POLICY ON THE PROCESSING OF PERSONAL DATA BELONGING TO PROSPECTS PURSUANT TO ARTICLE 13 OF REGULATION (EU) 2016/679 (“REGULATION”)

 

Schoch & Co. S.r.l. hereby provides you with information regarding the processing of your personal data with regards to the commercial relationship between yourself (as company contact, professional, sole trader, legal representative etc., of a subject commonly referred to as “prospect”) and Itema S.p.A., with whom you have established contact, for example by submitting a business card, filling in a form during a trade fair or requesting a quotation.

1. Identity and contact details of the data controller
The Data controller is Schoch & Co. S.r.l., with registered offices in Via Cav. G. Radici 4, 24020 Colzate (BG), email privacy@itemagroup.com (hereinafter referred to as the “Company” or “Data Controller”).

2. Categories of personal data
The data processed by the Company are of a “common” nature, concerning identity and contact details (e.g., forename and surname, email address, company role, etc.)

3. Purpose and legal basis for processing and period of data storage
The aforementioned personal data are processed for the following purposes and on the basis of the following conditions of lawfulness, and for the period indicated below:

Purpose of data processing	Legal basis for processing	Duration of storage of data
a. In order to recontact prospects in order to establish a contractual relationship with the company.	The execution of pre-contractual measures adopted at the request of the data subject, pursuant to article 6.1, letter b) of the Regulation.	The data are processed until the request has been fulfilled, save for the implementation of a commercial relationship with the client on its specific request in this regard.
b. For the purpose of generic marketing; the carrying out of market research and the sending by email of communications, information and advertising materials that concern in general the products and services offered by the Company, with the latter using either automated or telephonic methods.	Consent of the data subject, pursuant to article 6.1 letter a) of the Regulation.	The data are processed for a period of 10 years, save for revocation of consent.

4. Nature of provision and methods of processing
The provision of data is necessary in order to allow the Company to follow up on contacts.
The personal data are processed by the Company with both digital and paper methods and in respect of the principles specified by the Regulation and are protected with technical and organisational measures that are adequate in guaranteeing their integrity and confidentiality.

5. Data recipients
The data may be communicated to third parties operating as autonomous data controllers (e.g., professional firms or public administration) and processed, on behalf of the Company, by third parties designated as data processors providing the Company with services aimed at achieving the aforementioned purposes, for example IT or marketing services.

Furthermore, the data are processed by employees of the Company working within sectors of the organisation charged with the fulfilment of the purposes indicated above, who are expressly authorised for processing and have received appropriate operating instructions.

6. Transfer of data to other countries
The data will be held at the registered offices of the Company and on its servers (both located in Italy), but may be transferred to subjects in other countries, i.e., outside of the European Union (“EU”) and the European Economic Area (“EEA”), for example in the United States, where the IT providers are located, through one of the guarantees provided for by the Regulation to legitimise transfer, such as that specified in article 46.2, letter c) of the Regulation.

7. Rights of the data subject
In relation to the data processing described herein, you may exercise the rights provided by the Regulation, including the right to:

• receive confirmation of the processing of personal data and to access the data (right to access).
• update, modify and/or integrate the personal data (right to rectification).
• request the erasure of the data in the cases provided for by article 17 of the Regulation (right to be forgotten).
• obtain the restriction of processing of the data in the cases provided for by article 18 of the Regulation (right to restriction of processing).
• object to the processing of the data carried out on the basis of the legitimate interest of the Data Controller at any time, in a manner that is facilitated and free of charge, for reasons related to the particular case (right to object).
• revoke any consent granted at any time.
• oppose the receiving of promotional communications by clicking on the dedicated unsubscribe link at the foot of all emails.
• to receive the data in a structured, commonly used, machine-readable and interoperable format, and, if technically possible, to transmit it to another controller without hindrance, in the event that processing is based on consent or contract and is carried out with automated tools (right to data portability).

To exercise these rights, you may contact the Company at any time, sending your request by email to the following address privacy@itemagroup.com or by registered letter with return receipt addressed to Itema Group Data Protection Committee to the following address: via Cav. G. Radici n. 4, Colzate (BG), 24020 – Italy.

You have the right to lodge a complaint with the Data Protection Authority or a supervisory authority in the Member State in which you habitually reside or work, or in the State in which the alleged infringement has taken place.