This policy shall be drawn up according to art. 13 and 14 of EU Regulation 2016/679 of the European Parliament and Council, relative to the protection of natural persons with regard to the processing of their personal data, and the free movement of such data and repealing the Directive 95/46 CE (General Regulation relative to data protection).
The personal data which could be processed are:
Ecoterm does not collect Special Categories of Personal Data (for example data on race, ethnicity, religious or philosophical belief, sexual orientation, political opinion, belonging to a trade union, information on Your health conditions and biometrics and genetics data).
However, Ecoterm could collect information about offences and criminal convictions.
We take these data directly from you, through the compilation of online forms, or they could be collected by third parties, independent controller of the processing (for ex. Companies of Ecoterm, agents, distributors, recruiters, commercial society, records, lists or database publicly available, etc.).
If you do not provide your personal data
Whenever it is necessary to collect personal data for law or contractual obligations, and you do not provide these data at the time of the request, we may not be able to carry out the performance expected for this contract ( for example, the supply of goods and services). In this case, we could be forced to delete one of your order relative to a product or a service, and if that happens, we will give you a prior communication.
The processing is carried out for the following purposes:
The provision of data has a mandatory nature for the above mentioned purposes, from point 1 to 3, because related to the performance of legal and contractual obligations/rights, and the purposes from point 4 to 6 because related to the execution of performed operations for the contractual relationship and the economic activity of the Commissioner. Regarding these purposes, the refusal to provide these data, that is to say the authorization of the processing, may cause the impossibility by the Commissioner and the person concerned to fulfil the mutual commitments during the contract drafting and the legal obligations.
Regarding point 7 to 9 the provision of data and their relative processing are discretionary.
For point 10, instead, which applies only to technical data of web surfing and use of our website, these data are collected and processed in an aggregate and anonymous way (they do not require the consent to use) and their processing is based on the legitimate interest of the controller to make the use of our website functional for the user and verify its proper functioning.
The data processing will be carried out by the employees designated by the Commissioner as responsible, or also by external parties, belonging to the same Group of Companies (controlled companies and subsidiaries), in accordance with the rules of the EU Regulation 2016/679 and the instructions provided by the Commissioner.
Ecoterm makes data accessible only to the authorized personnel for specific activities and tasks. These entities –for example- employees, interim and/or any other natural person placed under the direct authority of Ecoterm- perform their activity because they are authorized and according to the instructions given by Ecoterm.
On written request, addressed to Ecoterm Srl, Via dell’Industria n.710, 41038 San Felice Sul Panaro (MO) or to the e-mail address firstname.lastname@example.org Ecoterm will you communicate the names and the contact details of the person in charge for this issue.
The access to the database managed with computer facilities is allowed also to external entities, if it is necessary to guarantee the update and full functioning of the computer tools.
The processing requires tools and paper, computer and telematic supports in compliance with the dispositions aim at guaranteeing the security and confidentially, as well as the pertinence of data relative to the declared purposes in this policy.
Ecoterm does not resell to third parties or spread deliberately the personal data collected directly from the interested persons.
According to the above mentioned purposes, your data may be communicated to the following categories of subjects:
We will process your personal data only for the time required to fulfil the purposes these data were collected for, including legal, accounting and reporting needs. In order to determine the adequacy of the retention period of personal data, we consider the quantity, the nature and the sensibility of personal data and the potential damage that an unauthorized use or their spread could cause, the purposes we process your personal data for, also taking into consideration the possibility to achieve the same purpose by other means, and the applicable legal requirements.
By law we must save a certain amount of basic information of our customers (including contact details, Identity details, financial and transaction data) for 10 years from the termination of the relationship for tax purposes. In some cases we could make anonymous your personal data (so that they cannot be associated with you) for statistical and research reasons; in this case we could use these information for an unlimited period, without forward you further communication.
Ecoterm shall not transfer outside the EU your personal data.
In relation to the above mentioned processing and the existing data into the archives of the Commissioner, the rights of art. 15, 16, 17, 18, 20, 21 of the Regulation EU 2016/679 (the text is available on the website www.garanteprivacy.it) could be exercised through a written request to the referring persons indicated below this document.
Your personal data are protected by the rights as enshrined in the law of data protection.
These rights are:
If you wish to exercise the rights above mentioned, please contact us.
Generally, there are no forecast expenditures:
You will not be asked for payments to have access to your personal data (or to exercise our other rights). However, you could provide for the payment of a reasonable amount of money in case of unfounded, reiterated or excessive requests, In these cases we might refuse to fulfil these requests.
What Ecoterm could ask you:
We might ask you for specific information to confirm your identity and guarantee the right of access to your personal data (or the exercise of any other right). It is a security measure to prevent the diffusion of your personal data to not authorized people. We might also contact you for further information about possible reminders.
Timing for the answers:
We try to answer to any request admissible within one month. If your request is particularly difficult or if you submitted several requests, it might be necessary a longer period of time. In this case you will be informed and keep update.
To exercise all the above mentioned rights, you can contact the Controller of the processing as follows:
We have implemented appropriate security measures to prevent the loss, manipulation, alteration or divulgation of your personal data. Moreover, the access to your personal data is limited to employees, agents, suppliers and other third parties with only job purposes. Your personal data will be processed according to our instructions and the confidentiality obligation.
We have implemented some procedures to deal with any possible breach of the personal data, that will be notified to You and any other competent authority, if necessary.