Privacy Policy

www.zinetti.com

INFORMATION TO THE INTERESTED PARTY ON THE PROCESSING OF HIS PERSONAL DATA

MADE IN ACCORDANCE WITH ARTICLES 13-14 OF EU Reg.2016/679.

We inform you that we will process your personal data according to principles of correctness, lawfulness, transparency and protection of your privacy and rights and we inform you that any personal data you may provide us with (first name, last name, identification document details and copy thereof, telephone, email address), will be subject:

1. in relation to pre-contractual and contractual obligations:

   • of processing necessary for the negotiation and execution of the contract for the conclusion ofwhich the interested party came into contact with the holder by providing him/her with his/herdata;

   • of processing aimed at the recovery and collection of debts owed to the data subject, which may involve the communication of data to credit recovery companies, law firms, Justice Bodies, Credit Institutions, Insurance Companies;

   • of processing for the purpose of access to credit by the owner, which may involve the communication of data to Credit Institutions;

   • of processing for statistical and contact purposes for the negotiation and execution of contracts even after the negotiation and execution of the contract for the conclusion of which the interested party came into contact with the holder by providing his data;

2. In connection with legal obligations:

   • of processing aimed at the fulfillment of fiscal, tax and anti-money laundering obligations in dependence of the execution of the contract to which the owner and interested party are parties, which may involve the communication of data to professionals in charge of the preparation and keeping of accounting records, to Banking Institutions, to Tax Authorities, to Bodies in charge of the control of tax compliance, to lawyers and to Bodies of Justice;

We inform you that, taking into account the purposes of the processing as outlined above, the provision of data is compulsory and their non-, partial or incorrect provision may have, as a consequence, the inability to perform the contractual services.

Your Data, moreover, if you have given your consent, will be subject:

• of processing aimed at making the holder’s commercial offers to the data subject more effective, which, among other things, may involve the communication of personal data to partner companies of the holder,

• of communication to third parties who are interested in making contact with the data subject through the data controller; in this case, it will be up to the data subject to identify the categories of third parties by whom he or she wishes to be contacted by communicating them to the data controller when providing consent.

Where the data subject is under 16 years of age, the processing must be authorized by the holder of parental responsibility, for whom identification data and copies of identification documents will be acquired.

The processing will be carried out with both manual and computerized and telematic tools with logics of organization and processing strictly related to the above purposes and in any case insuch a way as to ensure the security, integrity and confidentiality of the data in compliance with the organizational, physical and logical measures provided for by the provisions in force.

The data for the purpose of processing with telematic tools may be communicated to service providers, partners and Authorities and/or Public Bodies operating outside/in the national territory or even outside the EU.

Personal contact data having a purely business nature (email address) may be used for sending periodic newsletters. You may at any time stop sending newsletters by writing to the Data Controller or by following the instructions at the bottom of the newsletter.

Personal data are retained for ten years from the date of communication or, if later, for the ten years following the issuance of the last invoice related to the last contract for the negotiation and execution of which such data were used in accordance with this policy, unless otherwise required by law.

You may at any time write to the data controller to exercise your right:

• to access your personal data;
• to obtain the rectification of your personal data if it is incorrect;
• to obtain the deletion of your personal data in the cases referred to in Article 17 GDPR;
• to obtain the limitaiton of processing within the limits of Article 18 GDPR;
• to avainl yourself of data portability in accordance with Article 20 GDPR;
• to object to the processing in the cases provided for in Article 21 GDPR;
• not to be subjected to automated processing as provided for in Article 22 GDPR;
• to revoke consent, where provided: revocation of consent does not affect the lawfulness of the processing based on the consent given before recovation;
• to lodge a complaint with the supervisory authority (Privacy Guarantor).

The data controller is Maurizio Zinetti, email maurizio@zinetti.com

This policy is also posted on the company website for your ready reference.

Disclosure updated as of May 25, 2018.

THE OWNER

Maurizio Zinetti