Privacy
Obex Systems Srl is committed to protecting the personal data entrusted to it. Therefore, the management and security of such data is guaranteed with the utmost care, as required by privacy legislation, in full compliance with the principles of lawfulness, correctness and transparency. In accordance with the current provisions of law on privacy (in particular EU Regulation 679/2016 on the protection of natural persons with regard to the processing of personal data, as well as the free circulation of such data), this information explains who the Data Controller is, for what purposes Obex Systems Srl may use the data provided, how it will process them, to whom they may be communicated, where they may be transferred and what the rights of the interested party are.
WHO WILL PROCESS THE DATA PROVIDED
The data provided will be processed, as Data Controller, by Obex Systems Srl, with registered office in Via XX Settembre, 42 – 30035 Mirano (VE).
PERSONAL DATA PROCESSED AND PURPOSE OF THE PROCESSING
The personal data collected, both in paper and electronic form, which are the subject of processing, concern:
· identification, administrative, accounting, fiscal and commercial data of the interested parties (such as members of the corporate bodies, employees, collaborators of third parties with whom the Customer has commercial relationships);
· credit card data;
· user/password for accessing programs (e.g. adwords, facebook, linkedin). Such data, of which the Customer is legitimately in possession, are provided by him in the context of the development and execution of pre-contractual/contractual relationships with the Data Controller. The data may be processed for the following purposes: A. sending estimates to companies/natural persons who are already Customers/potential Customers; B. execution of the services requested by the Customers; C. monitoring of collections; D. fulfillment of legal obligations (e.g. accounting, fiscal obligations); E. exercise of the Data Controller’s right of defense in court; F. sending communications – commercial information (for example newsletters, invitations to events, ways to obtain a gadget or a promotion) to Customers – suppliers/potential Customers – suppliers of companies that are Customers of Obex Systems Srl, in the case of data acquired directly by the Company (for example via landing pages); G. sending communications – commercial information (for example newsletters, invitations to events, other commercial information) to customers/potential customers of Obex Systems Srl. NATURE OF THE PROVISION The Company will process the data referred to in the previous points:
A., B. and C. because it is necessary for (i) carrying out pre-contractual activities aimed at developing a contractual proposal and (ii) performing the services requested by the Customer;
D. because it is necessary to fulfill a legal obligation to which the Company is subject;
E. because it is necessary for pursuing the legitimate interest of the Company in protecting its rights in the event of legal disputes;
F. and G. on the basis of the Customer’s consent; the Customer will always be given the opportunity to revoke their consent in the manner provided in the following paragraphs. The provision of data for the purposes:
· A., B., C. and E. is necessary for the performance of the contractual and/or pre-contractual activities of the Company;
· D is mandatory and any refusal by the interested party will make it impossible for the Company to pursue the purposes described in the previous paragraph;
· F. and G. is optional, however failure to provide such data will make it impossible for the Company to pursue the declared purposes. The extent and adequacy of the data provided will be assessed on a case-by-case basis in order to determine the resulting decisions and avoid the processing of data exceeding the purposes pursued. The Company undertakes not to use the personal data provided for purposes other than and in addition to those described in this information, without first informing the interested party and, where necessary, obtaining his/her consent. PROCESSING METHODS The data is processed using computerised procedures or, in any case, telematics or paper supports, with logic strictly related to the purposes themselves and, in any case, in such a way as to guarantee their security and always in compliance with the legislation in force on the matter, in particular EU Regulation 679/2016. The data will also be:
· processed by company resources, adequately trained and committed to confidentiality, as personnel authorized to process the data;
· stored in ways that are suitable to guarantee their security, integrity and confidentiality, through the adoption of appropriate security measures required by law. RETENTION PERIOD With reference to the processing for the purposes:
· A., B., C., D. and E., the Company will process the personal data for the time necessary to pursue these purposes and, in any case, for a period not exceeding 10 years from the termination of the last contractual relationship with the Customer. The data may also be stored beyond this period in relation to the possible need to use them in court in the event of litigation, or in any other case in which the legitimate interests of the Company prevail over the interests or fundamental rights and freedoms of the interested party;
· · F. and G., the data will be retained until the consent is revoked by the interested party according to the methods made available by the Company for this purpose.
COMMUNICATION AND DISSEMINATION
The data collected will not be communicated or disseminated outside the Company. The data may be communicated, by virtue of the performance of the relationship with the Customer to
public bodies, to fulfill legal obligations or to exercise the rights of the Company (for example, the right to defense in court);
private bodies and organizations established in the territory of the Italian State to which, through contractual agreements, services (technical, IT and administrative/accounting support) are entrusted that are strictly functional to the purpose for which the data are provided by the interested party. The Company wishes to inform you that if, due to the evolution of its organization or agreements with new suppliers, it becomes necessary to transfer data outside the European Union, such transfer will take place in accordance with the applicable legal provisions (Article 45, paragraph 1 of the GDPR, Transfer on the basis of an adequacy decision, or Article 46, Transfer subject to adequate guarantees). RIGHTS OF THE INTERESTED PARTY AND METHODS OF EXERCISE
We inform you that EU Regulation 679/2016 (in particular, Chapter III) grants the interested party specific rights, for the exercise of which the same may contact the Company, writing to Via XX Settembre, 42 – 30035 Mirano (VE) or by sending an email to info@obexsystems.com. In particular, these rights are provided for by the GDPR in the articles:
13, Information to be provided in the event of collection of personal data from the interested party. In particular, we highlight what is indicated in paragraph 2, point d) regarding the right to lodge a complaint with the Data Protection Authority;
· 15, Right of access by the interested party;
· 16, Right to rectification;
· 17, Right to erasure (‘right to be forgotten’);
· 18, Right to restriction of processing;
· 19, Obligation to notify in the event of rectification or erasure of personal data or restriction of processing;
· 20, Right to data portability;
· 21, Right to object;
· 22, Automated individual decision-making, including profiling. The Data Controller undertakes to best manage the interested party’s request in order to guarantee the effective exercise of his/her rights.
HOW TO CONTACT THE OWNER
Any further information regarding the processing and this information may be requested by writing to Via XX Settembre, 42 – 30035 Mirano (VE) or by email to info@obexsystems.com.
CHANGES AND UPDATES
This Privacy Policy may undergo changes and additions, also as a consequence of the update of the applicable legislation regarding the protection of natural persons with regard to the processing of personal data and the free circulation of such data. The text of the most updated information can be consulted at obexsystems.com/privacy.