Contact form disclosure pursuant to art. 13 Regulation EU 2016/679
Relevant legislation:
- EU Regulation no. 679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, and the free movement of personal data (hereinafter “EU Regulation”)
- Italian Legislative Decree No. 196 of 30 June 2003 (hereinafter the 'Privacy Code'), as amended by Italian Legislative Decree No. 101 of 10 August 2018
- Recommendation no. 2/2001 of 17 May 2001 on the minimum requirements for on-line data collection in the European Union, adopted by the European personal data protection authorities, meeting in the Group set up by art. 29 of Directive no. 95/46/EC (hereinafter “Recommendation of the Workgroup pursuant to art. 29”)
Data Science S.r.l. (hereinafter "the Company"), controlled by Var Group S.p.A. pursuant to Article 2359 of the Italian Civil Code., with registered office at via Piovola 138, Empoli (FI), VAT no. 07235860488, wishes to inform users of the terms and conditions applied by the Company to the processing operations performed on their personal data.
In particular, the information is provided in relation to personal data supplied by users by filling in the "contact form" on the Company's website.
The Company acts as 'Data Controller', meaning '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'.
In concrete terms, the processing of personal data may be carried out by persons specifically authorised to carry out processing operations on users' personal data and, to this end, duly instructed by the Company.
In application of the legislation on the processing of personal data, users who consult and use the Company's website assume the role of 'data subjects', meaning the natural persons to whom the personal data being processed refer.
1. Purposes and legal basis of the personal data processing
The personal data processed by the Company are directly provided by users, by filling in the contact form, in order to request information or receive assistance.
In this case, the processing is based on the execution of specific requests and the fulfilment of pre-contractual measures; the express consent of users is therefore not necessary.
On the basis of the specific and optional consent provided by users, personal data may be processed by the Company for the purpose of sending commercial and promotional communications relating to the Company's services and products, as well as information messages relating to the Company's institutional activities.
Please note that users may revoke their consent to the processing of their personal data at any time; revocation of consent does not affect the lawfulness of the processing carried out prior to such revocation.
You may revoke consent already given to the Company by writing to the following email address:
digitallaw&[email protected]
2. Methods and duration of personal data processing
The processing of users' personal data is carried out by company personnel specifically authorised by the Company; for this purpose, such persons are identified and instructed in writing.
The processing may be carried out using information technology, online or hard-copy instruments and media observing the rules intended to guarantee the security and confidentiality of the personal data, and among other things the accuracy, updating and pertinence of the personal data with respect to the purposes declared.
The personal data collected will be stored in electronic and/or hard-copy archives present at the registered office or operating offices of the Company.
The personal data conferred by users will be stored in a form that enables them to be identified for a period of time no longer than that necessary for the purposes, as identified in point 1 of the present disclosure, for which the said data are collected and processed.
In any case the storage period is determined observing the terms permitted by the applicable laws.
In relation to marketing and commercial promotion purposes, in the case of expression of the optional consent required, the personal data collected will be stored for the time strictly necessary for managing the purposes indicated above according to criteria based on observance of the current laws and correctness and balance between the legitimate interest of the Company and the rights and freedoms of the users. Consequently, in the absence of specific rules that provide for different storage times, the Company will take care to use the personal data for the aforesaid marketing and commercial promotion purposes for a congruous time.
In any case the Company will take great care to avoid use of the personal data for an unlimited time, proceeding periodically to check in an appropriate manner the effective continuation of the users’ interest in having the processing performed for marketing and commercial promotion purposes.
3. Nature of conferment of personal data
The conferment of personal data is optional, but necessary in order to provide a response to requests for information or assistance made by users.
In particular, non-compilation of the fields present in the contact form prevents sending of requests for information or assistance to the Company.
In this case, consent to the processing of personal data is 'compulsory' insofar as it is instrumental to obtaining replies to requests for information or assistance made to the Company.
In the other case pursuant to point 1 of the present disclosure, the processing is based on conferment of the specific and optional consent; as already stated, the consent may be withdrawn.
4. Recipients of personal data
Users' personal data may be communicated, in Italy or abroad, within the territory of the European Union (EU) or the European Economic Area (EEA), in fulfilment of an obligation imposed by law, regulation or Community legislation; in particular, personal data may be communicated to public authorities and public administrations for the performance of institutional functions.
Moreover, without the need for users' consent, personal data may be communicated to companies belonging to the Var Group S.p.A. business group for the sole purpose of responding to requests for information or assistance addressed to the Company.
The personal data will not be distributed and therefore will not be divulged to the public or to an indefinite number of parties.
5. Rights pursuant to arts 15, 16, 17, 18, 20 and 21 of EU Regulation 2016/679
Users, in their capacity as data subjects, may exercise the rights of access to the personal data provided for in art. 15 of the EU Regulation and the rights provided for in arts 16, 17, 18, 20 and 21 of the said Regulation regarding the rectification, erasure, restriction of the processing of the personal data, the portability of the data, where applicable, and objection to the processing of the personal data.
The aforesaid rights may be exercised by writing to the following address: digitallaw&[email protected]
If the Company does not respond within the time provided for in the legislation or the response provided is unsuitable, users may appeal to the Personal Data Protection Authority.
These are the details:
Personal Data Protection Authority
Piazza Venezia n. 11 - 00187 Roma
Fax: (+39) 06.69677.3785
Telephone switchboard: (+39) 06.69677.1
E-mail: [email protected]
We must specify that SeSa S.p.A., the company that performs the function of holding in the SeSa S.p.A. business group to which the Company belongs in consideration of the control over Var Group S.p.A. under the terms of art. 2359 of the Italian Civil Code, after assessing the specialist knowledge of the provisions on the subject of personal data protection, has appointed the Personal Data Protection Officer. The Personal Data Protection Officer oversees observance of the legislation on the subject of personal data processing and provides the necessary advice.
In addition, where necessary, the Personal Data Protection Officer cooperates with the Personal Data Protection Authority.
Below are the relevant contact details: [email protected]