With this privacy disclosure, Modula SpA, with registered office in Fiorano Modenese (MO), Via Ghiarola Vecchia no. 73, informs you that - pursuant to and in accordance with the provisions of art. 13 of European Regulation 2016/679 on the protection of personal information (“GDPR”) - your personal information will be processed using electronic and manual instruments, including through social networks, in Italy and abroad.
This disclosure is drafted on the basis of the principle of transparency and all elements required by the GDPR and is broken down into individual sections in order to make it faster and easier to read and understand (the “Disclosure”).
1. Data controller
The Data Controller (the “Data Controller”) is Modula SpA, with registered office in Fiorano Modenese (MO) - Via Ghiarola Vecchia no. 73.
2. Legal basis of processing
The legal bases of the processing of your personal information are the consent you provide, the fulfilment of contractual obligations and the fulfilment of legal obligations.
In any event, it will always be possible to request clarifications concerning the concrete legal basis of all processing and in particular a specification of whether the processing is based on the law, set forth in a contract or necessary to conclude a contract.
3. Purpose of the processing
1) Your personal information will be processed for the following purposes:
a) to send newsletters;
b) to manage requests for estimates;
c) for the subscription to and activation of the provision of the Service and the connected services set forth in the contract;
d) to invoice amounts and any supplementary services;
e) to fulfil regulatory obligations including accounting, administrative and tax obligations;
f) to manage any complaints and disputes;
g) to prevent fraud and manage delays and/or non-payment;
h) to protect, manage and recover receivables;
i) for the storage and use of accounting data to refuse future contractual relationships;
j) to manage and maintain the website;
k) for participation through the website in initiatives organised by the data controller (such as events).
2) In addition, your personal information will be processed for purposes relating to:
a) sending information, sales offers, advertising and promotional materials regarding our products or services (including with automated procedures via email, SMS, post, telephone contact, etc.);
b) the collection and analysis of behaviours and habits relating to the use of web content and our services, including through cookies, so as to conduct market research, improve the services provided and customise them, as well as reduce the number of repetitions of advertising messages and facilitate the forwarding of the sales information and offers pursuant to letter a). The processing of your personal information for profiling purposes will take place with automated and non-automated instruments and means, through data processing instruments that will create your commercial and web behaviour profile. This data processing instrument creates connections between the data collected during your navigation on the Website through the use of profiling cookies.
The provision of your data is necessary to achieve the purposes pursuant to point 1) letters a) and b).
Failure to provide information or the provision of partial or inaccurate information will make it impossible for Modula SpA to provide you with the services requested.
The processing of your information for the purposes pursuant to point 2) letter a) is justified by legitimate interest; in any case, with reference to such purposes, you may revoke your consent at any time in accordance with the methods set forth in point 8).
The processing of your information for the purposes pursuant to point 2) letter b) is optional; however, failure to provide information or the provision of partial or inaccurate information will make it impossible for Modula SpA to improve the services provided and customise them through profiling activities.
4. Communication of personal information
Your personal information will be processed exclusively by people authorised to process it and by people designated as data processors, in compliance with the GDPR, so as to carry out all processing activities necessary to pursue the purposes specified in this Disclosure. The personal information may be communicated to public entities or the judicial authority, when required by law or to prevent or suppress the commission of a crime.
5. Data storage period
The personal information will be stored for the period of time necessary to pursue the purposes relating to point 3). In particular, the personal information will be processed for a period of time equal to the minimum necessary or until the termination of the contractual relationships in place between you and the Data Controller, without prejudice to any further storage period that may be imposed by legal standards. In relation to the marketing purposes pursuant to letter a), the information will be stored, without prejudice to the revocation of consent, for a period of time not exceeding that necessary for the achievement of such purposes. If consent is provided with reference to profiling purposes, the information will be stored, without prejudice to the revocation of consent, for a period of time not exceeding that necessary for the achievement of such purposes.
The information will be stored for an additional period of time should this become necessary to manage any disputes or litigation.
6. Revocation of consent
The data subject is entitled to revoke the consent provided at any time either fully and/or partially. This shall not impair the lawfulness of the Processing carried out based on the consent provided prior to the revocation.
To revoke your consent, simply contact the Data Controller at the addresses published in this disclosure. In the case of registration on the website, you may access your personal profile and change the consent provided.
7. Geographical scope of processing
Your personal information will be processed by the Data Controller within the territory of the European Union.
If for technical and/or operational reasons it is necessary to rely on parties located outside the European Union, such parties shall be appointed as Data Processors and the transfer of personal information to such parties, limited to carrying out specific Processing activities, shall be governed in compliance with the provisions of the GDPR.
All necessary precautions shall be adopted to guarantee the full protection of personal information basing such transfer on the assessment of appropriate guarantees including for example adequacy decisions with regard to third-party recipient countries expressed by the European Commission; appropriate safeguards expressed by the third-party recipient pursuant to article 46 of the GDPR.
In any case, you may request further details from the Data Controller if your personal information has been processed outside the European Union, requesting evidence of the specific safeguards put into place.
8. Rights of the data subject
Pursuant to arts. 15 et seq. of the GDPR, you may exercise the rights expressly recognised to the data subject at any time, and in particular:
• obtain confirmation as to whether your personal information is being processed and obtain access to the data and the following information (processing purposes, categories of personal information, recipients and/or categories of recipients to which the data were and/or will be communicated, storage period);
• obtain the adjustment of inaccurate personal information regarding you and/or the supplementation of incomplete personal information, also by providing a supplementary declaration;
• obtain the erasure of the personal information, in the cases provided under the GDPR;
• obtain restriction to processing in the cases established in privacy legislation in force;
• obtain the portability of your information, and in particular request your personal information provided to the Data Controller and/or request the direct transmission of your information to another data controller;
• object to the processing at any time, for reasons associated with your specific situation, to the processing of your personal information in full compliance with privacy legislation in force, as well as for marketing and profiling purposes.
You may exercise your rights by writing to the following email address: [email protected] Please attach a copy of your ID.
In any event, you will always be entitled to submit a complaint to the competent supervisory authority (Data Protection Commissioner) pursuant to art. 77 of the GDPR, if you believe that the processing of your data is contrary to Privacy Legislation in force.
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