Information on the protection of personal data
pursuant to art. 12 et seq. of EU regulation 679/2016
Pursuant to EU Regulation 679/2016, in observance of the accountability principle, any processing of personal data shall be done in a lawful, correct and transparent manner. These principles require that the Data Subject is notified that processing is carried out, is told of the purposes for which processing is done, and is advised of the rights that he/she may exercise.
In this regard, the Controller provides the Data Subject with the information necessary to ensure correct use in observance of the accountability principle.
Therefore, with this in mind, we invite you to read the following information.
The Royal Co. Srl, as the Controller, in the person of the legal representative pro-tempore, pursuant to and for the effects of EU Regulation 2016/679, with this document notifies the Data Subject that the personal data concerning them, acquired by the Controller or requested later and/or communicated by third parties, is necessary and will be used for the purposes indicated below.
The personal data processed will be, in general, personal details or company names or email addresses or telephone numbers.
The purposes for which processing is done
Personal data referring to the Data Subject or collected from the same will be used to provide you with The Royal Co. Srl services and assistance as per the Articles of Association.
For these purposes we may process your employees’ personal data, including data of a sensitive nature, based on your communication.
This information will be used exclusively for associative, pre-contractual, contractual, legal, tax and accounting obligations, for legal protection, service communications, and to manage complaints.
For the aforementioned purposes, processing your personal data does not require any consent and providing this personal data is a necessary requirement for the associative relationship.
Your personal data may also be used, in the continuation of the associative relationship, to notify you about new The Royal Co. Srl services or initiatives.
You will still be free to ask, at any time, to be unsubscribed from our mailing list for this type of associative communication, by emailing us at: firstname.lastname@example.org.
The methods by which data is processed and the confidentiality obligation
Processing is done with IT tools and/or manually on paper by parties bound to confidentiality with logic related to the purposes for which processing is performed and, in any case, to guarantee data security and protection.
The data collected will not be disclosed nor disseminated to third parties.
Communication to third parties
Your personal data may be communicated to third parties known to us exclusively for the aforementioned purposes and, specifically, to the following:
- Bodies and Public Administrations to fulfil legal obligations;
- External companies and professionals who may perform services on our behalf as External Processors;
A Data Subject’s personal data will be stored for the time needed to fulfil the relationship which exists between the parties and to fulfil the related obligations, without prejudice to a longer period of storage in compliance with current law. After such a period, the data will be deleted.
The Data Subject’s rights
Pursuant to current legislation, the Data Subject may assert his/her rights towards the Controller, as expressed by Regulation 679/2016, i.e.:
• Right of access (article 15);
• Right to rectification (article 16);
• Right to erasure (article 17);
• Right to restriction of processing (article 18);
• Right to data portability (article 20);
• Right to object to processing (article 21);
• Right to revoke consent;
• Right to lodge a complaint with a Supervisory Authority.
Right of access
The Data Subject shall have the right to obtain from the Controller confirmation as to whether or not personal data concerning him/her is being processed, and, where that is the case, access to the personal data and the following information:
• a) the purposes of the processing;
• b) the categories of personal data concerned;
• c) the recipients or categories of recipient to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations;
• d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• e) the existence of the right to request from the Controller rectification or erasure of personal data or restriction of processing of personal data concerning the Data Subject or to object to such processing;
• f) the right to lodge a complaint with a Supervisory Authority;
• g) where the personal data is not collected from the Data Subject, any available information as to its source;
• h) the existence of an automated decision-making process, including profiling, referred to in article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the Data Subject.
1. Where personal data is transferred to a third country or to an international organisation, the Data Subject shall have the right to be informed of the appropriate safeguards pursuant to article 46 relating to the transfer.
2. The Controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the Data Subject, the Controller may charge a reasonable fee based on administrative costs. Where the Data Subject makes the request by electronic means, and unless otherwise requested by the Data Subject, the information shall be provided in a commonly used electronic form.
The right to obtain a copy shall not adversely affect the rights and freedoms of others.
Right to rectification
The Data Subject shall have the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning him/her. Taking into account the purposes of the processing, the Data Subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure
1. The Data Subject shall have the right to obtain from the Controller the erasure of personal data concerning him/her without undue delay and the Controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
• a) the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• b) the Data Subject withdraws consent on which the processing is based according to point (a) of article 6(1), or point (a) of article 9(2), and where there is no other legal ground for the processing;
• c) the Data Subject objects to processing pursuant to article 21(1) and there are no overriding legitimate grounds for processing, or the Data Subject objects to processing pursuant to article 21(2);
• d) the personal data has been processed unlawfully;
• e) the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject;
• f) the personal data has been collected in relation to the offer of information society services referred to in article 8(1).
2. Where the Controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform Controllers which are processing the personal data that the Data Subject has requested the erasure by such Controllers of any links to, or copy or replication of, that personal data.
3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
• a) for exercising the right of freedom of expression and information;
• b) for compliance with a legal obligation which requires processing by Union or Member State law to which the Controller is subject for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
• c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of article 9(2) as well as article 9(3);
• d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing;
• e) to establish, exercise or defend a right in a court of law.
Right to restriction of processing
1. The Data Subject shall have the right to obtain from the Controller restriction of processing where one of the following applies:
• a) the accuracy of the personal data is contested by the Data Subject, for a period enabling the Controller to verify the accuracy of the personal data;
• b) the processing is unlawful and the Data Subject opposes the erasure of the personal data and requests the restriction of its use instead;
• c) the Controller no longer needs the personal data for the purposes of the processing, but the data is required by the Data Subject to establish, exercise or defend a right in a court of law;
• d) the Data Subject has objected to processing pursuant to article 21(1) pending the verification of whether the legitimate grounds of the Controller override those of the Data Subject.
2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the Data Subject’s consent or to establish, exercise or defend a right in a court of law or to protect the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3. A Data Subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the Controller before the restriction is lifted.
Right to data portability
1. The Data Subject shall have the right to receive the personal data concerning him/her, which he/she has provided to a Controller, in a structured, commonly used and machine-readable format and shall have the right to transmit that data to another Controller without hindrance from the Controller to whom the personal data has been provided, where:
• a) the processing is based on consent pursuant to point (a) of article 6(1) or point (a) of article 9(2) or on a contract pursuant to point (b) of article 6(1); and
• b) the processing is carried out by automated means.
2. In exercising his/her right to data portability pursuant to paragraph 1, the Data Subject shall have the right to have the personal data transmitted directly from one Controller to another, where technically feasible.
3. The exercise of the right referred to in paragraph 1 of this article shall be without prejudice to article 17. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.
4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
Right to object to processing
1. The Data Subject shall have the right to object, on grounds relating to his/her particular situation, at any time to processing of personal data concerning him/her which is based on point (e) or (f) of article 6(1), including profiling based on those provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject or to establish, exercise or defend a right in a court of law.
2. Where personal data is processed for direct marketing purposes, the Data Subject shall have the right to object at any time to the processing of the personal data concerning him/her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. Where the Data Subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the latest at the time of the first communication with the Data Subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the Data Subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the Data Subject may exercise his/her right to object by automated means using technical specifications.
6. Where personal data is processed for scientific or historical research purposes or statistical purposes pursuant to article 89(1), the Data Subject, on grounds relating to his/her particular situation, shall have the right to object to the processing of the personal data concerning him/her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In addition to the aforementioned rights, the Data Subject has the right to withdraw his/her consent upon making an appropriate request, as well as to lodge a complaint with a Supervisory Authority in the cases provided for by law.
Controller and privacy notices
The Controller is The Royal Co. Srl, with offices at Via Enrico Berlinguer, 50/a, Montemurlo, Prato, Italy.
For any communication pursuant to the above articles of EU Regulation 2016/679, the Controller has made the following email address available: email@example.com.