INFORMATION NOTICE PURSUANT TO ART. 13 OF THE EU REGULATION N. 2016/679
B810 Srl , (Tax code and VAT number 03378920361) (infra “B810”), in the person of its pro tempore legal representative, with registered office in Reggio Emilia, via E. Lazzaretti, 2/1, DIGICOM Srl , (Tax code and VAT number: 03488160122) (hereinafter “DIGICOM”), in the person of its pro tempore legal representative, with registered office in Legnano (MI), viale Cadorna, 95, and MC REGEM Srl , (Tax code and VAT number: 02891380350) (hereinafter “MC REGEM”), in the person of its pro tempore legal representative, with registered office in Reggio Emilia, via G. Gutenberg, 3, as co-Controllers of the treatment pursuant to art. 4 n. 7) and 26 of EU Regulation no. 2016/679 (GDPR), inform you that, pursuant to art. 13 of the GDPR, your personal data described in the following art. 1 will be processed for the execution of the processing purposes described in the following art. 2.
B810, DIGICOM and MC REGEM can be jointly referred to as “co-data controllers”, and they are part of the same business group pursuant to art. 4 n. 19) of the GDPR: in this regard, they specify that the essential content of the related joint ownership agreement pursuant to art. 26 paragraph 2) of the GDPR can be easily consulted by you by sending a specific request to one of the contact details illustrated in the following art. 7.
- Category of personal data being processed.
1.1. The co-Data Controllers collect and process, in order to pursue the specific processing purpose described in art. 2, your personal data pursuant to art. 4 n. 1) of the so-called GDPR. identifiers (eg email address) in the event that you qualify as a “consumer user” as better described in the GCS (infra “personal data”) or your non-personal data pursuant to art. 3 n. 1) of the EU Regulation no. 2018/1807 (eg so-called corporate email address) (hereinafter “non-personal data”) in the event that you qualify as a “professional user”.
- Purpose of the processing and related legal basis.
2.1. Your personal data (and / or your non-personal data, in the case of a professional user) are processed by the co-Data Controllers, for the execution of the following processing purposes, after obtaining the specific, informed, free and unambiguous consent from the consumer user and / or from the professional user:
- Sending commercial / promotional / advertising / marketing communications (including market research), to be carried out using automated / electronic / telematic methods (e.g. email; mobile app; social page; newsletter) or through non-automated / traditional methods (e.g. paper mail).
In compliance with art. 13 paragraph 2) letter c) of the GDPR, the co-Data Controllers inform you of the right to revoke, at any time, any consent given for the processing purposes described in art. 2.1. letter a), without this event being able, however, to prejudice the lawfulness of the processing based on the consent provided before the revocation.
In this regard, the co-Data Controllers specify that the legal basis of the processing purpose described in art. 2.1. letter a) is found in art. 6 paragraph 1) letter a) of the GDPR, in art. 130 paragraphs 1) and 2) of the Privacy Code and in art. 8 of Legislative Decree n. 70 of 9.4.2003 (Electronic Commerce Code).
- Retention period.
3.1. In compliance with art. 13 paragraph 2) letter a) of the GDPR, the co-controllers of the processing inform you of the following retention period, at the end of which your personal data (and / or your non-personal data, in the case of a professional user) will be subject to cancellation, destruction or anonymization: (i) for the execution of the processing purpose referred to in art. 2.1. letter a): as long as you communicate to the co-Controllers, even separately, your revocation of the consent previously provided for the execution of the processing purpose in question.
4.1. In compliance with art. 13 paragraph 1) letter e) of the GDPR, the co-controllers specify that your personal data (and / or your non-personal data, in the case of a professional user) may be communicated, where appropriate and necessary, to a or more recipients pursuant to art. 4 n. 9) of the GDPR, thus identified, in general, by category: (i) for the execution of the processing purpose referred to in art. 2.1. letter a): authorized parties pursuant to art. 4 n. 10), 29 and 32 paragraph 4) of the GDPR to the processing by each of the co-Data Controllers; consultants or companies of various kinds that provide, in any case, services and / or performances (including professional) connected, even indirectly, to the fulfillment of the purpose in question (eg marketing companies).
4.2. The co-Data Controllers specify that your personal data (and / or your non-personal data) will not be disclosed.
5.1. The co-Data Controllers specify that your personal data (and / or your non-personal data) are stored in automated, partially automated or non-automated archives belonging to or attributable, even indirectly, to the co-Controllers. of the treatment, and located within the European Economic Area (EEA).
- Rights of the interested party.
6.1. In relation only to your personal data, the co-controllers of the processing inform you of the right to exercise the following rights that may be subject to the limitations provided for by art. 2 undecies and 2 duodecies of the Privacy Code: right of access ex art. 15 of the GDPR: the right to obtain confirmation as to whether or not personal data is being processed, as well as the information referred to in art. 15 of the GDPR (e.g. processing purposes, retention period); right of rectification ex art. 16 of the GDPR: right to correct, update or integrate personal data; right to cancellation ex art. 17 of the GDPR: right to obtain the cancellation or destruction or anonymization of personal data, however, where the conditions listed in the same article are met; right to limit the processing ex art. 18 of the GDPR: right with a markedly precautionary connotation, aimed at obtaining the limitation of treatment where the hypotheses governed by the same art. 18; right to portability of the data pursuant to art. 20 of the GDPR: right to obtain personal data, provided to the co-Data Controllers, in a structured format, commonly used and readable by an automatic system (and, where required, to transmit them, directly, to another Data Controller of the processing), where the specific conditions indicated in the same article exist (eg legal basis of consent and / or execution of a contract; personal data provided by the interested party); right to object ex art. 21 of the GDPR: right to obtain the permanent cessation of a specific processing of personal data; right to lodge a complaint to the Supervisory Authority (i.e., the Italian Privacy Guarantor) pursuant to art. 77 of the GDPR: right to lodge a complaint where it is believed that the processing under analysis violates national and community legislation on the protection of personal data.
6.2. In addition to the rights described in the previous art. 6.1., The co-Data Controllers specify that, in relation only to your personal data, there is, where possible and conferring, the right to exercise, on the one hand, the (sub) right provided for by art. 19 of the GDPR (“The data controller communicates to each of the recipients to whom the personal data have been transmitted any corrections or cancellations or limitations of the processing carried out pursuant to Article 16, Article 17, paragraph 1, and Article 18, unless this proves impossible or involves a disproportionate effort. The data controller communicates these recipients to the interested party if the interested party requests it “), to be considered connected and connected to the exercise of one or more rights regulated by art. 16, 17 and 18 of the GDPR; on the other hand, the co-data controllers specify that, in relation only to your personal data, there is, where possible and conferring, the right to exercise the right provided for by art. 22 paragraph 1) of the GDPR (“The interested party has the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or which significantly affects his person”) , subject to the exceptions provided for in paragraph 2 below).
6.3. In compliance with art. 12 paragraph 1) of the GDPR, the co-controllers undertake to provide the communications referred to in Articles. from 15 to 22 and 34 of the GDPR in a concise, transparent, intelligible, easily accessible form and in simple and clear language: this information will be provided in writing or by other possibly electronic means or, at the request of the interested party, will be provided orally provided that the identity of the latter is proven by other means.
6.4. In compliance with art. 12 paragraph 3) of the GDPR, the co-Data Controllers inform you that they undertake to provide information relating to the action taken regarding a request pursuant to art. from 15 to 22 of the GDPR without undue delay and, in any case, at the latest within one month of receipt of the request; this term can be extended by no. 2 months if necessary, taking into account the complexity and number of requests (in this case, the co-Data Controllers undertake to inform of this extension and the reasons for the delay, within one month of receipt of the request).
6.5. The aforementioned rights (except for the right pursuant to art.77 of the GDPR) can be exercised through the contact details illustrated in the following art. 7.
- Contact details.
7.2. The Data Protection Officer (DPO) pursuant to art. 37 of the GDPR, appointed by the co-Data Controllers, can be contacted at one of the following addresses, to be considered alternative and equivalent: email@example.com ; firstname.lastname@example.org ; email@example.com
Reggio Emilia / Legnano, 20.10.2021 (date of last update)
B810 Srl , DIGICOM Srl and MC REGEM Srl
(in the person of their respective pro tempore legal representatives)