Privacy Issues - Treatment of personal information
OCME S.r.l. (hereinafter “Ocme”), having its seat in Parma, Via Del Popolo, n.20/A, duty represented by its pro tempore legal representative, as Controller of your personal data spontaneously communicated (verbally, by means of your visit card, e-mail or by means of website, etc.) is glad to provide you, pursuant to Sections 13, General Data Protection Regulation UE 2016/679 (hereinafter “GDPR”), with all of the following information (hereinafter, the “Information Notice”).
(a) Identity and Contact details of the Joint Controllers
Via Del Popolo, n.20/A – 43122 - Parma
Tax code / VAT no.: 00786410340
Tel. (0521) 275211
(b) Contact details of the Data Protection Officer
Office of the Data Protection Officer (“DPO”)
Via Del Popolo, n.20/A – 43122 - Parma
Certified email address PEC): firstname.lastname@example.org
(c) Purposes of the processing for which the personal data are intended and related legal basis
Your personal data will be processed:
(i) without your consent (section 6, items b, c, f, GDPR), for the following purposes:
- performance of pre-contractual and contractual obligations deriving from the execution of a contract;
- compliance with legal obligations, as provided for by a law (national or EU) or perform an order of any authority, as well of any other entity to which Ocme is subject;
- exercise the rights of Ocme, with particular reference to judicial defensive rights;
(ii) with your consent (section 7, GDPR), for the following purposes:
- organisation of events, conferences, lessons and workshops also for professional training;
- marketing and promotional activities of professional services, distribution of promotional materials, sending out of professional newsletters and publications;
- management of surveys and customers’ satisfaction questionnaires.
For the purposes under par. (i) above, the collection of your personal data is necessary. In lack of the data or in case of any express refusal of consent to process such data may cause the impossibility to Ocme to perform the contract or the possible violation of the competent Authorities requests.
For the purposes under par. (ii) above, the collection of your personal data is made on voluntary basis; consequently, you may decide not to provide us with any consent, or to waive it in any moment.
(d) Processed Categories of Personal Data
Within the purposes of processes mentioned under par. c) above, we shall exclusively process those personal data concerning, by way of example, your name and family name, tax code, VAT number, residence, domicile, work address, email, certified email address, phone and fax numbers, employer company, business role and / or position.
(e) Categories of Personal Data Recipients
The personal data you will submit us for the purposes mentioned under par. c), section (i) above, could be transferred to:
- Employees and collaborators of Ocme, in their capacity of persons duly authorised to data processing (“charged of processing”),
- Any third party subject, performing outsourced activities on behalf of Ocme, in their capacity of data processors,
- Any judicial or controlling Authority, public entities (whether national or foreign ones),
- Any other entities belonging or controlled or controlling to which Ocme is part thereof.
Upon your express consent to processing the personal data for the purposes indicated under par. (c), section (ii) above, data may be transferred to those subjects indicated under items 1), 2) and 3) above, as well as, upon your prior consent, to other entities belonging controlled or controlling to which Ocme is part thereof.
(f) Storage and Transfer of Personal Data to Third Countries
Personal data are processed and stored “on cloud” and on servers located within and outside EU, belonging to or in the possession of Ocme and/or third party processors, as duly appointed.
The transfer to non EU-countries is performed in compliance with the provisions under par. V, GDPR (sec. 46), adopting standard contractual clauses drafted pursuant to versions no. 2004/915/EC and n. 2010/87/EU, as adopted by the European Commission.
Your personal data will not be subject to dissemination.
(g) Personal Data Storage Period
Personal Data provided for the purposes indicated under par. (c), section (i) above are processed and stored for the entire duration of the contract and for the subsequent period necessary for the purpose of (i) guaranteeing the proper functioning, and (ii) guaranteeing supply of spare parts, and (iii) revisions and periodic updates
Anyway personal data will be stored as long as time-barring legal terms will be elapsed, even regardless of the termination of such contractual relationship, for whichever reason or cause.
Personal Data provided for the purposes indicated under par. (c), section (ii) above are processed and stored for the time necessary for the performance of the same purposes and, anyhow, not later than 2 years from the date in which we will receive your consent
(h) Exercisable Rights
In compliance with the provisions under Chapter III, Section I, GDPR, you may exercise the rights therein indicated and in particular:
- Right of Access – Obtain confirmation whether your data are processed or not and, in such a case, obtain information related, in particular, to: the purposes of such processing, the categories of the processed personal data, the storage period, the recipients to whom such data can be transferred (Section 15, GDPR);
- Right of Rectification – Obtain, without undue delay, the rectification of inaccurate personal data and to have incomplete personal data completed (Section 16, GDPR);
- Right of Erasure – Obtain, without undue delay, the erasure of your personal data, in the cases provided for by the GPDR (Section 17, GDPR);
- Right to Restriction – Obtain from the Joint Controllers the limitation to processing, in the cases provided for by the GDPR (Section 18, GDPR);
- Right to Data Portability – Receive your personal data as communicated to the Joint Controllers in a structured, commonly used and machine-readable format and obtain the transmission of such data to another controller without any hindrance, in the cases provided for by the GDPR (Section 20, GDPR);
- Right to object – Object to the processing of your personal data, unless the Joint Controllers have compelling legitimate grounds for the continuation of the processing (Section 21, GDPR);
- Right to Lodge a Complaint with the Supervisory Authority – Lodge a complaint to Autorità Garante per la protezione dei dati personali, Piazza di Montecitorio n. 121, 00186, Roma (RM).
You may exercise such rights by means of a request to be sent by email to the Data Privacy Officer certified email address above indicated.
(i) Processing Operations
Your personal data are processed through the operations indicated in section 4, n. 2), GDPR - whether or not performed by automated means – such as: collection, recording, organization, structuring, update, storage, adaptation or alteration, retrieval and analysis, consultation, use, disclosure by transmission, alignment or combination, restriction, erasure or destruction.
Whichever the way, it will guaranteed their security, logical and physical, and overall their confidentiality, adopting all necessary technical and organizational measures appropriate to guarantee the data security.