AddMore SRLS has always considered the protection of the personal data of its Users to be of fundamental importance. With this document (hereinafter, the „Information“), we intend to renew our commitment to ensure that the processing of personal data carried out in any manner, whether automated or manual, takes place in full compliance with the safeguards and rights recognized by the Regulations (EU) 2016/679 (hereinafter, „GDPR“ or „Regulation“) and by the additional applicable rules on the protection of personal data.
The term personal data refers to the definition contained in art. 4 in point 1) of the Regulations, ie “any information concerning an identified or identifiable natural person; the natural person is considered identifiable who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychological, economic, cultural or social „(hereinafter, the“ Personal Data „).
The Regulation provides that, before proceeding with the processing of Personal Data – with this term being intended, according to the relative definition contained in art. 4 in point 2) of the Regulation, „any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as the collection, registration, organization, structuring , storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction „(hereinafter,
In this regard, this Information – drawn up on the basis of the principle of transparency and all the elements required by art. 14 of the Regulation – aims to provide you, in a simple and intuitive way, with all the useful and necessary information so that you can provide your Personal Data in a conscious and informed way and, at any time, request and obtain clarifications and / or corrections.
A. THE HOLDER AND THE CO-HOLDERS OF THE TREATMENT
The association that will process your Personal Data for the purposes referred to in Sections C and D of this Information and which, therefore, will play the role of data controller according to the relative definition contained in art. 4 in point 7) of the Regulation, ie „the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data“ is:
ADD MORE SRLS, with registered office in PESCARA VIA NAZIONALE ADRIATICA NORD, 348
Your Personal Data will also be accessible to other Group companies – as joint data controllers – who have entered into a joint ownership agreement inter partes, pursuant to art. 26 of the Regulation, with which they have undertaken to: – jointly determine some purposes and methods of processing your Personal Data; – jointly determine, in a clear and transparent way, the procedures to provide you with a timely response if you wish to exercise your rights, as provided for by articles 15, 16, 17, 18 and 21 of the Regulation as well as in cases of portability of Personal Data provided for by art. 20 of the Regulations, as better described in Section H of this Notice; – jointly define this Information in the parts of common interest indicating all the information required by the Regulation. The complete list of joint data controllers is available from the Data Controller and can be provided following a specific request by the interested parties to be forwarded to the contacts referred to in Section I.
B. CONTACTS OF THE PERSONAL DATA PROTECTION OFFICER
In order to facilitate relations between you, as the interested party, that is the „identified or identifiable natural person“ to whom the Personal Data refer pursuant to art. 4 in point 1) of the Regulations (hereinafter, the „Data Subject“) and the Joint Controllers, the Regulations have provided, in some specific cases, for the appointment of a control and support figure who, among the various tasks assigned, also acts as a point of contact with the interested party.
The Joint Controllers have adopted this figure of „data protection officer“, the so-called „Data Protection Officer“, identifying and appointing, pursuant to art. 37 of the Regulations, Ms Sara de Simone (hereinafter, the „DPO“).
The DPO, pursuant to and for the purposes of art. 39 of the Regulation, is called upon to carry out, inter alia, the following activities: – inform and provide advice to the Data Controller as well as to the employees who carry out the Processing operations regarding the obligations deriving from the Regulation as well as from other provisions of the Union or of the Member States relating to the protection of Personal Data; – monitor and supervise compliance with the Regulations, the applicable regulations regarding the protection of Personal Data as well as the policies and procedures adopted by the Data Controller; – provide support in the feedback to the interested party; – cooperate with the competent Authority for the Protection of Personal Data.
As required by art. 38 of the Regulations, you can freely contact the DPO for all matters relating to the processing of your Personal Data and / or if you wish to exercise your rights as provided for in Section H of this Information, by sending a written communication to the administration email address @ addmorelogistics.it ;
C. MAIN PURPOSES
The Joint Controllers, in order to allow you to register on their website www. addmorelogistics.it – in the sections where it is possible to register and / or send requests for information using the contact forms and / or subscribe to the newsletter service – needs to collect some of your Personal Data .
The processing of your Personal Data will be conducted by the Data Controller to allow you, therefore, to participate in initiatives (for example, events for condominiums) also promoted through the Internet Sites, receive newsletters, send requests for information and take advantage of all other services, from time to time offered by the Internet Sites to which you have registered and / or within which you are browsing; the processing of your Personal Data will be legally based on the contractual relationship that will be created between you and the Owner following your acceptance of the conditions for participation in the Internet Sites.
To allow the Data Controller to carry out the processing activities for the above purposes, it will be necessary to provide the Personal Data marked with the symbol [*].
This treatment will be lawful by virtue of art. 6, paragraph 1, point b) of the Regulations.
In the absence of the provision of even one of the marked data, it will not be possible to proceed with the processing of your Personal Data and, consequently, it will not be possible to complete your registration on the Internet Sites and / or benefit from the services provided by them for which it is requested a provision of Personal Data.
The Personal Data that will be requested from you for the pursuit of the aforementioned purposes will be those reported in the registration and / or contact form, i.e., by way of example and not limited to: name, surname, username, date of birth, domicile address / residence, e-mail address, telephone numbers of fixed and / or mobile users, tax code. In this case, you will be able to view this information in the Privacy section of the Internet Sites.
D. FURTHER PURPOSES
The Joint Controllers, subject to your express, free and unequivocal consent pursuant to art. 6, paragraph 1, point a) of the Regulation, may request, in addition to the data referred to in the previous Section, additional Personal Data such as, by way of example but not limited to, data relating to tastes, preferences, habits, needs and consumption choices. , for the following purposes:
1. direct marketing: this term means the will of the Joint Controllers to carry out promotional and / or marketing activities towards you. This category includes all activities carried out to promote products, services, sold and / or supplied by the Joint Controllers on the basis of their legitimate interest in pursuing their corporate purpose;
2. profiling: this term means the will of the Joint Controllers to profile you, that is, to evaluate your tastes, preferences and consumption habits also related to market surveys and statistical analyzes. This category includes any form of automated processing of personal data to evaluate certain personal aspects such as those concerning, by way of example but not limited to, professional performance, economic situation, personal preferences, interests, reliability, behavior, the location or movements;
3. indirect marketing: this term means the will of the Joint Controllers to carry out promotional and / or marketing activities towards you on behalf of third parties. This category includes all the activities carried out to promote products, services, sold and / or supplied by third parties with whom the Joint Controllers have legal relationships without in this case there being communication of your Personal Data;
4. transfer of data to third-party companies: this term means the will of the Joint Controllers to communicate your Personal Data to third-party companies, with which the Joint Controllers have legal relationships, for promotional, marketing and commercial purposes.
With regard to the direct marketing purpose referred to in point (i), it should be noted that, by virtue of art. 6, paragraph 1, point f) of the Regulations, the Joint Controllers may carry out this activity based on their legitimate interest, regardless of your consent and in any case up to your opposition or limitation (pursuant to the provisions of Section H letter d) of this Notice) to this Treatment as better explained in Recital 47 of the Regulation, in which it is „considered legitimate interest to process personal data for direct marketing purposes“. This will also be possible following the assessments made by the Joint Controllers regarding the possible and possible prevalence of your interests,
The contact methods aimed at direct marketing activities (i) may be both automated and traditional. In any case, as detailed below in Section H, you can revoke your consent, even partially, for example by consenting only to traditional contact methods.
The processing of your Personal Data for the purposes referred to in points (ii), (iii) and (iv) cannot be separated from obtaining your consent which must necessarily comply with the conditions set out in art. 7 of the Regulation, thus determining the lawfulness of the processing of your Personal Data.
In particular, with regard to the purposes referred to in point (iv), the processing will be carried out with automatic and non-automatic tools. Furthermore, when the third-party companies contact you, you will always be provided with the relevant information so that you can always know what your rights are and how to exercise them.
As for the contact methods that involve the use of your telephone contacts, we remind you that the direct marketing activities by the Joint Controllers will be carried out after checking your possible registration in the Register of Oppositions as established pursuant to and for the purposes of the Presidential Decree 7 September 2010, n. 178 and subsequent amendments
E. SUBJECTS TO WHOM YOUR PERSONAL DATA MAY BE COMMUNICATED
Your Personal Data may be disclosed to specific subjects considered recipients of such Personal Data.
In fact, art. 4 at point 9) of the Regulation, defines as the recipient of a Personal Data „the natural or legal person, public authority, service or other body that receives communication of personal data, whether or not it is a third party“ (of hereinafter, the „Recipients“).
In this perspective, in order to correctly carry out all the processing activities necessary to pursue the purposes referred to in this Notice, the following Recipients may be in a position to process your Personal Data: – third parties who carry out part of the processing activities and / or activities connected and instrumental to the same on behalf of a Data Controller or Joint Controllers. These subjects have been appointed as data processors, having to be understood individually with this term, pursuant to art. 4 at point 8) of the Regulations, „the natural or legal person, public authority, service or other body that processes Personal Data on behalf of the Data Controller“ (hereinafter, the „Data Processor“); – individuals, employees and / or collaborators of a Data Controller or Joint Controllers, who have been entrusted with specific and / or more processing activities on your Personal Data. These individuals have been given specific instructions on the subject of security and correct use of Personal Data and are defined, pursuant to art. 4 at point 10) of the Regulations, „persons authorized to process Personal Data under the direct authority of the Data Controller or Data Processor“ (hereinafter, the „Authorized Persons“); – subjects to whom the Joint Controllers have, for any reason, transferred the data referred to in point (iv) of Section D. „Persons authorized to process Personal Data under the direct authority of the Data Controller or Data Processor“ (hereinafter, the „Authorized Persons“); – subjects to whom the Joint Controllers have, for any reason, transferred the data referred to in point (iv) of Section D. „Persons authorized to process Personal Data under the direct authority of the Data Controller or Data Processor“ (hereinafter, the „Authorized Persons“); – subjects to whom the Joint Controllers have, for any reason, transferred the data referred to in point (iv) of Section D.
Where required by law or to prevent or suppress the commission of a crime, your Personal Data may be disclosed to public bodies or judicial authorities without these being defined as Recipients. In fact, pursuant to art. 4 at point 9), of the Regulation, „the public authorities that may receive communication of Personal Data in the context of a specific investigation in accordance with the law of the Union or of the Member States are not considered Recipients“.
F. PROCESSING TIME
One of the principles applicable to the processing of your Personal Data concerns the limitation of the retention period, governed by art. 5, paragraph 1, point e) of the Regulation which states “Personal Data are stored in a form that allows identification of the Data Subjects for a period of time not exceeding the achievement of the purposes for which they are processed; Personal Data may be stored for longer periods provided that they are processed exclusively for archiving purposes in the public interest, for scientific or historical research or for statistical purposes, in accordance with art. 89, paragraph 1, without prejudice to the implementation of adequate technical and organizational measures required by these Regulations to protect the rights and freedoms of the interested party „.
In light of this principle, your Personal Data will be processed by the Joint Controllers limited to what is necessary for the pursuit of the main purposes referred to in Section C of this Information.
In particular, your Personal Data will be processed for a period of time equal to the minimum necessary, as indicated in Recital 39 of the Regulation, i.e. until the termination of the contractual relationships existing between you and the Data Controller and / or Joint Controller, without prejudice to a further retention period that may be imposed by law as also provided for by Recital 65 of the Regulation.
With regard to the treatments carried out for the achievement of the additional purposes referred to in Section D of this Notice, the Joint Controllers may lawfully process your Personal Data until you communicate, in one of the methods provided for in this Notice, your will to withdraw consent. to one or all of the purposes for which it was requested of you. Any withdrawal of consent will in fact require the Joint Controllers to cease the processing of your Personal Data for these purposes.
G. WITHDRAWAL OF CONSENT
As required by the Regulation, if you have given your consent to the processing of your Personal Data for one or more purposes for which it was requested, you can, at any time, revoke it totally and / or partially without prejudice to the lawfulness of the processing based on the consent given before the revocation.
The methods for revoking the consent are very simple and intuitive, just contact the Data Controller and / or the Joint Controllers and / or the DPO using the contact channels reported in this Information, respectively in Sections B and H.
As required by art. 15 of the Regulation, you will be able to access your Personal Data, request its correction and updating, if incomplete or incorrect, request its cancellation if the collection took place in violation of a law or regulation, as well as oppose the processing for legitimate and specific reasons.
In particular, we report below all your rights that you can exercise, at any time, against a Data Controller and / or the Joint Controllers.
1. Right of access
You will have the right, pursuant to art. 15, paragraph 1 of the Regulation, to obtain from the Data Controller confirmation that your Personal Data is being Processed or not and, in this case, to obtain access to such Personal Data and the following information: a) the purposes of the Treatment; b) the categories of Personal Data in question; c) the Recipients or categories of Recipients to whom your Personal Data have been or will be communicated, in particular if Recipients from third countries or international organizations; d) when possible, the retention period of the Personal Data provided or, if not possible, the criteria used to determine this period; e) the existence of the right of the interested party to ask the Data Controller to rectify or delete personal data or limit the processing of personal data concerning him or to oppose their treatment; f) the right to lodge a complaint with a supervisory authority; g) if the Personal Data are not collected from the Data Subject, all available information on their origin; h) the existence of an automated decision-making process, including profiling pursuant to art. 22, paragraphs 1 and 4, of the Regulation and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of this processing for the interested party. g) if the Personal Data are not collected from the Data Subject, all available information on their origin; h) the existence of an automated decision-making process, including profiling pursuant to art. 22, paragraphs 1 and 4, of the Regulation and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of this processing for the interested party. g) if the Personal Data are not collected from the Data Subject, all available information on their origin; h) the existence of an automated decision-making process, including profiling pursuant to art. 22, paragraphs 1 and 4, of the Regulation and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of this processing for the interested party.
All this information can be found in this Information which will always be available to you in the Privacy section of the Internet Sites.
1. Right of rectification
You will be able to obtain, pursuant to art. 16 of the Regulation, the correction of your Personal Data that are inaccurate. Furthermore, taking into account the purposes of the processing, you will be able to obtain the integration of your Personal Data which are incomplete, also by providing an additional declaration.
1. Right to cancellation
You will be able to obtain, pursuant to art. 17, paragraph 1 of the Regulation, the cancellation of your Personal Data without undue delay and the Data Controller will have the obligation to delete your Personal Data, if there is even one of the following reasons: a) the Personal Data are no longer necessary with respect to purposes for which they were collected or otherwise processed; b) you have revoked the consent on which the processing of your personal data is based and there is no other legal basis for their processing; c) you have opposed the processing pursuant to art. 21, paragraph 1 or 2 of the Regulations and there is no longer any legitimate overriding reason to proceed with the Processing of your Personal Data; d) your Personal Data have been unlawfully processed;
In some cases, as required by art. 17, paragraph 3 of the Regulation, the Data Controller is entitled not to delete your Personal Data if their processing is necessary, for example, for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of public interest, for archiving purposes in the public interest, for scientific or historical research or for statistical purposes, for the assessment, exercise or defense of a right in court.
1. Right to limit the processing
You will be able to obtain the limitation of processing, pursuant to art. 18 of the Regulation, in the event that one of the following hypotheses occurs: a) you have contested the accuracy of your Personal Data (the limitation will last for the period necessary for the Data Controller to verify the accuracy of such Personal Data); b) the processing is unlawful but you have opposed the cancellation of your Personal Data, asking instead that its use be limited; c) although the Data Controller no longer needs it for processing purposes, your Personal Data are used to ascertain, exercise or defend a right in court; d) you have opposed the processing pursuant to art. 21, paragraph 1, of the Regulation and you are awaiting verification of the possible prevalence of the Data Controller’s legitimate reasons with respect to yours.
In case of limitation of processing, your Personal Data will be processed, except for storage, only with your consent or for the ascertainment, exercise or defense of a right in court or to protect the rights of a ‚other natural or legal person or for reasons of significant public interest. We will inform you, in any case, before this limitation is lifted.
1. Right to data portability
You can, at any time, request and receive, pursuant to art. 20, paragraph 1 of the Regulation, all your Personal Data processed by the Data Controller and / or by the Joint Controllers in a structured, commonly used and legible format or request its transmission to another data controller without impediments. In this case, it will be your responsibility to provide us with all the exact details of the new data controller to whom you intend to transfer your Personal Data by providing us with written authorization.
1. Right to object
In accordance with art. 21, paragraph 2 of the Regulation and as also reaffirmed by Recital 70, you can object, at any time, to the Processing of your Personal Data if these are processed for direct marketing purposes, including profiling to the extent that it is connected to such direct marketing. .
1. Right to lodge a complaint with the supervisory authority
Without prejudice to your right to appeal to any other administrative or judicial office, if you believe that the processing of your Personal Data conducted by the Data Controller and / or the Joint Controllers occurs in violation of the Regulations and / or applicable legislation, you can lodge a complaint with the Authority. Competent Guarantor for the Protection of Personal Data.
To exercise all your rights as identified above, simply contact the Data Controller and / or the Joint Controllers in the following ways: – by sending an e-mail to the mailbox email@example.com ; – by sending a registered letter to the Headquarters of the Data Controller.
J. PLACES OF PROCESSING
Your Personal Data will be processed by the Data Controller and / or by the Joint Controllers within the territory of the European Union, in the Vatican City and in the Republic of San Marino.
If for technical and / or operational reasons it becomes necessary to make use of subjects located outside the European Union, we inform you as of now that these subjects will be appointed as Data Processors pursuant to and for the purposes of art. . 28 of the Regulations and the transfer of your Personal Data to these subjects, limited to the performance of specific processing activities, will be regulated in accordance with the provisions of Chapter V of the Regulations.
All necessary precautions will therefore be taken in order to guarantee the most complete protection of your Personal Data by basing this transfer: (a) on adequacy decisions of the recipient third countries expressed by the European Commission; (b) on adequate guarantees expressed by the third party recipient pursuant to Article 46 of the Regulation; (c) on the adoption of binding corporate rules; (d) adopting standard contractual clauses approved by the European Commission.
In any case, you can request more details from the Data Controller and / or the Joint Data Controllers if your Personal Data have been processed outside the European Union by requesting evidence of the specific guarantees adopted.