In keeping with Legislative Decree no. 196 of June 30 2003 (Personal Data
Protection Code, hereinafter referred to as “Privacy Code”), Start Promotion S.r.l.
as Data Controller for processing your personal data herewith inform you that the
above mentioned Privacy Code provides for the protection of individuals and other
entities with regard to personal data processing and that this processing will be
inspired to principles of fairness, lawfulness, transparency and protection of your
privacy and rights.
Your personal data will be processed in accordance with the provisions of the above
mentioned law, as well as with the confidentiality obligations therein set
out.
Processing Purposes. Your data will be processed for purposes related to the fulfilment
of the following obligations, either legal or contractual:
• Fiscal and accounting obligations
• Post-sales support
• Management of legal disputes
• Client management
• Quality management
• Fulfilment of market surveys and/or statistics, as well as promotional activities
including mailing of advertising material, if applicable
• Business planning
• Customer satisfaction audit
• Invoice record management
The processing of data required to fulfil the above obligations is necessary
for a proper management of our business relation and the provision of such
data is mandatory to satisfy the purposes above. The Data Controller also inform
you that, in case any of the mandatory information are not provided or are provided
incorrectly, the Data Controller might be unable to guarantee the correct and adequate
processing of your personal data.
Processing Methods. Your personal data can be processed as follows:
• Possible charge of a third party for processing tasks
• Creation of customer, supplier or user profiles
• Data collection in a public or open to public place
• Data collection through information or telematic technologies
• Temporary processing for rapid data aggregation or anonymization
• Data processing through electronic calculators
• Data processing through paper records.
Data will be processed in accordance with the provisions of Sections 11, 31 and
subsequents of the Privacy Code and by adopting the minimum security
measures laid down in the technical specifications (Annex B).
Data Communication: Your data will be retained at our office and communicated only
to those subjects who are entitled to fulfil services necessary to a correct management
of our business relation, ensuring the full respect of the data subject’s rights.
Your data will be processed only by personnel expressely authorized by the Data
Controller and, in particular, by the following authorized subjects and entities:
• Administration Department
• General Manager
• Operational Department
Your data may be communicated to selected third parties including:
• Public and/or private entities to whom communication of personal data is mandatory
or necessary to fulfil legal obligations, or necessary to manage our business relation
• Couriers, carriers, Post Office, logistic companies
• Consultants, professionals and professional associations
• Banks
Data dissemination: Your data will not be disseminated in any way.
Data Controller: The Data Controller for data processing is Start Promotion S.r.l.
(via Mauro Macchi, 50, 20124, Milano (MI) ITALY; Ph. +39 02 67071383), in
the person of its pro tempore legal representative.
You have the right to obtain from the Data Controller the erasure, communication,
updating, rectification and integration of your personal data and, in general, you
are entitled to all the rights set out by Section 7 of the Privacy Code, hereafter
included .
Furthermore, any time you can access the updated version of the present policy by
connecting to: http://www.privacylab.it/informativa.php?07623196711
Legislative Decree no. 196/2003, Section 7 – Right to access personal data and
other rights
1. A data subject shall have the right to obtain confirmation as to whether or not
personal data concerning him exist, regardless of their being already recorded,
and communication of such data in intelligible form.
2. A data subject shall have the right to be informed
a) of the source of the 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 as per Section 5(2);
e) of the entities or categories of entity to whom or which the personal data may
be communicated and who or which may get to 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.
3. A data subject shall have the right to obtain
a) updating, rectification or, where interested therein, integration of data;
b) erasure, anonymization or blocking of data that have been processed unlawfully,
including data whose retention is unnecessary for the purposes for which they have
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.
4. A data subject shall have 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 for the performance
of market or commercial communication surveys.