Privacy Policy


INFORMATION SHEET AND REQUEST OF CONSENT ABOUT THE PROCESSING OF PERSONAL DATA

Dear User/Data subject,
this information sheet is provided pursuant to Legislative Decree 196 dated 30 June 2003, as subsequently amended (Privacy Code), and pursuant to Articles 13 and 14 of (EU) Regulation 2016/679 of the European Parliament and the Council dated 27 April 2016.
We inform you that the personal data you have provided when consulting website www.tvm-tech.it, will be processed by the company as the Data Controller in order to give you the opportunity to get in touch with it for information regarding the products and services offered by company Tvm-Tech S.r.l. (hereinafter, also TVM) and to enable users to request from the same company to subscribe to a specific newsletter through which to get good trade deals and/or to be constantly updated about the company’s activities and products and/or to get in touch with the Data Controller to be able to order its products. 
Such data will be processed by Tvm-Tech S.r.l., represented by its temporary representative, as Data Controller (hereinafter, also Controller), in compliance with the protection principles defined by the Code and subsequent amendments regarding personal data, as by all European and national legislative actions and/or decisions of controlling Authorities.
The following information sheet relates to the website www.tvm-tech.it, but not to other websites the User may visit by means of a link leading there.

 

A. PURPOSES OF PROCESSING 

The data voluntarily provided by the Users are variously processed by the Controller to:

  • Enable the User to get in touch with the Data Controller in order to receive information about the products and services provided by TVM;
  • Enable the user to receive a specific newsletter through which to get good trade deals and to be always updated about the activities and the products sold by the Data Controller. Such processing is optional and will be carried out only following User consent.

 

B. TYPE OF DATA COLLECTED AND PROCESSED 

The following personal data are collected, for both types of processing described above: 

  • Full Name; 
  • E-mail;
  • Telephone (optional).

The user will also be asked to provide a brief description of the reason why the Data Controller is being contacted.
Although Data Subjects may make their choices freely and without prejudice to the provision of navigation data, it is essential to provide the above-described data and failure to provide, even partially, the data expressly mentioned as necessary will make it impossible for the user to receive the newsletter and/or dedicated advantageous trade deals and/or to contact the Data Controller in order to find information regarding the products and services offered by the company or purchase them. 
The telephone number remains out of this list; its provision is not mandatory but optional.
In any case, for the processing of data regarding the newsletter, explicit User consent is necessary, and it can be cancelled in any moment.

 

C. DATA CONTROLLER, DATA PROCESSOR AND PEOPLE IN CHARGE 

The Data Controller is company Tvm-Tech S.r.l. (VAT no. 03168500167), represented by its temporary legal representative, with registered office in Via G. Natta 10, 24030 Mapello, Bergamo.
We inform you that the Data provided can be processed by other entities involved in the Controller’s organization, all in the position of people in charge of processing, or external parties (for example, providers of third-party technical services, hosting providers, providers of platforms for online payments, platforms to provide training programmes), appointed as entities in charge or, if necessary, External Data Processors operating on behalf of the Controller. 
In any case, all the entities that process data in the name and on behalf of the Data Controller will be duly appointed and will feature the organization of means and resources to process personal data in accordance with the provisions of the GDPR.

 

D. METHODS OF PROCESSING 

The personal data that have been provided will be processed at the office of the Data Controller or by External Data Processors appointed by the Data Controller (providers of IT and logistic services; providers of outsourced services, cloud computing and management services; external professionals and consultants; external software programmes for mailing list management). Data will be processed by means of IT and/or data transmission procedures in the ways and within the limitations which are necessary to pursue the above-mentioned purposes. In any case, the server where customers’ data will be stored is located within the European Union.
The Data Controller makes use of services provided by major companies in the sector which are tasked with developing and maintaining ERP software programmes and the technical maintenance of the website. 

 

E. DATA TRANSFER TO THIRD COUNTRIES 

The Data Controller declares that data processed belonging to professionals and to company representatives are not transferred to third countries.

 

F. STORAGE PERIOD 

We inform you that Data provided will be processed and stored by the Data Controller for the above-mentioned purposes and will be stored at the Data Controller’s premises for the times indicated below.
When invoicing, data regarding purchases made will be stored for 10 years from the invoice date, in accordance with the provision of applicable tax/accounting law.
If the User has contacted the Data Controller purely to find information regarding products and services offered by the company, without actually purchasing products and/or services, such data will be stored for a period of one year and will then be erased, the amount of time to give the Data Controller an adequate time frame to perform the erasure from a technical viewpoint and in order to enable the Data Controller to better meet the User’s requirements in the event of further contact. 
If the User has given their consent in order to ask to receive the newsletter and/or interesting and advantageous economic deals regarding the products marketed by the Data Controller (processing for Marketing), the Processing shall continue until the User withdraws their consent. In each dedicated email containing Newsletters or good economic deals, there will be a specific link by means of which the User can withdraw their consent.
From the moment of withdrawal, the Data Controller will immediately stop sending Newsletters and/or commercial offers and will have thirty days to erase all personal data, which is an adequate amount of time to erase data from a technical/logistic viewpoint.
Personal data collected for purposes that can be attributed to a legitimate interest of the Data Controller will be stored until such interest has been met.

 

G. RIGHTS OF THE DATA SUBJECT

The data subject may at any time exercise their rights vis-à-vis the Data Controller pursuant to Legislative Decree 193/2006 and Regulation (EU) 2016/679 as they are defined in the following articles:

  1. RIGHT OF ACCESS BY THE DATA SUBJECT - Art. 15 Reg. (EU) 2016/679
  2. RIGHT TO RECTIFICATION - Art. 16 Reg. (EU) 2016/679
  3. RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”) - Art. 17 Reg. (EU) 2016/679
  4. RIGHT TO RESTRICTION OF PROCESSING - Art. 18 Reg. (EU) 2016/679
  5. RIGHT TO DATA PORTABILITY - Art. 20 Reg. (EU) 2016/679
  6. RIGHT TO OBJECT - Art. 21 Reg. (EU) 2016/679

 

GENERAL RULES FOR THE EXERCISE OF RIGHTS 

We inform you that the rights as per the paragraphs above can be exercised in any moment by sending an email to the following address: info@tvm-tech.it together with a digital copy of your valid identity document.
We remind you that if you ask us to stop all processing of your personal data, and not just that for promotional purposes, we will no longer be able to continue to provide you with the services you have requested us and that, unless you only request to stop sending promotional communications by means of automated systems, if you send us a general request we will stop all processing of your personal data, even by means of traditional instruments. 

In any case, our company may store some of your personal data if they may be necessary to defend or assert one of its rights.
Should you wish, an updated list with the names of the Data Processors is at your disposal at the offices of the Data Controller, from which you may also request it by sending an e-mail to info@tvm-tech.it.

 

Definitions 

ART. 5 GDPR 

For the purposes of this regulation, the following means:

Personal data: any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not ny automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Restriction of processing: the marking of stored personal data with the aim of limiting their processing in the future;

Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

Pseudonymisation: the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

Filing system: any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;

Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Members State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller; 

Recipient: a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing; 

Third party: a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

Consent of the data subject: any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her; 

Personal data breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

Genetic data: personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question; 

Biometric data: personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data;

Data concerning health: personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his of her health status; 

Main establishment:
a) as regards a Controller with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered the main establishment;
b) as regards a processor with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this regulation; 

Representative: a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor with regard to their respective obligations under this regulation;

Enterprise: a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity; 

Group of undertakings: a controlling undertaking and its controlled undertakings;

Binding corporate rules: personal data protection policies which are adhered to by a Controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity; 

Supervisory authority: an independent public authority which is established by a Member State pursuant to Article 51;

Supervisory authority concerned: a supervisory authority which is concerned by the processing of personal data because: 
a) the controller or processor is established on the territory of the Member State of that supervisory authority;
b) data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or
c) a complaint has been lodged with that supervisory authority;

Cross-border processing:
a) processing of personal data which takes place in the context of the activities of establishments in more than one Member State or a controller or processor in the Union where the controller or processor is established in more than one Member State; or 
b) processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State;

Relevant and reasoned objection: an objection to a draft decision as to whether there is an infringement of this regulation, or whether envisaged action in relation to the controller or processor complies with this regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;

Information society service: a service as defined in point (b) of Article 1 (1) of Directive (EU) 2015/1535 of the European Parliament and of the Council (19);

International organisation: an organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.