to obtain, from the Company (sending the related request to the contact details given above), access to his or her personal data, the rectification of said data, their erasure or restriction to their processing, and the portability of the data.; furthermore, the data subject has the right to object to the processing of his or her personal data, again notifying the Company, and to exercise the other rights set out in Chapter 3 section 1 of the GDPR including the right to withdraw consent, where applicable: the withdrawal of consent shall not prejudice the lawfulness of the processing based on the consent given before its withdrawal.

 

8. Complaints

If the User believes that the processing of his or her personal data breaches the GDPR and any other applicable legislation on personal data protection, the User has the right to lodge a complaint with the Italian Data Protection Authority (Autorità Garante della Protezione dei dati personali) whose contact details can be found on the website www.garanteprivacy.it.

 

9.  Processing method

Please, be informed that your data will be processed using IT tools and on paper/manually and adopting appropriate systems to ensure the protection of their confidentiality. All the data will be stored and processed ensuring their confidentiality and in compliance with all applicable legislation (and therefore in compliance with the principles of fairness, lawfulness, transparency and protection of confidentiality and rights) and with logics strictly linked to the purposes stated in this information to data subjects. Only the processing operations that are necessary to pursue the purposes stated in this information to data subject will be performed on the data. As regards the Company, the data will be stored at its headquarters or server farm, while, as regards the data processors, at their headquarters or server farms. The data communicated to third parties will be independently stored and processed by the third parties concerned. The data will be organized also in databanks-databases.

 

Information to data subjects updated on 15 July 2022

 

The previous versions of information to data subjects can be obtained sending the related request to the Company to the addresses given above.