INFORMATION ON THE PROCESSING OF PERSONAL DATA

Pursuant to art. 13 of the EU Regulation 2016/679 (hereinafter “GDPR”), containing provisions for the protection of persons and other subjects with respect to the processing of personal data, we wish to inform you that the personal data provided by the Supplier or acquired by TPS Pro srl with registered office in Bologna, Via A. Gramsci 3 – 40121 Bologna (BO) VAT number 03169391202 (hereinafter “DATA CONTROLLER”), as data controller, during the contractual relationship or, in any case, with reference to it, will be processed with the methods and for the following purposes:

1. Object of the Processing

The DATA CONTROLLER processes personal identification data (e.g. name, surname, company name, address, telephone and email contacts, bank and payment details) (hereinafter, “PERSONAL DATA” or also “DATA”) communicated by you on the occasion of the conclusion of contracts relating to goods and/or services offered by the DATA CONTROLLER.

2. Purposes of the processing

Your personal data are processed:

a) without your express consent (art. 24 lett. a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes:

▪ conclude contracts for goods and/or services offered by the DATA CONTROLLER;

▪ fulfil the pre/contractual and fiscal obligations deriving from relations with you in existence;

▪ fulfil the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as, for example, in the field of anti-money laundering);

▪ exercise the rights of the DATA CONTROLLER, for example the right of defense in court;

b) only with your specific and distinct consent (articles 23 and 130 of the Privacy Code and article 7 of the GDPR), for the following Marketing Purposes:

▪ send you via e-mail, mail and/or sms and/or telephone contacts, newsletters, commercial communications and/or advertising material on products or services offered by the DATA CONTROLLER and detection of the degree of satisfaction on the quality of goods and services;

▪ send you via e-mail, mail and/or sms and/or telephone contacts, commercial and/or promotional communications of third parties (for example, business partners, insurance companies).

We point out that if you are already our customers, we may send you commercial communications relating to services and products of the DATA CONTROLLER similar to those you have already used, unless you disagree (art. 130 paragraph 4 Privacy Code).

3. Methods of processing

The processing of your personal data is carried out by means of the operations indicated in art. 4 of the Privacy Code and art. 4 no. 2) GDPR and precisely: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electronic and/or automated processing. The DATA CONTROLLER will process the personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the Service Purposes and for no more than 2 years from the collection of data for the Marketing Purposes.

4. Access to data

Your data may be made accessible for the purposes referred to in art. 2.a) and 2.b) to:

▪ employees and collaborators of the DATA CONTROLLER

▪ third parties or other subjects (by way of example, credit institutions, professional firms, insurance companies, accounting, tax, legal consultants, etc.) who carry out outsourcing activities on behalf of the DATA CONTROLLER, in their capacity as external data processors.

5. Communication of data

Without the need for express consent (pursuant to Article 24 letter a), b), d) Privacy Code and Article 6 letter b) and c) GDPR), the DATA CONTROLLER may communicate your data for the purposes referred to in art. 2.a) to Supervisory Bodies (such as IVASS, ANAC), Judicial Authorities, as well as to those subjects to whom the communication is mandatory by law for the performance of said purposes. These subjects will process the data in their capacity as independent data controllers.

6.Data transfer

Personal data are stored on servers located in Italy, within the European Union. It is understood in any case that the DATA CONTROLLER, where necessary, will have the right to move the servers even outside the EU. In this case, the DATA CONTROLLER hereby ensures that the transfer of data outside the EU will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

7. Nature of the provision of data and consequences of refusing to answer

The provision of data for the purposes referred to in art. 2.a) is mandatory. In their absence, we cannot guarantee you the Services of art. 2.a). The provision of data for the purposes referred to in art. 2.b) is instead optional. You can therefore decide not to provide any data or to deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the DATA CONTROLLER. You will still be entitled to the Services referred to in art. 2.a).

8. Rights of the data subject

In your capacity as a data subject, pursuant to art. 7 of the Privacy Code and art. 15 of the GDPR you have the following rights:

➢ obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;

➢ obtain the indication: a) of the origin of the personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of processing carried out with the aid of electronic instruments; d) of the identification details of the DATA CONTROLLER, of the data processors and of the designated representative (art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR); e) of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, managers or agents;

➢ obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in points 1. and 2. have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where this proves impossible or involves a use of means manifestly disproportionate to the protected right;

➢ 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 the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, by using automated call systems without the intervention of an operator by e-mail and/or by traditional marketing methods by telephone and/or paper mail. It should be noted that the right of opposition of the data subject, set out above, for direct marketing purposes by automated means extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right of opposition even only in part. Therefore, the data subject can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.

Where applicable, you also have the rights referred to in Articles 15-21 of the GDPR (Right of rectification, right to be forgotten, right to limitation of processing, right to data portability, right to object), as well as the right to complain to the Data Protection Authority pursuant to art. 77.

9. How to exercise rights

You can exercise your rights at any time by sending:

– a registered letter with return receipt to TPS Pro srl, Via A. Gramsci 3 – 40121 Bologna (BO)

– an e-mail to the address info@tpspro.it

10. Data controller, data processor and data processors

The data controller is TPS Pro srl with registered office in Via A. Gramsci 3 – 40121 Bologna (BO). The updated list of data processors and data processors is kept at the registered office of the DATA CONTROLLER.

11. Cookie policy

A cookie is a small text file (a few bytes) exchanged between a website and the browser and normally used by the website manager to store information necessary to improve navigation within the site.

Technical cookies: These cookies allow the site to function properly; they are aimed at maintaining adequate navigation performance or increasing the functionality or performance of the site. They are divided into:

•  navigation or session cookies: they are aimed at ensuring the normal navigation and use of the site, using different options or services. These cookies allow, for example, to store the elements that characterize a specific request, make a purchase, subscribe to the participation in an event;

•  functionality cookies: these are cookies that allow the user to navigate according to a series of criteria selected (such as language, text characters, type of browser) in order to improve the service rendered

•  analytical cookies: they are used to process statistical analysis on the navigation methods of users on the site through computers on the number of pages visited or the number of clicks made on a page during the navigation of the site, as well as reports on demographic data (such as sex, age and interests). They are used to collect data on how visitors (not only those who are registered) use the site and thus allow us to improve its appearance and navigation. In particular, the Google service called Google Analytics is used, to which non-aggregated data are sent and for this reason the informed consent of the user is required.

Profiling cookies: They are used by third-party providers that allow you to display banner ads on other affiliated sites, showing you the latest products you have viewed on the site. To carry out this promotional activity, we use both proprietary and third-party cookies.

This site does not use cookies for profiling users, nor are other tracking methods used.

Instead, session cookies (non-persistent) are used strictly limited to what is necessary for safe and efficient navigation of the sites. The storage of session cookies in terminals or browsers is under the control of the user, where on the servers, at the end of the HTTP sessions, information relating to cookies remains recorded in the service logs, with storage times not exceeding seven days like the other navigation data.

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