Contact form information ex art. 13 EU Regulation 2016/679
EU Regulation No. 679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter "EU Regulation")
Legislative Decree No. 196 of 30 June 2003 (hereinafter the "Privacy Code"), as amended by Legislative Decree No. 101 of 10 August 2018
Guidelines on promotional activities and the fight against spam "of 4 July 2013 (hereinafter" Guidelines of the Authority for the Protection of Personal Data ")
SPS S.r.l. (hereinafter also the "Company"), a joint-stock company belonging to the SeSa S.p.A. group of companies by virtue of its shareholding in Var Group S.p.a., with registered office in Via Antonio Zanolini 36 AB, 40126 Bologna, VAT no. 04222630370, wishes to inform users of the methods and conditions applied by the Company to the processing operations performed on their personal data. In particular, the information is provided in relation to personal data supplied by users by filling in the "contact form" on the Company's website. The Company acts as "Data Controller", meaning "the natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data". Specifically, personal data may be processed by persons specifically authorised to process the personal data of users and, to this end, duly instructed by the Company. In application of the legislation on the processing of personal data, users who consult and use the Company's website assume the quality of "interested parties", meaning the natural persons to whom the personal data being processed refer.
1. Purposes and legal basis of the processing of personal data
The personal data processed by the Company are directly provided by users, by filling out the contact form, in order to request information or receive assistance. In this case, the processing is based on the execution of specific requests and the fulfilment of pre-contractual measures; the express consent of the users is therefore not necessary. On the basis of the specific and optional consent provided by users, personal data may be processed by the Company in order to send commercial and promotional communications relating to the Company's services and products, as well as information messages relating to the Company's institutional activities. Furthermore, on the basis of the specific and optional consent provided by users, personal data may be communicated to companies belonging to the SeSa S.p.A. business group, in order to allow the latter to send commercial and promotional communications relating to the services and products of the aforementioned companies, as well as information messages relating to the institutional activities of the companies themselves. It should be noted that users may revoke, at any time, the consent already given to the processing of personal data; revocation of consent does not affect the lawfulness of the processing carried out prior to such revocation. It is possible to revoke consent already given to the Company by writing to the following email address: firstname.lastname@example.org
1. Methods and duration of personal data processing
The processing of users' personal data is carried out by company personnel specifically authorised by the Company; to this end, such persons are identified and instructed in writing. The processing may be carried out using IT, telematic or even paper instruments and supports in compliance with the provisions aimed at guaranteeing the security and confidentiality of personal data, as well as, among other things, the accuracy, updating and relevance of personal data with respect to the stated purposes. The personal data collected will be stored in electronic and/or paper archives at the Company's registered office or at its operational headquarters. The personal data provided by the users will be stored in a form that allows their identification for a period of time not exceeding the time necessary to achieve the purposes, as identified in point 1 of this policy, for which the data are collected and processed. In any case, the storage period will be determined in accordance with the terms permitted by applicable laws. In relation to marketing and commercial promotion purposes, in the event that the optional consents requested are given, the personal data collected will be stored for the time strictly necessary for the management of the aforementioned purposes in accordance with criteria based on compliance with current regulations and on fairness as well as on the balance between the legitimate interests of the Company and the rights and freedoms of users. Consequently, in the absence of specific rules providing for different retention periods, the Company will take care to use personal data for the aforementioned marketing and commercial promotion purposes for a reasonable period of time. In any case, the Company will take every care to avoid using personal data indefinitely, proceeding periodically to verify in an appropriate manner the actual persistence of the users' interest in having the processing carried out for marketing and commercial promotion purposes.
3. Nature of the provision of personal data
The provision of personal data is optional but necessary in order to respond to requests for information or assistance made by users. In particular, failure to fill in the fields in the contact form prevents the Company from sending requests for information or assistance. In this case, consent to the processing of personal data is "compulsory" in that it is instrumental to obtaining feedback on requests for information or assistance made to the Company. In all other cases referred to in point 1 of this information notice, processing is based on the provision of specific and optional consent; as already stated, consent is always revocable.
4. Recipients of personal data
The personal data of the users may be communicated, in Italy or abroad, within the territory of the European Union (EU) or the European Economic Area (EEA), in compliance with an obligation of law, regulation or Community legislation; in particular, the personal data may be communicated to public authorities and public administrations for the performance of institutional functions. In addition, without the need for user consent, personal data may be communicated to companies belonging to the SeSa S.p.A. business group for the sole purpose of responding to requests for information or assistance addressed to the Company. Subject to the specific and optional consent of users, personal data may be communicated to companies belonging to the SeSa S.p.A. business group, in order to allow the latter to send commercial and promotional communications relating to the services and products of the aforementioned companies, as well as information messages relating to the institutional activities of the companies themselves.
Personal data shall not be transferred outside the territory of the European Union (EU) or the European Economic Area (EEA).
Personal data will not be disseminated and therefore will not be disclosed to the public or to an indefinite number of subjects.
5. Rights under Articles 15, 16, 17, 18, 20 and 21 of EU Regulation 2016/679
Users, in their capacity as data subjects, may exercise their rights of access to personal data as provided for in Article 15 of the EU Regulation and the rights provided for in Articles 16, 17, 18, 20 and 21 of the EU Regulation regarding the rectification, erasure, restriction of processing of personal data, data portability, where applicable, and opposition to the processing of personal data. The aforementioned rights may be exercised by writing to the following address: email@example.com
If the Company does not reply within the timeframe provided for by the regulations or if the response to the exercise of rights is inadequate, users may lodge a complaint with the Guarantor for the Protection of Personal Data.
Guarantor for the Protection of Personal Data Piazza Venezia n. 11 - 00187 Roma
Fax: (+39) 06.69677.3785
Telephone switchboard: (+39) 06.69677.1
6. Personal Data Protection Manager
It should be noted that SeSa S.p.A., the holding company of the SeSa S.p.A. entrepreneurial group, to which SPS S.r.l. belongs in view of its shareholding in Var Group S.p.A., has appointed a Personal Data Protection Manager for the companies belonging to the same entrepreneurial group.
The Data Protection Officer monitors compliance with data protection regulations and provides the necessary advice. He also cooperates with the Data Protection Authority where necessary.
The Data Protection Officer and his contact details are listed below: