INFORMATION ON THE TREATMENT OF PERSONAL DATA
In compliance with the obligations deriving from national legislation (Legislative Decree No. 196 of June 30, 2003, Code regarding the protection of personal data and subsequent amendments) and community, (European regulation for the protection of personal data No. 679/2016, GDPR ), the Company Sentinel Ch. SpA, with registered office in Milan (MI) Via Robert Koch 2, P.IVA CF and P.IVA 07118040158, in its capacity as Data Controller, discloses the methods and purposes of the processing of personal data relating to the legal representatives, the owners and / or the employees of the Customer or Supplier Companies.
- Source of data Sentinel CH. S.p.A. informs that, for the establishment and execution of contractual relationships in progress, the same can come into possession of personal data such as name and surname, telephone number, email address, and other common data of natural persons who hold the qualification of legal representatives, owners, employees or collaborators of the company’s own customers and suppliers. These data could be acquired by Sentinel CH. S.p.A. because communicated directly by the interested party (business card delivery, telephone or email communication), or because transmitted by third parties, such as, by way of example, the employer or colleagues of the same party..
- Legal basis and purpose of the processing Personal data, as described above, will be processed by Sentinel CH. S.p.A. for the following purposes:
- With regard to the personal data of the owners or legal representatives of customers or suppliers, to carry out all the activities connected to the stipulation and execution of contracts, as well as to fulfill legal obligations deriving from existing relationships with customers and suppliers, and possibly to allow the Data Controller to pursue his legitimate interest in exercising his rights, including that of defending in court;
- With regard to personal identification data of employees and collaborators of Sentinel Ch. SpA customer and supplier companies, for the pursuit of the legitimate interest of the Data Controller in the management of communications and the exchange of information necessary for the execution of contracts with customers and providers.
Any further purpose will be the subject of dedicated information and any specific and separate consent, where required by law.
3- Treatment modalities The processing of the personal data described above is carried out by means of the operations indicated in art. 4 n. 2) GDPR and precisely through collection, registration, organization, storage, consultation, processing, modification, selection, extraction, use, communication, cancellation and destruction of data. Personal data is processed both on paper and electronic and / or automated. The Data Controller uses appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of personal data. Personal data will be processed not only by the Data Controller, but also by its employees, collaborators, consultants and professionals, always within the scope of the aforementioned purposes and subject to their designation as appointed parties or external managers and assignment of specific instructions, necessary for compliance with the legislation on the protection of personal data. The management and storage of personal data will take place on servers located within the European Union and managed by the Data Controller. Currently the servers are located in Italy. With reference to personal data processed for the purposes referred to in points a) and b) of art. 2 above, the data will not be transferred outside the European Union. In any case, it is understood that the Owner, if necessary, will have the right to move the location of the servers to another European Union country and / or to countries outside the EU. In this case, Sentinel CH. S.p.A. ensures from now on that the extra-EU data will be transferred in compliance with the applicable legal provisions, stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses envisaged by the European Commission.
- Duration of treatment The processing of the personal data of the owners and legal representatives of the client or supplier companies will last no longer than 10 years, except in the event that such data should be processed for the protection in court of the rights of the Owner. In this case, the processing will take place for as long as is necessary to achieve the purposes described. The data of employees and collaborators of customers or suppliers will be processed for the duration necessary to achieve the purposes referred to in letter b) of point 2 above. An update and a cancellation, at least annually, of the data no longer current is in any case envisaged.
- Access to data Personal data as identified in paragraph 1 above may be made accessible, only for the purposes referred to in art. 2 above, to employees and collaborators of the owner or companies of the Sentinel Group Ch. S.p.A. in Italy and abroad, in their capacity as appointees and / or internal processors and / or system administrators.
- Dissemination of data Your data will not be disclosed.
- Nature of data provision and consequences of failure to provide data The provision of data for the purposes referred to in art. 2 is strictly necessary to achieve the purposes described above. Furthermore, the Data Controller informs that any non-communication, or incorrect communication, of one of the necessary information has the emergent consequences of the impossibility or difficulty for the Data Controller to guarantee the correct and correct management of relations with its customers and its suppliers.
- Rights of the interested party Data subjects are entitled to the rights referred to in Chapter III of the GDPR, namely the rights to:
- Getting from Sentinel CH. S.p.A. confirmation of the existence or not of personal data concerning them, even if not yet recorded, and their communication in intelligible form;
- obtain the indication: a) of the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with the aid of electronic instruments; d) of the identification data concerning the data controller, data processors and the representative designated pursuant to art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or appointees;
- obtain: a) updating, rectification or, when interested, integration of data; b) the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including data which does not need to be kept for the purposes for which the data was collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the event that such fulfillment occurs it proves impossible or involves the use of means manifestly disproportionate to the protected right;
- withdraw your consent at any time;
- oppose, in whole or in part, for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of collection;
- if you believe your rights are violated, make a complaint to the Privacy Authority.
Where applicable, it also has the rights set forth in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right to limitation of treatment, right to data portability, right to object), as well as the right to complain to the Guarantor Authority.
- Method of exercising rights You may at any time exercise your rights, as per point 8 above, by sending:
– a registered letter a.r. to Sentinel CH. S.p.A. , with registered office in Milan, Via Robert Koch 2.
– an e-mail to sentinel@pec.sentinel.it.
- Owner, managers and appointees The Data Controller is Sentinel CH. S.p.A. with registered office in Milan, Via Robert Koch 2, VAT number 071180400158.
The updated list of the categories of data processors and data processors is kept at the registered office of the Data Controller.
for having read the information regarding the processing of data and assumption of the commitment to disclosure
We declare that we have read the above information and undertake to show it to employees and / or collaborators, whose data are communicated to Sentinel CH. S.p.A. and by these treaties for the conduct of commercial relations.
Milan, date of dispatch of the information Sentinel CH. Spa