Privacy Policy about Marketing

 

 

MARKETING POLICY

PRIVACY POLICY

PURSUANT TO ARTICLES 13 AND 14 REG. EU 2016/679 (“GDPR”)

 

INTRODUCTION

In compliance with the obligations deriving from the European Regulation for the Protection of Personal Data no. 679/2016, GDPR and the national legislation on the protection of personal data, below are all the information relating to the processing of your personal data.

We would like to point out that your data is processed in compliance with the legislation on data protection and the confidentiality obligations which are at the basis of all our activities.

  1. Who is the data controller of your data?

The Data Controller is Sentinel Ch S.p.A., with registered office in Milan, Via Roberto Koch 2, Tax Code and VAT number 07118040158, which can be contacted at the following addresses:

  • +39 02 36217.1
  • +39 02 36217.464

E-mail sentinel@pec.sentinel.it

  1. When does this regulation apply?

This policy is directed to you, if:

  • You are our customer or our supplier and you are entering into or have entered into a contract with us or need assistance on the products;
  • You are not yet our customer, but you are interested in one or more of our products and wish to contact us by phone, email or by filling out the contact form on our website, to receive a quote or information about our products;
  • You have requested information and/or a quote on our products by filling in a form on a third-party site that promotes our products (Marketplace);
  • You have participated in one of our lead generation campaigns published on LinkedIn;
  • You have had contacts with our company and you want to receive communications about our products and our promotions, news relating to our business or invitations to events, or you want to participate in statistical surveys promoted by us on our products or services offered by us;
  • You wish to join a promotional campaign of our products;
  • You are filling out a form on the sentineldiagnostics.com website because you want to receive communications about our products, our promotions, and our activities or you want to receive our newsletter, invitations or participate in statistical surveys promoted by us on our products or services offered by us;
  • You met us at trade fairs or congresses, and you expressed interest in our products and activities by handing us your business card or contact details and you are interested in receiving news relating to our activities or invitations to events, or you want to participate in statistical surveys promoted by us on our products or on the services we offer;
  • Although you have never researched or had direct contact with our Company, you operate in the healthcare sector and you received an email from us in which we ask you to be able to submit our offers, our proposals and access to our marketing services, surveys, newsletters or invitations to events.
  1. From whom do we receive your data?

We can receive the data we process from you, from third parties or, with your consent, we collect them automatically from our website, comparing them with your other data.

Whenever we get in contact because we are linked by negotiations or commercial relationships, you send us your requests for information or other, the data we process are only those communicated by you, or those generated by your choice relating to whether or not you join our initiatives or, subject to your consent, from your navigation in some special sections of the website.

If, on the other hand, you have never had any previous contact with us, you should know that we have probably received your data (relating to your name and surname, your professional e-mail address, your company role and your professional qualification) from Third Parties, who have selected your profile because you are potentially interested in our products. This may include, for example, your colleagues, your employer or our partner websites, which we use to advertise our products, and who have received your expression of interest in our products. In this case, your data is transferred to us only if you have expressly requested a quote on one of our products or if you have requested to be sent our price list

We carefully assess the legitimate acquisition and transfer of data by our suppliers; in any case, you must know that, if you do not show any interest in the services we offer, we immediately proceed to remove your data from all of our databases.

  1. What data do we process and for what purposes?

a) If you are or wish to be our customer or supplier,

  1. your personal and contact data such as name, surname, address, tax code or VAT number, bank details, are necessary to conduct the pre-contractual negotiations and to perform the contractual obligations that subsist with you (including carrying out the necessary operations for the fulfilment of orders and other requests);
  2. the same data referred to in point 1. above will also be necessary to fulfil the legal obligations deriving from the entering into the contract;
  3. to guarantee that we can carry out all the necessary communications, exchange information of various kinds and with various means, formulate requests or process requests received from you, connected to the performance of a contract;

b) If you are an employee or collaborator of a company or body with which we are in contact, your shared and contact data such as name, surname, email, company you belong to, professional qualification, company role are necessary to guarantee that we are able to make all the necessary communications, exchange information of various kinds and with various means, formulate requests or process requests received from you, connected to the performance of a contract or an office you are dealing with for work reasons;

c) Whether or not you are our customer or supplier, based on the preferences that will be selected by you and the consent that you will have expressed, we may process your personal data such as name and surname, email, professional qualification, any company or organisation to which you belong, telephone number, type of areas or products of interest or previously purchased, areas of the website visited, activities carried out, emails opened, participation in events organised by us or in which we participate, for one or more of the following purposes:

  1. To allow you to receive (by post, e-mail or telephone) communications about our products, our promotions and our activities in general (marketing);
  2. To allow you to provide your contribution in conducting statistical research on our products and services (survey);
  3. To allow you to receive newsletters or invitations to events (newsletters and invitations);
  4. To allow us to better customise the promotion and newsletter services, by sending you targeted and relevant content (profiling).

None of the activities now listed will be performed by us without your express and specific consent.

In the forms on the site, some fields are marked with an asterisk. The data relating to these fields are necessary in order to answer your questions or provide you with the services you need and without which we cannot respond to your requests. Fields without an asterisk instead are optional data; providing us with these data is useful for us to better understand your preferences for the purpose of personalising your services.

  1. Under what legal principle can we process your data and for how long do we do it? 
Purpose Legal basis Storage time
a)    1 Art. 6 lett. b) GDPR

processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

 The data processed will be retained for a period of 10 years.
a)    2 Art. 6 lett. c) GDPR

Processing is necessary for compliance with a legal obligation to which we are subject.

 The data processed will be retained for a period of 10 years.
a)    3

b)

 Art. 6 lett. f) GDPR

Processing is necessary for the pursuit of our legitimate interest in the correct management of relations with customers, suppliers and bodies with which we come into contact, after assessing the balance of your rights.

 The data processed will be kept until the consent is revoked and in any case no later than 10 years from the collection of the consent itself.
c)

 

 

 

 Art. 6 lett. a) GDPR

All processing carried out for the purposes of point c), above are based on your consent.

 The data processed will be kept until you decide to revoke your consent and in any case no later than 5 years from the collection of your consent.

Should the data, collected for the aforementioned purposes, be processed for the further purpose of protecting our rights in court, the processing, which will be based on our legitimate interest, after balancing your rights, will take place throughout the time necessary to achieve the purposes described.

The data may be transmitted to the Authorities, if requested by them. In this case, the Authorities will operate as independent Data Controllers and the transfer will take place on the basis of legal obligations.

  1. How and where do we process your data?

Your data is processed according to the principles of fairness, lawfulness and transparency, always protecting your privacy and your rights.

Processing will take place with means (physical and technological) suitable to guarantee its security and confidentiality at all times, according to the company’s best practices.

For the management of consents, preferences and for sending communications aimed at pursuing the aforementioned purposes, we use the Customer Relationship Management Software (CRM) offered in cloud computing by Salesforce.com Italy S.r.l., a company of the Salesforce.com Group, Inc.

The Data we process through the CRM are stored in two data centres owned and managed by Salesforce, located in geographically different locations, to ensure greater security and constant availability of data.

Salesforce data centres are located inside and outside the territory of the European Union and their location can be changed over time at the discretion of Salesforce. To check the location of Salesforce data centres, you can check the link.

Salesforce has undertaken with us to guarantee, in compliance with Art. 46 GDPR, adequate security standards, including measures for the secure transmission and storage of data, as well as the physical protection of its servers, adopting binding corporate rules and signing a specific legal act according to the standards of the European Commission and on the basis to the rulings of the European Court of Justice (Shrems II).

Salesforce, as External Data Processor, and its selected suppliers, have the possibility to access the data of the data subjects to improve and perfect their services, for example to solve technical problems, to improve the sending procedures or for commercial purposes, in order to geographically locate the area from which the recipients of the emails come.

In any case, Salesforce will not use your data to contact them directly, nor will it send them to third parties.

It is important that you know that, every time you select subscribe, modify and unsubscribe LINKS contained in the emails you receive from us, a direct link is activated to the Salesforce site on whose navigation data management practices we have no responsibility. If you want to know how your browsing data is collected and processed by Salesforce, please consult the Salesforce privacy policy at the following link.

  1. What happens if you do not communicate your data to us or do not provide consent to processing?

Failure to provide the data referred to in points a) 1, a) 2, a) 3, b) and c) 1, c) 2, c) 3, are essential to perform the contracts or provide the requested services.

The denial or withdrawal of consent to the processing of data for marketing (c 3) or profiling (c 4) purposes has no implication in relation to the provision of the services you requested, which simply will not be personalised.

  1. What are the categories of subjects who access your data?

Within the limits of the aforementioned obligations, purposes and tasks, your data will be processed:

  • by our employees, collaborators, suppliers, consultants and professionals, expressly appointed by us, subject to the assignment of specific instructions necessary for the fulfilment of the legislation on the protection of personal data. The updated list of the categories of managers and persons in charge of processing is kept at our registered office, at your disposal.
  • Together with our selected partners, appointed External Managers that we avail ourselves of.

Your data will not be disclosed or communicated to third parties, except to the extent necessary for the pursuit of the aforementioned purposes or to comply with legal obligations.

A complete list of external data processors is available at the request of the data subject.

  1. Are your data processed with automated processes?

Profiling process takes place in a fully automated way, and has the exclusive purpose of offering you targeted promotions or information. Profiling takes place on the basis of the areas of the site visited, the products selected or purchased, the events in which you have participated, the emails encountered and the information you provide by completing the surveys we propose.

Following an assessment of the consequences of profiling, we have deemed that these do not produce legal effects, nor significantly affect your person and your rights, also because, at any time, you can revoke the consent to the profiling of your data, without prejudice to the legitimate processing of data carried out before the revocation of the consent itself.

  1. What are your rights?

You can, at any time, exercise your rights, as envisaged by the GDPR and by the locally applicable legislation, in particular as regards Legislative Decree 196/2003 as amended, most recently referred to in Legislative Decree 101/2018.

Specifically, you are entitled to access your personal data; to obtain the rectification or cancellation of the same or the limitation of the processing that concerns you; to oppose their processing; to data portability; to revoke consent: the revocation of your consent does not affect the lawfulness of the processing based on the consent given before the revocation; to lodge a complaint with the supervisory authority (for Italy, the supervisory authority is the Guarantor Authority for the protection of personal data). The aforementioned rights may be exercised by sending a request to the references indicated in this statement.

You are entitled to check and modify your preferences at any time, as well as to revoke your consent to the processing of data, if this was the legal basis of the processing, by clicking on the appropriate buttons at the bottom of each email received.

If you deselect your preferences, your data will continue to be retained in Salesforce’s systems.

In case of withdrawal of consent to profiling, however, the data will be made anonymous with a secure process managed by our supplier Salesforce and stored anonymously.

As for the newsletters, you have the possibility, at any time, to deactivate the newsletter service in the following ways:

  • by clicking the opt-out button, contained in each email;
  • by e-mail to sentinel@pec.sentinel.it. ;
  • with a registered letter with return receipt to Sentinel CH. S.p.A., Via Robert Koch 2 Milan
  1. Methods of exercising your rights

You may exercise your rights, referred to in point 8 above, at any time by sending:

  • a registered letter with return receipt to Sentinel CH. S.p.A. Via Robert Koch 2 VAT 07118040158.
  • an e-mail to sentinel@pec.sentinel.it.