Privacy Policy

In accordance with that set forth in articles 13 and 14 of the European Regulation 2016/679 regarding Privacy, in order to ensure that processing your personal data is done in a lawful, correct and transparent way (articles 5 and 6 of EU Regulation 2016/679), we inform you that any personal data provided by you will be processed for the specific marketing purposes indicated.
The data in question is necessarily processed to achieve the aims referred to in this advisory note.

1. PURPOSES FOR PROCESSING PERSONAL DATA
Data provided will be processed:
A. in order to (subject to your express, written consent) carry out direct marketing activities including via email, SMS and MMS, by sending advertising and sales materials containing informational and or promotional messages regarding the products and services supplied and/or promoted by T.A.M.A. AERNOVA S.P.A., or its business partners, or in order to carry out market research and/or interviews to assess the products/services offered. Processing data is optional and possible only with the data subject’s consent, which may be freely withdrawn.
B. in order to fulfil any obligation set forth by law, regulation, or EU legislation, as well as:
­- to fulfil any obligations deriving from an already established relationship, or to respond to any specific requests;
­- to fulfil any obligations inherent to and as a consequence of carrying out the administrative, commercial, accounting and tax activities regarding the existing relationship;
­- to manage any disputes (for example, contractual non-fulfilment, injunctions, etc.);
­- to perform internal audit services (for example, security, quality of services/products, etc.);
­- to assert or to defend a right in the appropriate offices (for these purposes, consent is not requested since the processing in question may be done without the data subject’s consent pursuant to article 6 of EU Regulation 2016/679).

2. NATURE OF PROVIDING PERSONAL DATA
Providing data for the purposes referred to in point 1(A) of this advisory note is optional and if data is not provided, there are no consequences whatsoever beyond not being subject to the activities referred to in the same point.
Providing data for the purposes referred to in point 1(B) of this advisory note is necessary and if data is not provided, it will make it impossible to fulfil the activities referred to in this advisory note.

3. LEGAL BASIS FOR PROCESSING PERSONAL DATA AND THE LEGITIMATE INTERESTS IN PROCESSING
The legal basis for sending commercial communications and newsletters is your express consent to receive the same.

4. METHODS OF PROCESSING PERSONAL DATA

The data will be processed manually, on paper, by computer and/or by telematic means (therefore the data will be stored and processed both in paper format and computer format). Specific security measures are taken to prevent any loss of any data, any illicit or improper use of the data and any unauthorised access to the data. The data referred to above will be stored and processed in full respect of confidentiality issues in accordance with all applicable legislation on the subject of safeguarding the data subject’s rights and fundamental freedoms and, therefore, also in respect of the principles of lawfulness, correctness and transparency (pursuant to articles 5 and 6 of EU Regulation 2016/679), and with logic strictly correlated to the purposes indicated in this advisory note. Data will only be subjected to those operations absolutely necessary to achieve the purposes indicated in this advisory note. Data will be stored at the offices of T.A.M.A. AERNOVA S.P.A., and/or at the offices of the appointed Processor(s) (as well as at the offices of third parties to whom the data may be communicated and which operate as autonomous Controllers) and will be kept in archives including computerised databases.

5. DATA STORAGE

Data collected will be stored for a period of time necessary to provide the service and, in any case, for a period no longer than that needed to fulfil the purposes for which the data was collected and processed (generally for no longer than 24 months from the end of the relationship or, for potential customers, from the moment the data is provided and consent is expressed; - the “principle of storage limitation”, article 5 of the GDPR), and/or on the basis of the deadlines set forth by applicable legislation and/or on the basis of specific requests, including the detection of and protection against fraud or other illegal activities.

6. RECIPIENTS AND CATEGORIES OF RECIPIENTS OF PERSONAL DATA
Data may be communicated, for the purposes referred to in point 1 of this advisory note, to:
- service providers: we make use of service companies to manage your data, which is needed to fulfil the aims described in this advisory note such as, for example, to manage booking payments and to send marketing material for analytical support purposes. These service providers are held to comply with confidentiality agreements and are not authorised to use your data for any other purpose; 
- professionals and consultants, consultancy firms, factoring companies, credit institutes, debt collection companies, credit insurance companies, business information companies, companies operating in the transportation sector;
­- services to manage information systems and telecommunication networks;
­- parties responsible for controls, audits and certifying the Company’s activities, including in the interests of customers;
­- as well as to public entities, legal bodies and police organisations, i.e. parties who have the right to access data, as provided for by legal provisions or under the orders of a recognised authority;
­- all parties assigned by the Company, who will be held to process just the data necessary to carry out the tasks assigned to them by the Company, performing just those operations which are essential to performing the tasks themselves.

The Company will communicate just that data which is essential to achieving the individual purposes indicated in this advisory note. Data collected and processed will not be subject to dissemination, unless otherwise required by law.

7. TRANSFERRING PERSONAL DATA
Personal data is stored on servers located within the European Union. It remains understood, however, that the Controller, should it ever become necessary, has the right to move these servers, even outside of the EU. In this case, the Controller hereby states that any transfer of data outside of the EU will be done in full compliance with all applicable legislation subject to the stipulation of the standard contractual clauses as provided for by the European Commission or the data subject’s prior consent.

8. AUTOMATED DECISION-MAKING PROCESSES
The Controller does not use processing that consists of automated decision-making processes.

9. THE CONTROLLER
The Controller is:
T.A.M.A. AERNOVA S.P.A., with registered offices in Via Dell'industria, 11 - Mollaro - Predaia (TN), Italy.
Telephone: +39 0463/461700 Fax: +39 0463/461799; 0463/461798

10. THE DATA SUBJECT’S RIGHTS

Pursuant to articles 15, 16, 17, 18, 19, 20, 21, and 77 of the EU Regulation, the data subject is hereby informed that he/she:
- has the right to obtain from the Controller access to the personal data that concerns him/her, the rectification and deletion of this data and the right to restrict or to object to the processing of the same, to transfer this data to another Controller in the cases provided for;
- has the right to expect that any rectification or restriction made on the processing, upon request by the data subject – unless this proves impossible or involves a disproportional effort – will be communicated by the Company to each Processor to whom the data subject’s personal data has been communicated;
- has the right to lodge a complaint with the Supervisory Authority for the protection of personal data by following the procedures and instructions published on the Authority’s official website, www.garanteprivacy.it.

Exercising these rights is not subject to any form of constraint and is free.

This Privacy Policy was updated on 29/08/2018.

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