In compliance with the provisions of the L.D n. 196/2003 (hereinafter “Privacy Code”) and the Regulation (EU) 2016/679 (hereinafter “GDPR”), we inform you about the processing of personal data you provided.
IMMOBILIARE CARLO FARINI S.p.A (hereinafter “ICF”) respects the protection of the personal data that you share with it. Therefore, we guarantee security and accuracy in the processing of your data, as required by data protection regulation.
1. Purposes of data processing.
Personal data you provided shall be processed for the fulfillment of the obligations under this contract, in particular:
a. for adding your personal data in the company’s data base;
b. for service communications, to inform data subject about the real estate unit and the services offered and, in general, for needs related to the contractual relationship;
c. for accounting;
d. for management of receipts and payments;
e. for the fulfillment of the obligations set forth by Italian applicable law and, in general, by Italian system.
Data may be also processed to keep the data subject up-to-date about new products and/or services offered by the company and by companies related to it and, in general, for commercial and marketing purposes.
2. Nature of data collection and possible consequences of failure to provide such data.
The provision of data and the consent to their processing are mandatory to fulfill the obligations under this contract and required by law. Failure provision of data or omitted consent to their processing may prevent the closing of the contract, its execution or its pursuance.
The provision of data and the consent to their processing for commercial and marketing purposes are optional. Failure of such provision of data and consent has as limited consequence that data subject will not be informed about new products and/or services offered by the company as better specified in point 1.
3. Methods of data processing.
ICF intends to protect personal data by processing them in accordance with the principles of correctness, lawfulness and transparency. Therefore, we inform you that personal data will be processed through tools and procedures suitable for granting security and confidentiality, either on paper or electronic media, with the aid of digital supports, computerized and telematics means.
Data will be processed automatically and/or manually, implementing the technical security measures according to article 32 GDPR and to articles 33-36 and to exhibit B Privacy Code by subjects specifically appointed pursuant to article 29 GDPR.
Security measures will be kept to ensure the data subject’s confidentiality and to deny access to unauthorized third parties.
4. Data storage.
We inform that in accordance with the principles of legality, purpose limitation and the minimization of the data, also pursuant to article 5 GDPR, data will be kept and processed for no longer than is necessary for the purposes for which data is collected and processed and in compliance with the deadlines set by law.
For administration, accountability, orders, estimates, production, assistance, maintenance, shipping, invoicing, services, management of eventual litigation: 10 (ten) years, according to article 2220 Italian Civil Code, without prejudice for the time extensions justified by late payments.
5. Data communications.
For the execution of the contract and the above purposes data may be communicate:
a) to natural and juridical persons (by way of example: law firms, administrative and fiscal offices, data processing company, etc.) which assist ICF in the business management;
b) to companies connected to ICF;
c) to banking institutions for receipts and payments management;
d) to collaborators and employees, within the scope of their duties.
In order to carry out commercial and promotional activities, data may be communicated to companies and/or third parties connected to ICF which may process such data for analysis, market research, statistics, commercial and/or marketing purposes on their own or on behalf of ICF, in compliance with the privacy regulation and professional deontology.
6. Transfer of personal data to third countries.
ICF does not transfer personal data to third countries. Notwithstanding, for storage, ICF may use service providers in the cloud, whose servers may be settled in third countries. In such case, service providers will be selected among those that provide appropriate safeguards pursuant to article 46 GDPR.
7. Data subject’s rights.
Pursuant to article 7 Privacy Code, the data subjects shall exercise these rights:
- the right to obtain confirmation as to whether or not personal data concerning them exists and to obtain communication of such data in an intelligible form;
- the right to be informed:
a) of the source of personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated;
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing;
- the right to obtain:
a) updating, rectification, or where interested therein integration of the data;
b) erasure, anonymization or blocking of data that has been processed unlawfully, including data whose retention is unnecessary for the purposes for which it has been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
- the right to object, in whole or in part, a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
Starting from May 28th, 2018, the date on which GDPR is directly applicable in all the Member States, within the limits and terms set forth in articles 15-22 of the same Regulation, the data subjects are entitled to the right:
- to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data;
- if the processing is based on explicit consent of the data subject for one or more specific purposes, to withdraw the consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
- to lodge a complaint to the supervisory authority (Italian Authority Responsible for Privacy).
8. Data controller.
Data controller is the Legal Representative of ICF.
9. Data processor.
Data processor is the Legal Representative of ICF.
If you have any questions or comments about this policy, please contact us at firstname.lastname@example.org