Privacy policy
INFORMATION FOR DATA PROCESSING PURSUANT TO EU REGULATION 679/2016
Nemesis Srl, with legal headquarters at Via Giuseppe Mengoni n.4, 20121 Milan and operational headquarters located at Corso Mazzini, 84/5 31044 Montebelluna (TV), VAT number 04612670267, (hereinafter, “Data Controller”), as the data controller,
We inform you pursuant to art. 13 of Legislative Decree 30.6.2003 n. 196 (hereinafter, “Privacy Code”) and art. 13 of EU Regulation n. 2016/679 (hereinafter, “GDPR”) that your data will be processed in the following ways and for the following purposes:
SUBJECT OF PROCESSING
The Data Controller processes personal data, identifying (for example name, surname, company name, address, phone, e-mail, bank and payment references - hereinafter “data”) communicated by you at the time of signing the contract and for all other possible services you requested from the Data Controller. Health and criminal data will not be processed except for those you wish to provide us voluntarily, being aware of the non-necessity for the performance of the services requested from us.
PURPOSES OF PROCESSING
Your personal data are processed:
- A) without your express consent (art. 24 lett. a), b), c) of the Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes:
- to carry out the services you requested from the Data Controller for the provision of services such as: digital commerce, integrated marketing, worldwide operations, omnichannel customer experience;
- to fulfill the obligations provided by law (administrative, accounting, tax, and fiscal), by a regulation, by community legislation, or by an order of the Authority;
- to exercise the rights of the Data Controller, for example the right to defense in court;
- B) Only with your specific and distinct consent (arts. 23 and 130 of the Privacy Code and art. 7 GDPR), for the following Marketing Purposes:
- to send you via e-mail, mail and/or SMS and/or phone contacts, newsletters, commercial communications and/or advertising material, services and special offers.
PROCESSING METHODS
The processing of your personal data is carried out through the operations indicated in art. 4 of the Privacy Code and in art. 4 n. 2) GDPR, namely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion, and destruction of data. Your personal data are processed both in paper and electronic form. The data will be processed, elaborated, and stored within our IT systems. The Data Controller will process personal data for the time necessary to fulfill the purposes mentioned above and in any case for no longer than 10 years from the termination of the relationship for administrative service purposes and for no longer than 1 year from the collection of data for Marketing Purposes.
ACCESS TO DATA
Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):
- to employees and collaborators of the Data Controller in their capacity as internal appointees and/or data processors and/or system administrators;
- to third-party companies or other subjects (by way of example, credit institutions, professional firms, insurance consultants, etc.) that carry out outsourcing activities on behalf of the Data Controller, in their capacity as external data processors.
DATA COMMUNICATION
Without the need for explicit consent (pursuant to art. 24 lett. a), b), d) of the Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to judicial authorities in the event that they make an explicit request, as well as to those subjects to whom communication is mandatory by law for the fulfillment of the aforementioned purposes. These subjects will process the data in their capacity as independent data controllers. Your data will not be disseminated.
DATA TRANSFER
Personal data is stored in our IT system and will be used on servers for the storage of data residing both in Italy and in other European countries. It is understood that the Data Controller, if necessary, will have the right to move the servers to server farms located outside the EU. In this case, the Data Controller assures that the transfer of data will take place in accordance with applicable legal provisions, subject to the signing of the standard contractual clauses provided by the European Commission.
NATURE OF DATA PROVISION AND CONSEQUENCES OF REFUSAL TO RESPOND
The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we will not be able to guarantee you the Services of art. 2.A).
RIGHTS OF THE DATA SUBJECT
In your capacity as the data subject, you have the rights referred to in art. 7 of the Privacy Code and art. 15 GDPR, specifically the rights to:
- obtain confirmation of the existence or non-existence of personal data concerning you, even if not yet recorded, and their communication in an intelligible form;
- obtain the indication: a) of the origin of personal data; b) of the purposes and methods of processing; c) of the logic applied in the case of processing carried out with the aid of electronic tools; d) of the identifying details of the data controller, the processors, and the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) of the subjects or categories of subjects to whom personal data may be communicated or who may become aware of it as a designated representative in the territory of the State, of processors or appointees;
iii. obtain: a) the update, rectification or, when interested, the integration of the data; b) the erasure, transformation into anonymous form or blocking of data processed in violation of the law, including those for which retention is not necessary in relation to the purposes for which the data were collected or subsequently processed; c) the confirmation that the operations referred to in letters a) and b) have been brought to the attention, including regarding their content, of those to whom the data have been communicated, except in cases where such fulfillment proves impossible or involves a manifestly disproportionate effort in relation to the protected right;
- to object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if relevant to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising material. It is noted that the right to object of the data subject, as stated in the previous point b), for direct marketing purposes through automated means extends to traditional means and that the data subject retains the possibility to exercise the right to object even partially. Therefore, the data subject may choose to receive only communications through traditional means or only automated communications or none of the two types of communication.
Where applicable, you also have the rights referred to in Articles 16-21 GDPR (Right to rectification, right to erasure, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Supervisory Authority. It is also noted that it will be your duty to promptly communicate the update of your data by email and/or registered letter.
METHODS OF EXERCISING RIGHTS
You may exercise your rights at any time by sending:
- a registered letter to: Nemesis Srl, Corso Mazzini 84/5 - 31044 Montebelluna (TV) ITALY
- an email to the address: privacy@mcs.com
It is noted that for the protection of your rights, Nemesis Srl has appointed a Data Protection Officer, Dr. Gianfranco Sovernigo, who can be contacted at the email address privacy@mcs.com.
DATA CONTROLLER, PROCESSOR AND PERSONS IN CHARGE
The Data Controller is Nemesis Srl, with legal headquarters at Via Giuseppe Mengoni n.4, 20121 Milan and operational headquarters located at Corso Mazzini, 84/5 31044 Montebelluna (TV). The updated list of data processors and persons in charge of processing is kept at the legal headquarters of the Data Controller.
