PERSONAL DATA PROCESSING PRIVACY POLICY
This personal data processing privacy policy is provided in relation to the processing of personal data collected in the context of the contractual relationship with 32 BIT S.R.L.
1. Data Controller
For the purposes of the privacy policy, the data controller is 32 BIT S.r.l. with registered offices in Via Eridania, 151 Occhiobello (RO) 45030
Tax code and VAT Reg. no. 01624050298 Tel. +39 328.5826326
CERTIFIED EMAIL: 32-bit@pec.it WEB site: www.trentaduebit.it (Data Controller).
The Data Controller is a company active in the field of management software design and subsequent consultancy and support.
2. DPO
The Data Controller has appointed a Data Protection Officer who can be contacted at the email address dpo@trentaduebit.it
3. Data collected
The personal data that the Data Controller collects are your identification data communicated for the conclusion and execution of the existing contractual relationship, as well as those of its employees and collaborators (hereinafter the “Data”).
4. Purpose and legal basis of data processing
The Data you provide are used for the sole purpose of:
- executing the assignment conferred by virtue of the contractual relationship with the Data Controller and fulfilling the legal obligations related to it;
- subscribing to the newsletter service of the Data Controller;
- sending, by traditional mail, telephone, SMS, MMS, fax, email and instant messaging of communications of a commercial, promotional and advertising nature relating to the services and products provided by the Data Controller by the Data Controller;
- evaluating candidacy for open job positions.
The legal basis of the processing referred to in point a) is found in the execution of the contract to which the data subject is a party and the fulfilment by the Data Controller of the legal obligations related to it.
The provision of Data for this purpose is compulsory and any refusal thereof will make it impossible for the Data Controller to execute the existing contractual relationship.
The legal basis of the processing referred to in point b) is found in the execution of contractual measures at the request of the data subject.
The provision of Data for this purpose is compulsory and any refusal will make it impossible for the Data Controller to execute the request for subscription to the newsletter.
In any case, you can object to the processing and cancel your subscription to the newsletter service at any time by following the procedure specified in each newsletter or by sending a specific communication to the Data Controller, at the addresses indicated in the “Contacts” section.
The processing referred to in point c) is based on the legitimate interest of the Data Controller to promote its business and its products towards subjects who have expressed an interest in the activity of the Data Controller. Therefore, it is compatible with the expectation of the interested parties to stay updated on the activities of the Data Controller, as well as on the events and trade fairs in which the Data Controller will participate.
The Data Controller reserves the right to send such communications of a commercial, promotional and advertising nature by email to the company addresses communicated, both generic and specific. The right to object may be exercised at any time.
The legal basis of the processing referred to in point d) is found in the need to guarantee the requested evaluation of the data subject.
The provision of Data for this purpose is compulsory and any refusal will make it impossible for the Data Controller to execute the request for evaluation of their Curriculum Vitae regarding open positions.
5. Processing method
The Data will be processed by employees and/or collaborators of the Data Controller who are specifically designated as persons authorised to process (such as, by way of example, those in charge of the human resources function, the legal function, the administrative function and the information systems) and external data processors, whose respective names are available upon request to the Data Controller.
The Data Controller and the third parties it uses process the Data through manual processing or electronic or automated tools, according to logic strictly related to the purposes themselves and in any case in order to guarantee the security and confidentiality of the Data.
6. Communication (recipients) of the Data
The Data will be processed by the Data Controller and by the subjects appointed by it and may be communicated to third parties only where necessary for the performance of the activities referred to in article 3 above.
The third party recipients of the Data may process them, as the case may be, as independent data controllers or duly designated data processors.
The complete list of data processors is kept at the Data Controller’s head office and can be consulted upon request, to be sent to the contact details indicated in article 8 below.
7. Disclosure of Data
The Data will not be disclosed.
8. Period of storage
Your personal data are only processed for the time strictly necessary to achieve the purposes for which they were collected and, in any case:
- as regards the purpose referred to in point a) of the previous paragraph, for the entire duration of the contractual relationship and for the applicable statutory limitation periods;
- for the purposes referred to in point b) of the previous paragraph, the Data will be kept and processed for this purpose for up to 24 months from the subscription to the newsletter service, however, we will ask you if you wish to continue receiving the newsletter with one month’s notice and, in the event of refusal, the Data will be deleted; in the event of consent, they will be kept and processed for a further period of 24 months;
- for the purposes referred to in point c) above, no later than 24 months from collection;
- for the purpose referred to in point d), the data will be kept for a period not exceeding 3 (three) months.
9. Rights of the data subject
You have the right at any time to: (I) obtain confirmation of the existence or non-existence of personal data concerning you; (II) know the purposes of the processing and the methods, the recipients of such Data, and the retention period; (III) obtain the rectification or cancellation, and where applicable, the limitation of the processing; (IV) oppose the processing; (V) where applicable, receive – in a structured, commonly used and machine-readable format – the Data concerning you provided to the Data Controller and transmit such data to another data controller without impediment by the Data Controller; (VI) lodge a complaint with the Data Protection Supervisory Authority; (VII) select the methods with which you wish to be contacted for the purpose referred to in point c) of the preceding paragraph “Purpose and legal basis”.
To exercise the rights referred to in letters a. – c. above, you can contact the Data Controller at the following addresses:
- e-mail: info@trentaduebit.it
- ordinary mailing address: 32 BIT S.r.l., Via Eridania, 151, 45030 Occhiobello (RO) Italy, for the attention of the Privacy Manager.