INFORMATION ON THE PROCESSING AND PROTECTION OF PERSONAL DATA
The data controller is Agedi Italia S.r.l., with registered office in Via Cerva 22, Milan, Italy, pec: firstname.lastname@example.org (the «Company» or «Agedi«).
Purpose and legal basis of the processing of data
Agedi processes your personal data for the following purposes:
- The need to carry out an agreement of which you are a part of, or to perform pre-contractual activities at your request. This need represents the legal basis that legitimizes the resulting treatments. The provision of data necessary for these purposes represents, depending on the case, a contractual obligation or an essential requirement for the conclusion of the contract; in its absence, the Company may be unable to establish the relationship or execute it;
- The need to fulfil legal obligations (e.g. obligations under anti-money laundering legislation, provisions issued by Authorities or by the Judiciary, etc.). This need represents the legal basis that legitimizes the resulting treatments. The provision of the data necessary for these purposes means a legal obligation; in the absence of them, the Company would be unable to establish relationships and may have the obligation issue a warning;
- The promotion and sale of the Company’s services or other Agedi Group companies, including carrying out market research (so-called direct marketing). The legal basis that legitimizes the following treatments is your consent, which you are free to give or not and which you can also revoke at any time. The provision of data necessary for these purposes is not mandatory, and the refusal to provide them does not have any negative consequences, except for the impossibility of receiving commercial communications.
Categories of processed data
Agedi processes personal data collected directly from you, or from public registers, which include, by way of example, personal data (e.g. name, surname, address, date and place of birth), contact data (email, social profiles, etc. ), equity and financial information, real estate information, image data (e.g. photo on identity card) and other data attributable to the categories indicated above.
The Company may process customer data to follow up on specific services and operations requested by the customer (e.g. payment for services made with credit/debit cards that determine the processing of particular data). In such cases, the Company will ask the interested party for their consent to process data necessary to follow up on such services or operations.
Recipients or categories of recipients of personal data
The individuals in charge of the following functions within Agedi Group may become aware of your data: IT, administration and accounting, commercial, marketing and communication, operations, general management, human resources, and the legal department. We may disclose your data to the following categories of external subjects: companies belonging to the Agedi Group, when such communication is permitted as a result of a provision of the Privacy Guarantor or a provision of law, service providers (professional and technical) and those subjects to whom such communication must be made in fulfilment of an obligation established by law, by a regulation or by community legislation.
Transfer of data to third countries
We may transfer your personal data to third party recipients established within the European Union or the European Economic Area. This transfer does not require consent as each country of the European Union or the European Economic Area guarantees an adequate level of data protection. They may also be transferred to other countries outside the European Union considered adequate by the European Commission, such as the Principality of Monaco. Personal data may also be transferred to countries that are not part of the European Union or to the European Economic Area (so-called Third Countries) but recognized by the European Commission as having an adequate level of protection of personal data or, if not, only I all Agedi supplies located in the Third Country can provide proper levels of protection of personal data compared to that of the European Union (e.g. by signing the standard contractual clauses provided by the European Commission) and ensure that the rights of the interested parties are always exercised.
Rights of interested parties
The General Data Protection Regulation (the «Regulation«) gives individuals, individual firms or freelancers («Interested«) specific rights, including that of knowing what personal data the Company holds and how these are used (Right of access), to obtain updating, rectification or, if there is interest, integration, as well as the cancellation, transformation into anonymous form or limitation.
Interested parties and legal persons, entities and associations may at any time revoke, where released, their consent to the processing of data for the purpose of sending commercial and advertising material, direct sales or market research (i.e. direct marketing). The Company emphasizes that revocation will only be effective for the future.
Data retention period and Right to cancellation (i.e. Right of oblivion)
Agedi processes and stores your personal data for the entire duration of the contractual relationship, for the execution of the related and consequent obligations, for compliance with applicable legal and regulatory obligations, as well as for its own or third-party defensive purposes and up to the expiry of the statutory limitation period, starting from the closing date of the contractual relationship relating to the single service.
At the end of the applicable retention period, the personal data referable to the interested parties will be deleted or stored in a form that does not allow the identification of the interested party (e.g. irreversible anonymization), unless their further processing is necessary for one or more of the following purposes: i) resolution of pre-litigation or disputes initiated before the expiry of the retention period; ii) to follow up on investigations/inspections by internal control functions or external authorities launched before the expiry of the retention period; iii) to follow up on requests from the Italian or foreign public authorities received/notified to the Company before the expiry of the retention period.
Procedure for the execution of Rights
In order to exercise the rights referred to in paragraph 6, the interested party may contact Agedi at the references indicated in section 1 above.