ANEST IWATA STRATEGIC CENTER SRL based in Cardano al Campo (VA), Via degli Aceri 1-5, as the owner of the processing of personal data pursuant to d. lgs. 196/2003 and subsequent amendments – Personal Data Protection Code (“Privacy Code”) – and EU Regulation 679/2016 applicable from May 25, 2018 – General Data Protection Regulation (“RGPD”) (hereinafter Privacy Code and RGPD are collectively referred to as “Applicable Legislation”) recognizes the importance of the protection of personal data and considers their protection as one of the main objectives of its activity.
In compliance with the Applicable Legislation we are to provide due information regarding the processing of personal data provided. This information is provided pursuant to Articles 13 of the Applicable Legislation and which Anest Iwata Strategic Center srl invites you to read carefully as it contains important information on the protection of personal data and the security measures adopted to ensure their confidentiality in full compliance with the Applicable Legislation.
Anest Iwata Strategic Center srl informs that the processing of personal data will be based on the principles of lawfulness, fairness, transparency, purpose limitation and storage, data minimization, accuracy, integrity and confidentiality. Personal data will therefore be processed in accordance with the legislative provisions of the Applicable Legislation and the confidentiality obligations therein.

1. DATA CONTROLLER

According to the Applicable Regulations, the data controller is Anest Iwata Strategic Center srl located in Cardano al Campo (VA), Via degli Aceri 1-5.

2. PERSONAL DATA SUBJECT TO PROCESSING

“Personal Data” means any information concerning an identified or identifiable natural person with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more characteristic elements of his or her physical, physiological, psychological, economic, cultural or social identity.
“Particular Data” means personal data capable of revealing racial and ethnic origin, religious or philosophical beliefs, or trade union membership, as well as genetic and biometric data, data relating to a person’s health or sex life or sexual orientation.
“Judicial data” means personal data relating to criminal convictions and offenses or related security measures.
“Processing” means any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or set of personal data, such as collecting, recording, organizing, structuring, storing, adapting or modifying, extracting, consulting, using, communicating by transmission, dissemination or any other form of making available, comparing or interconnecting, limiting, erasing or destroying.

3. PLACE OF DATA PROCESSING

Data processing takes place at the aforementioned headquarters of the owner, at the operating offices and at identified third parties.

4. TYPES OF DATA PROCESSED

The processing involves personal and identification data voluntarily provided by the data subject (by way of example but not limited to: first name, last name, address, VAT number, tax code, landline or mobile phone number, e-mail address, bank details, etc.).

5. PURPOSE, LEGAL BASIS AND OBLIGATORY OR OPTIONAL NATURE OF PROCESSING

Personal data voluntarily provided will be processed by the controller for the following purposes:

A. Administrative-accounting.
For the purposes of the application of the provisions on the protection of personal data, the processing carried out for administrative-accounting purposes are those related to the performance of activities of an organizational, administrative, financial and accounting nature, regardless of the nature of the data processed. In particular, internal organizational activities, those functional to the fulfillment of contractual and pre-contractual obligations, the management of the labor relationship in all its phases, the keeping of accounts and the application of regulations on tax, trade union, social security-welfare, health, hygiene and safety at work pursue these purposes.

B. Informational and Promotional
The use of e-mail coordinates provided by the customer in the context of the sale of a product or service for the purpose of direct sales of its own products or services is permitted for the purpose of sending information and newsletters. The data subject, at the time of collection and at the time of sending each communication, is informed of the possibility to object to the processing at any time, easily and free of charge (Art. 130 paragraph 4 of Legislative Decree 196/03). In order to unsubscribe from the mailing list, it will be sufficient to write an e-mail at any time to the e-mail address privacy@anest-iwata-st.com with the subject “cancellation mailing list”.
C. Safety, pursuant to Legislative Decree 81/2008. With particular reference to the identification data freely given by the guest/visitor at our premises (first name, last name, entity or company to which he/she belongs), the processing has the sole purpose of ensuring compliance with formally applied company security procedures, also by virtue of the regulations in force

6. PROCESSING METHODS – DATA STORAGE

The processing will be carried out in automated and manual form, using methods and tools designed to ensure maximum security and confidentiality, by persons appointed as data processors and persons in charge of processing pursuant to applicable regulations. The data will be kept for a period not exceeding the purposes for which the data were collected and subsequently processed, and in any case in constancy of the existing contractual or commercial relationship.

7. SCOPE OF COMMUNICATION AND DISSEMINATION

The data subject to processing will not be disseminated, unless explicitly authorized by the data subject issued following appropriate information. On the other hand, the data may be communicated to companies contractually bound to the Data Controller and, where necessary, also to entities within and outside the European Union, in accordance with and within the limits set forth in Art. 42 by Art. 43 and Art. 44 of Legislative Decree No. 196/2003. The data may be communicated in this sense to third parties belonging to the following categories:
– subjects who provide services for the management of the information system used by the Data Controller and telecommunications networks, and who take care of the maintenance of the technological part (including e-mail and newsletter service);
– subjects and entities that collaborate with the Data Controller to carry out the training courses such as but not limited to: teachers, Fondi Paritetici Interprofessionali;
– freelancers, firms or companies as part of assistance and consulting relationships;
– subjects that carry out control, audit and certification tasks of the activities implemented by the Data Controller;
– competent authorities for fulfillment of obligations of laws and/or provisions of public bodies, at the request of the same.
The identification data processed in application of the company’s security procedures are not subject to communication, except for express and specific requests that may be made by the competent judicial and investigative authorities.
Subjects belonging to the above categories perform the function of Data Processor, or operate completely independently as separate Data Controllers. The list of data processors is constantly updated and available upon request at the Data Controller’s office.
Any further communication or dissemination will take place only with the explicit consent of the data subject.
In addition, in the course of ordinary processing activities, personal and identification data may be accessed and thus come to the attention of the individuals expressly designated by the writer as data processors and/or persons in charge of processing, authorized according to their respective profiles.

8. NATURE OF CONFERMENT AND REFUSAL

With regard to the data that we are obliged to know in order to fulfill the obligations arising from existing contracts, and obligations under laws, regulations, EU legislation, or provisions issued by the Authorities empowered to do so by law and by supervisory and control bodies, failure to provide such data will make it impossible to establish or continue the relationship, to the extent that such data are necessary for the execution of the same. The provision of data to allow the Holder to send commercial communications is optional; the interested party may object to the processing at any time by exercising the rights provided by the Applicable Regulations in the forms and ways indicated herein.
The Holder also makes it known that any non-communication, or incorrect communication, of any of the mandatory information, has as its emerging consequences:
-the inability of the holder to guarantee the adequacy of the processing itself to the contractual covenants for which it is performed;
-the possible mismatch of the results of the processing itself with the obligations imposed by the fiscal, administrative and civil law to which it is addressed.
The consent of the owner to the processing of the aforementioned data by Anest Iwata Strategic Center srl is not necessary in connection with the execution of a contract between the parties or the execution of pre-contractual measures taken at the request of the owner; by virtue of Article 6 paragraph b) such data will be processed without any need for consent, in the case of common data functional to such fulfillments.

9. RIGHT OF ACCESS TO PERSONAL DATA AND OTHER RIGHTS

Finally, we inform you that at any time you may exercise your rights towards the data controller in accordance with the Applicable Legislation (Chapter III, Articles 15 to 22), thus obtaining confirmation of the existence or non-existence of the same data, knowing their content and origin, verifying their accuracy, requesting their integration, updating, or rectification.
When the conditions provided for by the Applicable Regulations are met, you have the right to request cancellation, limitation of processing, portability, as well as to oppose, for legitimate reasons, their processing.
Specifically: right of access (art.15), rectification (art.16), erasure/oblivion (art.17), restriction of processing (art.18), data portability (art. 20), opposition (art. 21)
Pursuant to Art. 13 par. 2 lett d) you are informed of your right to lodge a complaint with the Data Protection Authority if you find that your rights as a data subject have been violated.

10. CHANGES TO THIS POLICY

This policy is subject to change. We recommend that you check our institutional website www.anest-iwata-coating.com regularly and refer to the most current version.

Cardano al Campo 01/10/2019