Privacy Policy

INFORMATION ON THE PROCESSING OF PERSONAL DATA PURSUANT TO ART. 13 EU REGULATION 679/2016

(Rel.01 of 20/05/2018)

Posdata S.r.l., with registered office at via Nicolò Mineo, 10 – 90145 Palermo, VAT No.: IT 01647390812, as the data controller (hereinafter "Controller"), informs you, pursuant to art. 13 EU Regulation 679/2016 (hereinafter "GDPR"), that the data collected will be processed in the manner and for the purposes described below:

1. Subject of the processing

The Controller processes personal identification data, such as name, email, phone number, postal address, tax data, and data related to telematic traffic (hereinafter "Data") provided by you when purchasing or subscribing to services or, in general, the existing contractual relationship with the Controller.

2. Cookies and similar tools

In compliance with the EU Dir. 2009/136/EC of 25/11/2009, the Controller informs you that this site uses cookies or similar tools to improve our service and offer the user some useful functionalities. This may include cookies from business partners stored on your computer or device when visiting our site (www.posdata.it/cookie-policy). Please visit the websites of our business partners for information on their cookie and privacy policies.

Cookies are small text files transferred to your computer or device via the web browser to allow us to recognize your browser and help us monitor visitors to our site, thus enabling us to better understand the products and services most suitable for users. A cookie contains contact information and useful information to identify the computer or device when visiting our site to help the user obtain a better user experience. Most web browsers automatically accept cookies, but you can change these browser settings to accept, reject, and delete cookies if desired. If you choose to change these settings, some features and functionalities may not operate as intended. The cookies used do not detect information stored on the computer or device.

For more information about cookies and how to prevent the browser from accepting them, visit the following website: www.allaboutcookies.org.

3. Purpose and legal basis of the processing

The collected personal data are processed, without your prior consent (art. 6 letter b), c) GDPR), for the sole purposes of managing and executing pre-contractual and contractual relationships; administrative and accounting management; compliance with laws, regulations, or community legislation imposed by Authorities; for the protection of the Controller's rights in judicial proceedings and the management of any disputes; for the prevention and suppression of illegal acts.

3.1. Further processing purposes

The collected data, with your free and explicit consent (art. 6 letter a) GDPR), may also be used for the further purposes indicated below under the terms and conditions specified:

1. Marketing: to send you newsletters, promotional material, and commercial communications through both automated (e.g., email, SMS, MMS, App) and traditional (postal mail and non-pre-recorded calls) contact methods, including from our partners.
2. Profiling: for profiling purposes, that is, to analyze or predict, using algorithms and other automated systems, your potential habits, personal preferences, interests, economic situation, reliability, behavior, location, to offer you products and services increasingly suited to your real interests and needs and to develop offers and commercial communications.
3. Communication of data to third parties (e.g., commercial partner companies) that produce or market goods or services related to the requested services, entities that promote goods or services, or entities that process such data in anonymous form for statistical purposes, in compliance with laws and regulations.

4. Processing and Retention Methods

The processing will be carried out through the operations indicated in art. 4 GDPR and may occur via computer systems (cloud, internet, intranet, computers, and mobile devices) and automated processes, as well as in paper form (archives).

The collected data will be stored in the Controller’s databases for the time strictly necessary to achieve the purposes for which they were collected and processed, in compliance with the law and as specified above, except where the current legislation requires the retention of your data for longer periods. Specifically, for the purposes referred to in points 3.1.a) and 3.1.b), the data will be retained for twenty-four (24) months and subsequently deleted or anonymized.​

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If you decide to close your account, the Controller will retain the personal data provided only for administrative purposes for ten (10) years from the termination of the contractual relationship, except for further needs for which their further retention is granted and/or required by specific legal provisions.

5. Nature of data provision and consequences of refusal

Providing personal identification data is necessary for the execution of the contractual relationship and the obligations deriving from legal, regulatory, or community legislation, but refusal would make it impossible to provide the requested services or performances fully or partially.

It is understood that if you do not want to give your consent to the processing of your data for the purposes mentioned above, this will not prevent you from accessing the website and using the functionalities available, even related to your personal account.

6. Data access

The Data will be processed for the above purposes by employees and/or collaborators of the Controller in their capacity as data processing officers and/or internal data processing managers and/or system administrators. They will be processed by third parties (e.g., suppliers, professionals, banks, affiliates) if they carry out outsourcing activities on behalf of the Controller, in their capacity as external data processors.

7. Data communication

Without express consent (ex art. 6 letter b), c) GDPR), the Controller may disclose the collected Data to public bodies to comply with the obligations provided by laws, regulations, or community legislation imposed by Authorities, which will process them in their capacity as autonomous data controllers.

They may also be communicated to Third Parties (e.g., partners and client companies), who will process the data to carry out instrumental activities for the requested services and the purposes mentioned above.

In general, selected service providers operate through data centers located within the European Union. If your data is transferred outside the European Economic Area (EEA), even for the technical management of the collected data, this will only occur in full compliance with the GDPR, to companies adhering to the Privacy Shield (USA) or third countries with recognized specific adequacy guarantees by the European Commission, or appropriate personal data protection guarantees provided through agreements or contractual clauses (including binding corporate rules – BCR, and standard contractual clauses).

8. Rights of the data subject

At any time, you can exercise your rights towards the data controller, pursuant to arts. 15-22 of EU Regulation 2016/679, and in particular the rights of access, rectification, integration, and, where allowed, data portability, as well as obtaining the deletion, limitation, or opposition to the processing of the Data for legitimate reasons and objecting to automated decision-making, including profiling. Also, the right to lodge a complaint with the Supervisory Authority by contacting the Controller or the appointed DPO as follows:

1. By sending a registered letter with return receipt to the address of the Controller indicated above;
2. By sending an email to privacy@posdata.it to communicate with the appointed DPO.

To ensure the protection of the data subject's personal information, we may need to request additional specific information to confirm the identity of the requesting data subject and ensure their right to access the information (or exercise any of the other rights) only to those entitled to receive such communications. This is another appropriate security measure for the protection of personal data.​

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The request to access your personal information (or to exercise one of the rights mentioned above) is free of charge. However, if the request is clearly unfounded or excessive, we may charge a reasonable fee considering the administrative costs incurred to provide the information or refuse to comply with the request in such circumstances.

9. Data Controller and Data Protection Officer (DPO)

The data controller is: Posdata S.r.l., via Nicolò Mineo, 10 – 90145 Palermo – www.posdata.it. The appointed Data Protection Officer (DPO) can be contacted at the following address: privacy@posdata.it