2024 © Polo Trading
INFORMATION PROVIDED PURSUANT TO ARTICLES 13-14 OF THE GDPR (GENERAL DATA PROTECTION REGULATION) 2016/679
We inform you that, for the establishment and execution of the ongoing contractual relationships with you, our organization is in possession of your data, also acquired verbally, directly or through third parties, qualified as personal by European Regulation 2016/679 (GDPR). According to the indicated regulation, such processing will be based on the principles of fairness, lawfulness, transparency, and the protection of your privacy and your rights. Pursuant to Article 13 of GDPR 2016/679, we therefore provide you with the following information:
Nature of the data processed:
We process your personal, tax, and economic data necessary for the performance of contractual relationships, current or future, with your company, as well as to achieve effective management of business relationships. The data is processed without your express consent (art. 24 lett. a, b, c Privacy Code and art. 6 lett. b, e GDPR), solely and exclusively for the following Service Purposes: to fulfill pre-contractual, contractual, and tax obligations arising from relationships with you; to fulfill obligations provided for by law, regulation, EU legislation, or an order of the Authority; to exercise the rights of the Data Controller, for example the right of defense in court. We do not possess your data that can be qualified as special or judicial in nature (arts. 9 and 10 of the GDPR).
Purpose of processing and duration:
Your data is processed for the entire duration of the contractual relationship and also subsequently, for contractual needs and related legal and tax obligations, and for effective management of financial and business relationships, operations indicated in art. 4 Privacy Code and art. 4 no. 2) GDPR. The Data Controller will process personal data for the time necessary to fulfill the purposes mentioned above and in any case for no longer than 10 years from the termination of the relationship for Service Purposes.
Processing methods:
Processing will be carried out both manually and/or by computerized and telematic means with organizational and processing logics strictly related to the purposes themselves and in any case in such a way as to guarantee the security, integrity, and confidentiality of the data in compliance with the organizational, physical, and logical measures provided for by current regulations.
Obligation or option to provide data:
With regard to the data we are obliged to know, in order to fulfill obligations provided for by law, your failure to provide such data will make it impossible to establish or continue the relationship, to the extent that such data is necessary for its execution.
Scope of knowledge of your data:
The following categories of subjects may become aware of your data, as data processors or persons in charge of processing, appointed by the undersigned company, data controller: administrators; internal secretarial offices; accounting and invoicing staff; staff responsible for marketing services; agents and representatives.
Communication and dissemination:
Your data will not be disclosed by us to unspecified parties by making them available or for consultation. Your data may be communicated by us, within their respective and specific competence, to Entities and in general to any public or private subject with respect to whom there is for us an obligation (or faculty recognized by law or secondary or EU regulation) or need for communication, as well as to our consultants, to the extent necessary to carry out their assignment at our organization, subject to our letter of appointment imposing the duty of confidentiality and security.
Your rights:
As a data subject, you have the rights referred to in art. 7 Privacy Code and art. 15 GDPR and specifically the rights to:
1. obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet recorded, and their communication in an intelligible form;
2. obtain the indication of: a) the origin of personal data; b) the purposes and methods of processing; c) the logic applied in case of processing carried out with the aid of electronic instruments; d) the identification details of the data controller, data processors, and the representative designated pursuant to art. 5, paragraph 2 Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it as designated representative in the territory of the State, data processors or persons in charge;
3. obtain: a) the updating, rectification, or, when interested, integration of the data; b) the erasure, anonymization, or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data was collected or subsequently processed; c) certification that the operations in letters a) and b) have been notified, also as regards their content, to those to whom the data was communicated or disseminated, except where this proves impossible or involves a manifestly disproportionate effort compared to the right protected;
4. object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication, using automated calling systems without the intervention of an operator by email and/or by traditional marketing methods by telephone and/or paper mail.
Where applicable, you also have the rights referred to in Articles 16-21 GDPR (Right to rectification, right to erasure, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Supervisory Authority. At any time you may obtain confirmation of the existence or otherwise of personal data concerning you and the communication of such data and the purposes on which the processing is based. Furthermore, you may obtain the erasure, anonymization, or blocking of data processed unlawfully, as well as the updating, rectification, or, if you have an interest in this regard, the integration of the data. You may object, for legitimate reasons, to the processing itself.
We kindly ask you to promptly notify the relevant office of the company of any changes to your personal data so that we can comply with art. 11, letter (c) of the aforementioned regulation, which requires that the data collected be accurate and, therefore, updated.
Data controller and data processor:
The data controller is POLO TRADING di Liberali Chiara with registered office in Via Pallade 3/D / 31050 Ponzano Veneto (TV). The Data Processor, to whom you can contact to exercise your rights and/or for any clarifications regarding the protection of personal data, can be reached at: polo@polotrading.it