INFORMATION* ON THE PROCESSING OF PERSONAL DATA
pursuant to Articles 13 and 14 of EU Regulation 2016/679
1. Following the entry into force of EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data, the CompanyZA.BE S.R.L., represented by its current legal representative, with its registered office at Via Italia, 71/A, Paitone (BS) (VAT No. 01459290175, tel. 030/6896941, email ufficio@zabe.it) in the capacity ofdata controlleris obliged to provide you with information regarding the use of your personal data in its possession.
2. In accordance with the legislation referred to, the processing of your personal data – including, but not limited to: personal details, bank details, contractual data and contact details – will be carried out in accordance with the principles of fairness, lawfulness, transparency and the protection of privacy.
3. In accordance with Articles 13 and 14 of EU Regulation 2016/679, we hereby inform you that:
Your personal data will be processed for purposes relating to the company’s business activities, in order to enable the effective management of commercial relationships, whilst meeting contractual requirements and legal obligations; in particular, your data will be processed:
- for inclusion in the company’s computerised databases and/or physical records;
- for the management of transport documents, invoices and credit notes;
- for the management of day-to-day accounts and VAT;
- for managing quotations and tenders;
- for the management of receipts and payments;
- to fulfil any other contractual and/or statutory obligations.
4. The legal basis for the processing is the need to fulfil contractual and/or pre-contractual obligations pursuant to Article 6(1)(b) of Regulation (EU) 2016/679, as well as the need to comply with legal obligations pursuant to Article 6(1)(c).
5. Please note that the provision of data is mandatory for the purposes of establishing and properly carrying out the contractual relationship as a whole, as well as for the fulfilment of obligations, including those of a tax nature, as required by law.
Failure to provide this information would prevent the establishment and/or performance of the contractual relationship.
6. The personal data you provide will not be disclosed, but may be communicated to, or may come to the attention of, staff members and/or external parties who collaborate with the company (acting as data processors or independent data controllers), such as:
- freelancers specialising in accounting and/or tax matters;
- banks for the processing of receipts and/or payments;
- other parties to whom disclosure may be necessary for the proper and full performance of the contractual relationship and/or to comply with legal obligations.
7. Personal data may be processed with or without the use of electronic means, and the data will be retained for a period not exceeding that necessary to fulfil the purposes for which it is processed and/or to comply with legal obligations.
We would also like to point out that there are no fully automated decision-making processes; instead, the data is processed on the basis of assessments carried out by staff members.
8. We would like to inform you that you have the right to request from the Data Controller access to your personal data, rectification, erasure and restriction of processing; you also have the right to object to the processing of your personal data and to exercise your right to data portability. The rights referred to in this section may be exercised in accordance with Articles 15, 16, 17, 18, 20 and 21 of EU Regulation 2016/679, which we have included as an annex to this notice for your convenience. Please note that the data controller does not carry out any marketing or profiling activities.
For further information or clarification, please contact the administrative office of the data controller using the contact details provided in point 1), asking to speak to the person responsible for responding to data subjects.
9. You have the right to lodge a complaint with the supervisory authority designated under national law.
We would like to take this opportunity to send our warmest regards.
ZA.BE. S.R.L.
*This notice supplements and completes information already known to the data subject.
Article 15 Right of access by the data subject The data subject has the right to obtain from the data controller confirmation as to whether or not personal data concerning him or her are being processed and, where that is the case, to obtain access to the personal data and to the following information: a) the purposes of the processing; b) the categories of personal data concerned; c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if they are recipients in third countries or international organisations; d) where possible, the envisaged period for which the personal data will be stored or, if this is not possible, the criteria used to determine that period; e) the existence of the data subject’s right to request from the data controller the rectification or erasure of personal data, or the restriction of the processing of personal data concerning them, or to object to such processing; f) the right to lodge a complaint with a supervisory authority; g) where the data have not been collected from the data subject, any available information as to their origin; (h) the existence of automated decision-making, including profiling as referred to in Article 22(1) and (4), and, at least in such cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. 2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the existence of appropriate safeguards pursuant to Article 46 relating to the transfer. 3. The controller shall provide a copy of the personal data undergoing processing. Where the data subject requests further copies, the controller may charge a reasonable fee based on administrative costs. If the data subject submits the request by electronic means, and unless the data subject specifies otherwise, the information shall be provided in a commonly used electronic format. 4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
Article 16 Right of rectification The data subject has the right to obtain from the data controller the rectification of inaccurate personal data concerning him or her without undue delay. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by providing a supplementary statement.
Article 17 Right to erasure (‘right to be forgotten’) 1. The data subject has the right to obtain from the data controller the erasure of personal data concerning him or her without undue delay, and the data controller is obliged to erase the personal data without undue delay if any of the following grounds apply: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; 4 May 2016 EN Official Journal of the European Union L 119/43 (b) the data subject withdraws the consent on which the processing is based in accordance with Article 6(1)(a) or Article 9(2)(a), and there is no other legal basis for the processing; (c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2); (d) the personal data have been unlawfully processed; (e) the personal data must be erased in order to comply with a legal obligation under Union law or the law of the Member State to which the controller is subject; (f) the personal data have been collected in relation to the provision of information society services referred to in Article 8(1). 2. Where the controller has made personal data public and is obliged, pursuant to paragraph 1, to erase them, shall, taking into account the available technology and the costs of implementation, take reasonable measures, including technical measures, to inform controllers who are processing the personal data of the data subject’s request to remove any links to, or copies or reproductions of, their personal data. 3. Paragraphs 1 and 2 shall not apply to the extent that the processing is necessary: (a) for the exercise of the right to freedom of expression and information; (b) for compliance with a legal obligation which requires processing under Union law or the law of the Member State to which the controller is subject, or 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 Article 9(2)(h) and (i) and 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 such processing; or (e) for the establishment, exercise or defence of legal claims.
Article 18 Right to restriction of processing 1. The data subject has the right to obtain from the data controller the restriction of processing where one of the following circumstances applies: a) the data subject contests the accuracy of the personal data, for the period necessary for the data controller to verify the accuracy of such personal data; b) the processing is unlawful and the data subject objects to the erasure of the personal data and requests instead that its use be restricted; c) although the data controller no longer requires the personal data for the purposes of the processing, the data is necessary for the data subject to establish, exercise or defend a legal claim; d) the data subject has objected to the processing pursuant to Article 21(1), pending verification as to whether the legitimate grounds of the data controller override those of the data subject. 2. Where processing is restricted in accordance with paragraph 1, such personal data shall be processed, except for storage, only with the data subject’s consent or for the purpose of establishing, exercise or defence of a legal claim, or to protect the rights of another natural or legal person, or for reasons of substantial public interest of the Union or of a Member State. L 119/44 EN Official Journal of the European Union 4.5.2016 3. A data subject who has obtained the restriction of processing in accordance with paragraph 1 shall be informed by the controller before that restriction is lifted.
Article 20 Right to data portability 1. The data subject has the right to receive the personal data concerning him or her, which he or she has provided to a data controller, in a structured, commonly used and machine-readable format, and has the right to transmit those data to another data controller without hindrance from the data controller to whom the data were provided, where: (a) the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a), or on a contract pursuant to Article 6(1)(b); and (b) the processing is carried out by automated means. 2. When exercising their rights regarding data portability under paragraph 1, the data subject shall have the right to obtain the direct transmission of personal data from one controller to another, where technically feasible. 3. The exercise of the right referred to in paragraph 1 of this Article is without prejudice to Article 17. That 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 must not adversely affect the rights and freedoms of others.
Article 21 Right to object 1. The data subject has the right to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them pursuant to Article 6(1)(e) or (f), including profiling based on those provisions. The data controller shall cease further processing of the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. 2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her carried out for such purposes, including profiling in so far as 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 May 2016 EN Official Journal of the European Union L 119/45 4. The right referred to in paragraphs 1 and 2 shall be explicitly brought to the data subject’s attention and shall be presented clearly and separately from any other information at the latest at the time of the first communication with the data subject. 5. In the context of the use of information society services and without prejudice to Directive 2002/58/EC, the data subject may exercise their right to object by automated means using specific technical measures. 6. Where personal data are processed for scientific or historical research purposes or for statistical purposes in accordance with Article 89(1), the data subject shall, on grounds relating to their particular situation, have the right to object to the processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out in the public interest.