INFORMATION ON THE PROCESSING OF CUSTOMERS’ PERSONAL DATA

 

UNOX S.p.A. (“UNOX”) recognises the importance of protecting personal data and is committed to ensuring that the data of its customers, both individuals and contact persons where the customer is a corporate body (“Concerned Parties”), is processed in compliance with EU Regulation 679/2016 (“GDPR”) and any other applicable legislation on the protection of personal data.

 

  1. 1. Data controller of the processing of personal data

UNOX S.p.A., with registered office in Via Majorana 22, 35010 Cadoneghe, PD is the data controller.

Tel.: +39 049 8657 511, Fax: +39 049 8657 555, info@unox.com.

 

  1. 2. Types of personal data

UNOX may process the following personal data of the Concerned Parties: personal details, address, contacts, email address, Italian tax ID code, bank details, IBAN, professional qualification.

 

  1. 3. Purpose and legal basis of the processing

UNOX can process personal data of the Concerned Parties, either manually or via electronic means, for the following purposes and under the following conditions:

a)        to fulfil legal obligations and respond to requests from the relevant authorities (article. 6, para. 1, point c GDPR);

b)        for the execution for the contractual relationship between UNOX and the individual customer, including customer care and the relevant administrative and accounting obligations (in which case the personal data of the Concerned Parties will be processed for the execution of a contract which they are party to, art. 6, para. 1, point b GDPR);

c)        for the execution for the contractual relationship between UNOX and the corporate client, including customer care and the relevant administrative and accounting obligations (in which case the personal data of the Concerned Parties will be processed in order for UNOX to pursue its legitimate interest in the performance of the contractual relationship, art. 6, para. 1, point f GDPR);

d)        to protect the rights of UNOX both in and out of the context of legal proceedings (in which case the personal data of the Concerned Parties will be processed in order for UNOX to pursue its legitimate interest in protecting its rights, art. 6, para. 1, point f GDPR);

e)        to carry out exceptional transactions concerning the data controller (including mergers, acquisitions and corporate restructuring), within the limits strictly necessary for the pursuit of the aim in question and on the basis of UNOX’s legitimate interest, following suitable balancing with the fundamental rights and freedoms of the Concerned Parties (in which case the personal data of the Concerned Parties will be processed in order for UNOX to pursue its legitimate interest, art. 6, para. 1, point f GDPR);

f)         to send commercial information, newsletters, updates or relevant event invitations to individual customers (in which case the personal data of the Concerned Parties will be processed in accordance with the express consent given for that specific purpose, art. 6, para. 1, point a GDPR);

g)        to send commercial information, newsletters, updates or relevant event invitations to contact persons of corporate clients (in which case the personal data of the Concerned Parties will be processed in order for UNOX to pursue its legitimate interest in proposing marketing initiatives to the corporate client, art. 6, para. 1, point f GDPR).

 

The email addresses of the Concerned Parties, provided in the context of the sale of a product or service, may also be used for the direct sale of products or services similar to those of the sale if the Concerned Parties have not refused the processing of their data; UNOX informs the Concerned Parties that they may refuse the processing of their data at any time, easily and free of charge, as detailed below.

 

  1. 4. The mandatory or optional nature of the provision of data and consequences in case of non-communication

The processing of the data of the Concerned Parties is necessary for the purposes detailed in point 3, above.

If the data is not provided for the purposes detailed in points a), b), c), d) and e) of point 3 above, it may not be possible to enter into or to continue the contractual relationship with the party in question or the company they belong to (in any case, the Concerned Parties may object at any time to the processing of the data that concerns them for the pursuit of the legitimate interests of the data controller, as detailed below, unless the data controller can prove the existence of legitimate and mandatory reasons to process said data that take precedence over the interests, rights and freedoms of the concerned party or in order to establish, exercise or defend a right in the context of legal proceedings).

In the case of the data not being provided for the purposes indicated in points f) and g) of point 3 above, there will be no adverse consequences for the contractual relationship but it will not be possible to receive marketing communications from UNOX (in any case, the Concerned Parties may revoke their consent or object to the processing at any time, as detailed below)

 

  1. 5. Retention period of personal data

The personal data of the Concerned Parties which is processed for the purposes detailed in points a), b), c), d) and e) of point 3 above will only be retained for the period strictly necessary for the purposes indicated and, in any case, for no longer than ten years from the conclusion of the contractual relationship with the customer or the company they belong to, after which it will be deleted or anonymised.

The personal data of the Concerned Parties which is processed for the purpose detailed in points f) and g) of point 3 above will only be retained for the period strictly necessary for the purposes indicated and, in any case, for no longer than ten years, after which it will be deleted or anonymised.

The exception to this is for any requirements related to pending or threatened legal proceedings.

 

  1. 6. Possible recipients or categories of recipients of the personal data and its transferral to countries outside the European Economic Area

The personal data of the Concerned Parties will be processed by authorised internal staff.

It may also be disclosed to external data processors or controllers, such as experts, consultants and lawyers, dealers, IT service providers, other companies in the group, companies involved in possible mergers, divisions or other extraordinary operations, as well as the relevant authorities, where permitted by the applicable laws. The complete and up-to-date list of these parties is available at the headquarters of the data controller and a copy may be requested at any time.

 

The data of the Concerned Parties will not be disclosed, unless this is necessary to comply with legal obligations, regulations and/or to implement obligations arising from the contractual relationship.

The data of the Concerned Parties may be transferred to countries outside the European Economic Area; in this case, UNOX will verify that the country of destination is considered adequate, that the recipient is Privacy Shield-certified or that they have group rules approved by the relevant authorities or will enter into special agreements, using the standard contractual clauses approved by the European Commission.

A copy of the appropriate or suitable safeguards is available at the headquarters of the data controller and may be requested at any time.

 

  1. 7. The rights of the Concerned Parties

The Concerned Parties have, and may exercise at any time, the right to:

 

a)        Access their personal data;

b)        Correct or delete it;

c)        Limit the processing of said data;

d)        Object to the processing of said data;

e)        Object to the processing of their personal data for the pursuit of the legitimate interests of the data controller (in which case the data controller will refrain from any further processing of the data, unless they can prove the existence of legitimate and mandatory reasons to process said data that take precedence over the interests, rights and freedoms of the concerned party or in order to establish, exercise or defend a right in the context of legal proceedings);

f)         Object, at any time, to the processing of personal data concerning them carried out for direct marketing purposes;

g)        Object, at any time and free of charge, to the processing of their personal data for the offering of similar products and services;

h)        Data portability;

i)         Withdraw their consent at any time, without prejudice to the lawfulness of the processing based on the consent given before their withdrawal.

In order to exercise these rights, the Concerned Parties can contact UNOX at the following email address: privacy@unox.it.

The Concerned Parties also have the right to lodge a complaint with the Personal Data Protection Authority.

 

  1. 8. Update to the information on the processing of customers’ personal data

This policy may be changed or updated in the future. This version is dated October 2018.

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