We inform you that for the establishment and execution of contractual relationships, our organization is in possession of your data, acquired verbally, directly or through third parties, qualified as personal by the 2016/679 European Regulation (GDPR). According to the indicated legislation, this treatment will be based on principles of correctness, lawfulness, transparency and protection of your privacy and your rights. Pursuant to article 13 of the GDPR 2016/679, therefore, we provide you with the following information:
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
- Contact Data includes address, email address and telephone numbers
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
- Usage Data includes information about how you use our website
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Processing purpose and data retention:
Your data is processed for the entire duration of the contractual relationship and also subsequently, for contractual requirements and related compliance with legal and tax obligations, and for the effective management of financial and commercial relationships, operations indicated in art. 4 of the Privacy Code and art. 4 n. 2) GDPR. The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the Service Purposes.
Data processing methods:
Data processing will be carried out both with manual and/or IT - telematic tools with organization and processing logics strictly related to the purposes themselves and in any case in order to guarantee the security, integrity and confidentiality of the data, in compliance with organizational and physical measures and logic provided for by the existing provisions.
Mandatory or optional data communication:
Regarding the data that we are obliged to know in order to fulfill the obligations established by law, failure to provide them by you makes it impossible to establish or continue the relationship, within the limits in which such data are necessary for the execution of the same.
Subjects involved in data processing:
The following categories of subjects may become aware of your data, as data processors or persons in charge of the processing: managers, directors and auditors; internal secretarial offices; accounting and billing staff; employees in the marketing of services; agents and representatives.
Personal data disclosure:
Your personal data shall not under any circumstances be disseminated to unknown persons. Your data may be communicated by us, to the extent of their respective and specific competence, to institutions and in general to any public or private subject with respect to which there is an obligation for us (or faculty recognized by law or secondary or community legislation) or the need for communication, as well as to our consultants, within the limits necessary to carry out their assignment at our organization, subject to our letter of appointment which imposes the duty of confidentiality and security.
Your legal rights:
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact the personal data supervisor.
Owner and manager of collected data:
Data collector and responsible is POSBANK Europe srl headquarted in Gardigiano di Scorzè (Italy), via P. Mattarella, 32 / ZIP 30030.
If you have any questions or concerns regarding this Policy, our privacy practices or your communication with Posbank Europe, please contact Posbank Europe in writing: firstname.lastname@example.org