INFORMATION NOTICE PURSUANT TO ARTICLE 13 OF EU REGULATION 2016/679

– CLIENTE/PARTNER –

 

 

PROGETTARE ZEROSEI S.r.l. Società Benefit, (Tax code and VAT number: 02001330352) (hereinafter “P06”), in the person of its legal representative pro tempore, with registered office in Reggio Emilia (RE), via A. Gramsci, 54/V, in its capacity as Data Controller pursuant to Articles 4 no. 7) and 24 of EU Regulation no. 2016/679 (GDPR), informs, pursuant to Article 13 of the GDPR, that the personal data better described in Article 1 below will be processed for the performance of the purpose described in Article 2.

 

1. Category of data being processed

1.1. P06 collects and processes, for the purpose of pursuing the purpose of the processing referred to in Art. 2, the personal information pursuant to Art. 4 n. 1) of the GDPR referring to you as a customer, including any information referring to your users/employees/collaborators involved in the relevant contractual relationship with P06 (hereinafter only “personal data”).

 

2. Purpose of processing and legal basis.

2.1. Personal data are processed by P06 for the performance of the following processing purpose:

a. Execution of a pre-contractual measure (e.g. quotation) and/or a contractual relationship, including the related and consequent regulatory and administrative requirements.

In compliance with Article 13 paragraph 2) letter e) of the GDPR, P06 specifies that failure to provide the requested personal data may possibly result in the impossibility to fully and correctly execute the processing purpose described in Article 2.1. letter a).

In this regard, P06 points out that the legal basis for the processing purpose described in Art. 2.1. letter (a) is to be found in Art. 6 paragraph 1) letter b) and c) of the GDPR.

2.2. Personal data are/may be processed, by P06, for the performance of the following processing purpose:

b. Execution, by P06, of the so-called external/dissemination teaching activities (e.g. presentations/participation in projects/competitions/conferences/seminars/masters/specialisation or training courses/conventions; papers; case/project study discussions; workshops; partnerships; magazines/journals, including specialised ones), aimed at presenting, at best, the teaching/training/educational services (including innovative ones) offered, developed and designed, even indirectly, by P06.

In compliance with Art. 13 paragraph 1) letter d) of the GDPR, P06 specifies that the legitimate interest pursuant to Art. 6 paragraph 1) letter f) of the GDPR pursued through the processing purpose referred to in Art. 2.2. letter b) consists in presenting to the best of its ability, before public or private operators/stakeholders, the services, including innovative, educational/training services offered, developed and designed, even indirectly, by P06.

In this regard, P06 points out that the legal basis of the processing purpose referred to in Art. 2.2 letter b) is to be found in Art. 6 paragraph 1) letter f) of the GDPR.

 

3. Retention period.

3.1. In compliance with Article 13 paragraph 2) letter a) of the GDPR, P06 communicates the following retention periods/criteria, after which personal data may be subject to erasure, destruction or anonymization: (i) for the performance of the processing purpose referred to in Article 2.1. letter a): no. 1 year, commencing from the final conclusion of a pre-contractual measure (which may be extended in order to comply with a regulatory obligation (even if already existing) or to assert or defend a right, even in a court of law), in the event that the pre-contractual measure has not resulted in a contractual relationship with P06: where the latter occurs, P06 also specifies that the personal data shall be retained up to 10 years pursuant to Articles 2220 and 2946 of the Civil Code, commencing from the definitive termination of the relevant contractual relationship, which may be extended, if necessary, in order to comply with a legal obligation (also in case of a new one) or to assert or defend a right, even in court; (ii) for the performance of the processing purpose referred to in Art. 2.2. letter b): until the objection.

 

4. Target audience.

4.1. In compliance with the art. 13 paragraph 1) letter e) of the GDPR, P06 specifies that personal data may be communicated, if appropriate and necessary, to one or more recipients pursuant to art. 4 no. 9) of the GDPR, identified as follows, generally, by category: (i) for the execution of the processing purposes referred to in Art. 2.1. letter a): subjects authorized to process by P06; consultants or companies of various kinds that provide services, however, connected, even indirectly, to the processing purpose in question; (ii) for the performance of the processing purpose referred to in Art. 2.2. letter b): parties authorized for the processing by P06; consultants or companies of various nature providing services, however connected, also indirectly, to the processing purpose in question (e.g. communication companies); parent companies/associates of P06.

 

5. Transfer.

5.1. Personal data are/may be stored in automated, partially automated or non-automated files belonging to or otherwise traceable, even indirectly, to P06, and located within the European Economic Area (EEA).

 

6. Data subject’s rights.

6.1. In relation to personal data, P06 informs you that you may exercise the following rights, which may be subject to the limitations provided in art. 2 undecies and 2 duodecies of the Privacy Code: right of access under art. 15 of the GDPR: right to obtain confirmation as to whether or not personal data are being processed, as well as the information under art. 15 of the GDPR (e.g. purpose of processing, storage period); right to rectification under art. 16 of the GDPR: right to correct, update or supplement personal data; right to erasure under art. 17 of the GDPR: the right to obtain the erasure or destruction or anonymisation of personal data, where, however, the conditions listed in the same article apply; right to restriction of processing under art. 18 of the GDPR: a right with a markedly precautionary connotation, aimed at obtaining the restriction of processing where the cases governed by art. 18; right to data portability under art. 20 of the GDPR: right to obtain personal data, provided to the Controller, in a structured, commonly used and machine-readable format (and, where required, to transmit them, in a direct way, to another Controller), where the specific conditions indicated by the same article exist (e.g. legal basis of consent and/or performance of a contract; personal data provided by the data subject); right to object under art. 21 of the GDPR: right to obtain the cessation, on a permanent basis, of a given processing of personal data; right to lodge a complaint with the Supervisory Authority (i.e., Italian Privacy Guarantor) pursuant to art. 77 of the GDPR: right to lodge a complaint where it is considered that the processing under analysis violates national and EU legislation on the protection of personal data.

6.2. In addition to the rights described in art. 6.1. above, the Controller informs you that, in relation to personal data, you are entitled, where possible and appropriate, to exercise, on the one hand, the (sub)right provided in art. 19 of the GDPR (“The controller shall communicate to each of the recipients to whom the personal data have been transmitted any rectification or erasure or restriction of processing carried out pursuant to art. 16, art. 17(1) and art. 18, unless this proves impossible or involves a disproportionate effort. The data controller shall inform the data subject of such recipients if the data subject so requests”), to be considered connected and related to the exercise of one or more of the rights regulated in art. 16, 17 and 18 of the GDPR; on the other hand, the Controller specifies to you that, in relation to personal data, there is, where possible and conferring, the right to exercise the right provided in art. 22 paragraph 1) of the GDPR (“The data subject shall have the right not to be subject to a decision which is based solely on automated processing, including profiling, and which produces legal effects concerning him/her or significantly affects him/her in a similar way”), subject to the exceptions provided for in paragraph 2) below.

6.3. In accordance with art. 12 paragraph 1) of the GDPR, P06 undertakes to provide the communications referred in art. from 15 to 22 and 34 of the GDPR in a concise, transparent, intelligible, easily accessible form and in plain and simple language: such information shall be provided in writing or by other electronic means where appropriate or, at the request of the data subject, shall be provided orally provided that the identity of the data subject is proven by other means.

6.4. Pursuant to art. 12 paragraph 3) of the GDPR, P06 informs you that it undertakes to provide you with the information relating to the action taken in respect of a request pursuant to art. from 15 to 22 of the GDPR without undue delay and, in any event, at the latest within one month from the receipt of such request; such period may be extended by 2 months if necessary, taking into account the complexity and number of requests (in such case, P06 undertakes to inform you of such extension and of the reasons for the delay, within one month from the receipt of the request).

6.5. The rights described above (with the exception of the right pursuant to art. 77 of the GDPR) may be exercised via the contact details set out in art. 7 below.

 

7. Contact details.

7.1. P06 can be contacted at the following address: info@progettarezerosei.it

7.2. The Data Protection Officer (DPO) pursuant to art. 37 of the GDPR, appointed by P06, can be contacted at the following address: privacydpoprogettarezerosei@baldiandpartners.it.

 

Reggio Emilia (RE), 16.12.2021 (date of last update).

 

PROGETTARE ZEROSEI S.r.l. Società Benefit

(in the person of its legal representative pro tempore)

– CLIENTE/PARTNER –

 

PROGETTARE ZEROSEI S.r.l. Società Benefit, (Tax code and VAT number: 02001330352) (hereinafter “P06”), in the person of its legal representative pro tempore, with registered office in Reggio Emilia (RE), via A. Gramsci, 54/V, in its capacity as Data Controller pursuant to Articles 4 no. 7) and 24 of EU Regulation no. 2016/679 (GDPR), informs, pursuant to Article 13 of the GDPR, that the personal data better described in Article 1 below will be processed for the performance of the purpose described in Article 2.

 

1. Category of data being processed

1.1. P06 collects and processes, for the purpose of pursuing the purpose of the processing referred to in Art. 2, the personal information pursuant to Art. 4 n. 1) of the GDPR referring to you as a customer, including any information referring to your users/employees/collaborators involved in the relevant contractual relationship with P06 (hereinafter only “personal data”).

 

2. Purpose of processing and legal basis.

2.1. Personal data are processed by P06 for the performance of the following processing purpose:

a. Execution of a pre-contractual measure (e.g. quotation) and/or a contractual relationship, including the related and consequent regulatory and administrative requirements.

In compliance with Article 13 paragraph 2) letter e) of the GDPR, P06 specifies that failure to provide the requested personal data may possibly result in the impossibility to fully and correctly execute the processing purpose described in Article 2.1. letter a).

In this regard, P06 points out that the legal basis for the processing purpose described in Art. 2.1. letter (a) is to be found in Art. 6 paragraph 1) letter b) and c) of the GDPR.

2.2. Personal data are/may be processed, by P06, for the performance of the following processing purpose:

b. Execution, by P06, of the so-called external/dissemination teaching activities (e.g. presentations/participation in projects/competitions/conferences/seminars/masters/specialisation or training courses/conventions; papers; case/project study discussions; workshops; partnerships; magazines/journals, including specialised ones), aimed at presenting, at best, the teaching/training/educational services (including innovative ones) offered, developed and designed, even indirectly, by P06.

In compliance with Art. 13 paragraph 1) letter d) of the GDPR, P06 specifies that the legitimate interest pursuant to Art. 6 paragraph 1) letter f) of the GDPR pursued through the processing purpose referred to in Art. 2.2. letter b) consists in presenting to the best of its ability, before public or private operators/stakeholders, the services, including innovative, educational/training services offered, developed and designed, even indirectly, by P06.

In this regard, P06 points out that the legal basis of the processing purpose referred to in Art. 2.2 letter b) is to be found in Art. 6 paragraph 1) letter f) of the GDPR.

 

3. Retention period.

3.1. In compliance with Article 13 paragraph 2) letter a) of the GDPR, P06 communicates the following retention periods/criteria, after which personal data may be subject to erasure, destruction or anonymization: (i) for the performance of the processing purpose referred to in Article 2.1. letter a): no. 1 year, commencing from the final conclusion of a pre-contractual measure (which may be extended in order to comply with a regulatory obligation (even if already existing) or to assert or defend a right, even in a court of law), in the event that the pre-contractual measure has not resulted in a contractual relationship with P06: where the latter occurs, P06 also specifies that the personal data shall be retained up to 10 years pursuant to Articles 2220 and 2946 of the Civil Code, commencing from the definitive termination of the relevant contractual relationship, which may be extended, if necessary, in order to comply with a legal obligation (also in case of a new one) or to assert or defend a right, even in court; (ii) for the performance of the processing purpose referred to in Art. 2.2. letter b): until the objection.

 

4. Target audience.

4.1. In compliance with the art. 13 paragraph 1) letter e) of the GDPR, P06 specifies that personal data may be communicated, if appropriate and necessary, to one or more recipients pursuant to art. 4 no. 9) of the GDPR, identified as follows, generally, by category: (i) for the execution of the processing purposes referred to in Art. 2.1. letter a): subjects authorized to process by P06; consultants or companies of various kinds that provide services, however, connected, even indirectly, to the processing purpose in question; (ii) for the performance of the processing purpose referred to in Art. 2.2. letter b): parties authorized for the processing by P06; consultants or companies of various nature providing services, however connected, also indirectly, to the processing purpose in question (e.g. communication companies); parent companies/associates of P06.

 

5. Transfer.

5.1. Personal data are/may be stored in automated, partially automated or non-automated files belonging to or otherwise traceable, even indirectly, to P06, and located within the European Economic Area (EEA).

 

6. Data subject’s rights.

6.1. In relation to personal data, P06 informs you that you may exercise the following rights, which may be subject to the limitations provided in art. 2 undecies and 2 duodecies of the Privacy Code: right of access under art. 15 of the GDPR: right to obtain confirmation as to whether or not personal data are being processed, as well as the information under art. 15 of the GDPR (e.g. purpose of processing, storage period); right to rectification under art. 16 of the GDPR: right to correct, update or supplement personal data; right to erasure under art. 17 of the GDPR: the right to obtain the erasure or destruction or anonymisation of personal data, where, however, the conditions listed in the same article apply; right to restriction of processing under art. 18 of the GDPR: a right with a markedly precautionary connotation, aimed at obtaining the restriction of processing where the cases governed by art. 18; right to data portability under art. 20 of the GDPR: right to obtain personal data, provided to the Controller, in a structured, commonly used and machine-readable format (and, where required, to transmit them, in a direct way, to another Controller), where the specific conditions indicated by the same article exist (e.g. legal basis of consent and/or performance of a contract; personal data provided by the data subject); right to object under art. 21 of the GDPR: right to obtain the cessation, on a permanent basis, of a given processing of personal data; right to lodge a complaint with the Supervisory Authority (i.e., Italian Privacy Guarantor) pursuant to art. 77 of the GDPR: right to lodge a complaint where it is considered that the processing under analysis violates national and EU legislation on the protection of personal data.

6.2. In addition to the rights described in art. 6.1. above, the Controller informs you that, in relation to personal data, you are entitled, where possible and appropriate, to exercise, on the one hand, the (sub)right provided in art. 19 of the GDPR (“The controller shall communicate to each of the recipients to whom the personal data have been transmitted any rectification or erasure or restriction of processing carried out pursuant to art. 16, art. 17(1) and art. 18, unless this proves impossible or involves a disproportionate effort. The data controller shall inform the data subject of such recipients if the data subject so requests”), to be considered connected and related to the exercise of one or more of the rights regulated in art. 16, 17 and 18 of the GDPR; on the other hand, the Controller specifies to you that, in relation to personal data, there is, where possible and conferring, the right to exercise the right provided in art. 22 paragraph 1) of the GDPR (“The data subject shall have the right not to be subject to a decision which is based solely on automated processing, including profiling, and which produces legal effects concerning him/her or significantly affects him/her in a similar way”), subject to the exceptions provided for in paragraph 2) below.

6.3. In accordance with art. 12 paragraph 1) of the GDPR, P06 undertakes to provide the communications referred in art. from 15 to 22 and 34 of the GDPR in a concise, transparent, intelligible, easily accessible form and in plain and simple language: such information shall be provided in writing or by other electronic means where appropriate or, at the request of the data subject, shall be provided orally provided that the identity of the data subject is proven by other means.

6.4. Pursuant to art. 12 paragraph 3) of the GDPR, P06 informs you that it undertakes to provide you with the information relating to the action taken in respect of a request pursuant to art. from 15 to 22 of the GDPR without undue delay and, in any event, at the latest within one month from the receipt of such request; such period may be extended by 2 months if necessary, taking into account the complexity and number of requests (in such case, P06 undertakes to inform you of such extension and of the reasons for the delay, within one month from the receipt of the request).

6.5. The rights described above (with the exception of the right pursuant to art. 77 of the GDPR) may be exercised via the contact details set out in art. 7 below.

 

7. Contact details.

7.1. P06 can be contacted at the following address: info@progettarezerosei.it

7.2. The Data Protection Officer (DPO) pursuant to art. 37 of the GDPR, appointed by P06, can be contacted at the following address: privacydpoprogettarezerosei@baldiandpartners.it.

 

Reggio Emilia (RE), 16.12.2021 (date of last update).

 

PROGETTARE ZEROSEI S.r.l. Società Benefit

(in the person of its legal representative pro tempore)