PRIVACY POLICY

ACCORDING TO ITALIAN REGULATION n°196/2003 AND EU REGULATION n°679/2016

 

According to the rule 13 of the Italian Regulation n°196/2003 and then the entering in force of the EU Regulation n°679/2016 and in conformity to this last Regulation, we would like to inform our customers about the following statements.

 

Purpose of processing personal information

Your personal data lawfully acquired according to business purposes and activities enrolled by F.C.S. Srl hereafter called “firm” to simplify the statement, are processed for the following business reasons:

 

a) Release of a fidelity card needed to get commercial benefits throughout company’s branches;

 

b) Simplify any reclaim or controversy;

 

c) Prevent/Repress any kind of fraud or any other illegal activity;

 

d) Communicate activities related to existing business contracts;

 

Your personal data will be also processed for the purposes stated in the current Italian normative regarding money laundering (Regulation number 231/2007 and following modifications).

 

Data processed might be of different kind. Anyway, they are collected and then processed, according to the causes specified above.

Concerning this statement, we remind you for personal data we mean every personal data that could reveal ethnic and racial origins, philosophical, religious and other kinds of beliefs, political opinions, subscription to political, religious organisations as well as any other personal data revealing sex appeals or health conditions. For legal data we mean instead “Personal data revealing legal measures according to Clause 3 par. 1 from letter a to letter o and from letter r to letter u of the Regulation n°313/2002.Then, legal office records, administrative penalties subjected to crime and to any other legal dispositions, as well as kind and degree of persecution according to Clause 60 and 61of the penal code. Any other reasons might be related to marketing, administrative and commercial activities, without your expressed consent according to Rule 24 lett. a, b, c of the Privacy code and Clause 6 lett. b and e of the GDPR. For the following reasons it will not be possible to:

 

a) Conclude business contracts regarding firm’s services;

 

b) Fulfil to prescribed legal dispositions related to existing business contracts;

 

c) Fulfil to required legal dispositions prescribed from Italian Authorities (e.g. money laundering);

 

d) Exercise Firm rights like defence right in case of litigation;

 

Only under your clear consensus (Rule 23 and 130 of Privacy Code and Rule 7 of GDPR) we can proceed for the following marketing reasons:

 

a) Send emails, letters, SMS, newsletter concerning products and services offerings as well as promotions or other services offered by the company compared to satisfaction degree regarding quality services;

 

a) b) Send emails, letters, SMS,newsletter regarding our products and services as well as promotions or other services always related to the firm responsible for data processing and other companies having partnership contracts with such a firm to offer services signed in the contract.

 

We are glad to inform that if you are already part of our customer portfolio, we might send you communications linked to our services and products comparable to the ones you already used, except in case of dissent (Rule 130 – Privacy code)

 

Processing mode

Data processing will be assessed assuring confidentiality and security needed according to the following modalities:

 

a) Personal data subject collection;

 

b) Processed for lawful purposes for extended data processing operations with the possible use of technological tools among the person involved;

 

Personal data processing is entirely realised through the activities listed in the Rule n° 4 of the Privacy Code and in the Clause 4 par. 2 GDPR). More precisely is indicated: collection, registration, organisation, preservation, editing, erase and data destruction. Your personal data will be stored in hard copies, in electronical devices. The firm will process all the personal data for the time needed to fulfil contracts clauses anyhow, not more than 10 years since contract’s due date for financial obligations and not more than 2 years for marketing activities.

 

Legal foundation

Legal foundation of personal data processing is regulated on business needs, regarding services requested in the signed contract.

 

Lawful interests prosecuted by the controller

Lawful interests prosecuted by the controller during data processing are applied under the rigorous laws’ framework as a part of the contract signed between the firm and the customer. According to Rule n° 6 permission to process personal data, is based entirely on the consensus expressed by the customer/person involved in a written statement.

 

Elective or obliged data provision and consequences of denied consensus

In this case, data provision is mandatory in order to allow the controller to enrol services required and listed in the signed contract. In case of denied consensus, the controller will not be able to pursue the statements listed in such document.

 

Data communication to third parties

The controller will process your personal data as well as any other person nominated under previous authorization.

Italian Authorities might process your personal data only in case of particular circumstances regarding legal obligations.

We also inform you that your data might be processed by other entities that are entertaining business relationship with F.C.S. Srl, like suppliers, accountants, labour consultants with the aim to fulfil contract clauses. Therefore, every activities is entirely performed under law’s dispositions.

 

Your personal data are not diffuses in any case and for any purpose.

 

Data conservation length

Your personal data will be stored for 2(two) years since the end or the interruption of the signed contract.

 

Automated decision-making process

 It is not part of our technologies

 

Data transfer outside the EU

The controller will not transfer any of your personal data outside EU and to a third country

 

Profiling

The controller will not perform any profiling activity on your personal data

 

Controller and Responsible of personal data processing

F.C.S. Srl, Viale America, 125 – 00144 Rome (RM) Italy, under the person, its CEO Mr. Acc. Ivo Lenci. Certified mail: f.c.s.srl@legalmail.it

 

Rights of the data subject

Data subject can exercise in any circumstance his rights according to what is prescribed in the Rule 17 of the Italian Regulation 196/2003 and Rule 15 of the EU Regulation n°679/2016. Right to personal data access. The data subject owns the right to know if there are any personal data concerning him, even if they are not registered yet as well as the notification of such situation. Data subject has also the right to know the source, the processing method purpose and reasons of the personal data process if treated with electronical devices; the name of the controller, the name of the DPO nominated under the normative n°5 section 2; details and category of people, members of the Italian Government that can acquire these personal data.

Data subject owns the right to pursue any action towards his personal data processing, including also the transformation to unidentified data as well as the block of processed data without previous authorization. Furthermore, the subject has the right to stop data processing even in case of marketing and commercial purposes. The Data subject in any circumstance owns the right to obtain personal data erase, act against data processing as well as the right to revoke the consensus without compromising the authorization given before the revocation, having also the right to involve competent authorities.

 

Data subject rights exercise

You can exercise your rights in any moment sending:

A registered mail addressed to F.C.S. Srl Viale America, 125 – 00144 Rome (RM) Italy

A certified mail at the following address: f.c.s.srl@legalmail.it