INFORMATIVA PRIVACY NOWPR.IT

Fulfilments to the former Art. 12 of the EU 679/2016 REGULATION – Information, communication and transparent modalities for the exercise of the rights of the Person concerned – Information under the articles 13-14 of the EU 679/2016 REGULATION

According to EU 679/2016 Regulation indicating “General regulation on data protection” (“EU/679/2016 Regulation”), Now S.r.l. (below “the Company”), as owner of Owner of the treatment, is obliged to give information on the use of personal data of its clients.
The present information refers to the treatments done by the people, who on behalf of the Company, carry out technical and organizational tasks as described in paragraph 1.

1. Objective and treatment modality. Nature of data grant.

The personal data owned by the Company are directly given by the person whose data are referring to (“Person concerned”). Personal data can furthermore be acquired by the Company to carry our its own activity or by third parties.

Personal data are treated within the normal activity of the Company for the following objectives:
a) objectives strictly connected and in accordance with the relationship with the Person concerned
The grant of necessary personal data for these objectives is not mandatory, however the refusal to give them may generate – in accordance with the relation between the data and required service – the impossibility by the Company to offer the service requested. Their treatment does not require the consent of the Person concerned.
b) fulfilment of obligations by law, by regulations or by the EU law. The grant of personal data necessary for these objectives is mandatory and their treatment does not require the consent of the Person concerned;
c) other objectives connected to the activity of the Company such as:

  • customer satisfaction survey on the quality of services carried out by the Company which can be executed also through specialized companies by personal or phone interviews, surveys, etc.;
  • promotion and sales of products and services of the Company though letters, phone, advertising materials, automated communication systems, e-mail marketing, etc.
  • execution of studies and market researches, done by personal or phone interviews, surveys, delivery of informative material on products and services offered by the Company.

The grant of the necessary data to the objectives as per above c) letter is not mandatory and their treatment requires the consent of the Person concerned.

In relation to the described objectives, the treatment of personal data is done manually or by electronic or automated tools, according to logics strictly connected to the same objectives and anyway to guarantee the privacy and safety of personal data. For certain services, the Company relies on trusted suppliers that as Responsible of data treatment carry out tasks of technical and organizational nature such as: In relation to the described objectives, the treatment of personal data is done manually or by electronic or automated tools, according to logics strictly connected to the same objectives and anyway to guarantee the privacy and safety of personal data. For certain services, the Company relies on trusted suppliers that as Responsible of data treatment carry out tasks of technical and organizational nature such as:
execution of information technology services in relation to the supply, development and maintenance of software and hardware systems necessary or functional to the execution of the services offered by the company, the survey on customer satisfaction or of clients’ needs; accounting activity; email marketing activity.

2. Categories subject to the treatment

In relation to the objectives described in paragraph 1, the Company and other persons that carry out on behalf or in favour of the same, the described tasks at paragraph 1 as per above, treat personal data in relation to: Name and Family Name, address and other identification elements (birth data, place of birth, fiscal code of the legal representative); fiscal code; e-mail; telephone number; bank account details (such as IBAN); data in relation to the family and personal situation; data in relation to education and job of the Person concerned and of the company, personal data of the legal representative. As far as the services and activities indicated in the current information, the Company does not need to treat personal data that the art. 9 of this regulation defines as “particular” (such as personal data to assess health conditions, political and union opinions, religious beliefs, etc.).

3. Categories of people to whom data may be communicated or people who may know as responsible or in charge of data treatment.

In order to carry out the objectives above described as per paragraph 1, the Company needs to communicate personal data of the Persons concerned to third parties, belonging to the following categories:

  • people carrying out on behalf of the Company, technical or organizational tasks indicated in paragraph 1, including the company doing accounting service
  • Authorities and Surpervisory Bodies, Judicial Authorities and in general entities, people, public or private with public affair functions;
  • companies and/or external professionals used by the Company in relation to assistance and consultancy services;
  • third companies for the treatment finalized to promotional initiatives, where the Person concerned has expressed his/her own consent.

Receivers of the described communication in work in total autonomy, as individual owner of the treatment or in some cases are designed by the Company as responsible of the treatment. Their list, constantly updated, is available in the Company.

Some categories of people, as being in charge of the treatment, may access to personal data in order to fulfil their tasks. In particular, the Company has designated as persons in charge data treatment of clients, the employees of the same Company, including system administrators in order to fulfil their tasks, temporary employees used by the Company and trainees.

Also persons designated by the Company as Responsible of the treatment may get informed about personal data, during the execution of their tasks, The identity of the responsible people designated by the Company can be acquired as per the modalities indicted in the next paragraph 5.

Personal data treated by the company and by persons who carry out on behalf of the company the same tasks of technical and organizational nature described at paragraph 1, are not subject of diffusion.

4. Terms of personal data preservation

Personal data will be treated for all the duration of the current contractual terms and also later in order to execute all law compliances and anyway for a period not superior to 10 years of the termination of the contractual relationship or in other cases expressively requested by the law. In case of treatment for promotional activities, till the request of the Person concerned for eventual opposition to the delivery and the willingness to renounce the receiving of commercial communication.

5. Rights of the Person concerned as per Articles 15 and further EU 679/2016 Regulation

We hereby inform that the regulation for the protection of personal data confer to the Persons concerned the possibility to exercise their specific rights, In particular, each person has:

a) the right to access, as foreseen by the Art. 15 of the 679/2016 Regulation, the possibility to access to all his personal information in relation to him or her;
b) amendment right, specifically foreseen by the Art. 16 of the 679/ 2016 Regulation, the possibility to obtain the update of incorrect personal data in relation to him or her without justified delay;
c) right to be forgotten, specifically foreseen by the Art. 17 of the 679/ 2016 Regulation, consisting in the right to cancellation of personal data of the Person concerned;
d) the right of limitation treatment when a situation occurs as foreseen by the Art. 18 of the 679/ 2016 Regulation;
e) right of data portability, specifically foreseen by the Art. 20 of the 679/ 2016 Regulation, the right to obtain in a suitable format the personal data and/or the right to see personal data being transmitted to another owner of treatment without impediments by this Company;
f) right of consent annulment at any moment, specifically foreseen by the Art. 7 of the 679/ 2016 Regulation;
g) the right to file a compliant to the Guarantor in case of violation of data treatment as per Art. 77 of the 679/ 2016 Regulation;
h) the right to call for a jurisdictional complaint in case of illegal data treatment, also in opposition to the obligations taken by the Guarantor as per Art. 78 of the 679/ 2016 Regulation;
i) opposition right at any moment of the treatment for the delivery of commercial and advertising communication or direct sales, sending an email to info@myadvisor.it, specifically requiring the cancellation of the proper name from the advertising mailing list.

6. Owner and Responsible of Treatment

Owner of treatment is Now S.r.l., legal head office in Via Carducci, 17 – 20123 Milan (MI) – Tel. +39 (02) 881290 1 – E-mail: info@nowpr.it

Applicable issues in relation to the exercise of the rights foreseen per law can be send in written form or by mail to the mail address, to the owner of the treatment in the person of the Legal Representative pro-tempore located at the legal head-office of Now S.r.l..

With the same modality it is possible to require the full list of the Responsible persons appointed by Now S.r.l..