Information notice pursuant to Art. 13 of the Regulation (EU) 2016/679 (“GDPR”)
Information when personal data are collected from the data subject
1. DATA CONTROLLER, pursuant to art. 4 and 24 of the Reg. (EU) 2016/679, is Poltrona Frau Spa – registered office Via L. Busnelli 1 Meda (MB), representend by the legal representative pro tempore.
The company has appointed the Data Protection Officer (DPO) pursuant to art.37-39 of the Reg. UE 2016/679 whose contact is: email@example.com
2. PURPOSES AND LAWFULNESS OF THE PROCESSING
The Personal data shall be processed in accordance to the requirements for the lawfulness of processing set forth by Art. 6 of the Regulation (EU) 2016/679 for the following purposes:
A) visit the website – art.6.1.f) as legal basis of the processing.
- request for information forwarded – art.6.1.f) as legal basis of the processing.
- subscription to “Architetti e Designer” and “Dealers” area to make use of the services and for administrative-accounting purposes connected – art.6.b) and f) as legal basis of the processing.
B) –(consent) subscription to the newsletter of Poltrona Frau Spa, for promotional communication by e-mail (mailing list service) and for related activities – art.6.1.a) as legal basis for the processing.
C) – (consent) direct marketing set by Poltrona Frau Spa promotional communication and/or invitation to events promoted or organized by the Data Controller, by e-mail, SMS, MMS, phone call also without operator, mail, or other communication tool – art.6.1.a) as legal basis for the processing.
D) – (consent) communication of your Personal Data to the companies of Poltrona Frau’s Group (Cap Desing Spa and Cassina Spa) for promotional, marketing and commercial communication porpuses, for sending informative and promotional material by e-mail, mail, SMS, MMS and phone call also without the operator, and connected to the Group’s brand “Cassina” and “Cappellini”- art.6.1.a) as legal basis for the processing.
E) – (consent) for profiling purposes, for letting Poltrona Frau Spa to process user profiles, consumers and / or analyze consumption habits and choices to improve the commercial offer, services, products offered, to make them more compliant with the interests of those concerned – art.6. 1. a) as legal basis for the processing.
3. RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA
Personal data provided by you may be communicated to recipients, which shall process your data as Processors (art. 28 of the Reg. EU 2016/679) and/or persons acting under the authority of the Controller and the Processor (art.29 of the Reg. UE 2016/679) for the purposes pointed in point 2 ahead. Precisely, your data may be communicated to recipients part of the following categories: -Group company for administrative-accounting purposes or for process your request; internal staff of the Data Controller; - subjects providing services for the management of the information system and communication networks (including e-mail and web sites); - studies or companies in the context of assistance and consultancy relationships; - Competent authorities for compliance with legal obligations and / or provisions of public bodies, upon request; - The subjects belonging to the aforesaid categories act as data Processors or act in complete autonomy as separate data Controllers.
4. DATA TRANSFER TO A THIRD COUNTRY AND/OR INTERNATIONAL ORGANISATION
Personal data may be transferred within or outside the European Union, in favour of companies part of the Group for administrative-accounting purposes or for process your request. Personal data may be transferred outside the European Union and the transfer will be made by Data Controller to the limits and conditions set forth by art. 44 and subsequent articles of the Regulation EU 2016/679 “General Principle for transfers”.
5. DATA RETENTION PERIOD OR RELEVANT CRITERIA
The processing shall be carried out in automated and / or manual manner, with methods and tools aimed at ensuring the best security and confidentiality, by persons specifically appointed to do so.
According to the provisions set forth in art. 5 par. 1 lett. e) of the Regulation EU 2016/679, collected personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. Personal Data will be retained:
- to visit the current internet website (temporary);
- request for contact - 1 year;
- subscription to the internet platform – until unsubscription;
- subscription to the newsletter – until unsubscription and withdrawal of consent (opt-out);
- profiling -5 years or until opposition;
- marketing (24 months) – in case of withdrawal of consent the cancellation will be immediate.
6. NATURE OF UNDERWRITING AND REFUSAL
Below, for each purposes of the processing of the Personal Data are listed the nature of underwriting.
The provision of data is necessary to navigate on this website.
The provision of personal data for purpose A is necessary to register to the site and enter in the personal area; the non submittal of personal data may the result the impossibility to refine the registration and have access the personal area.
The provision of personal data and the consent to the processing for purpose B – for the subscription to the newsletter - is optional and the non submittal of personal data will not prevent you from registering to the private area “Architect e Designers” and “Dealers”, but your Personal Data will not processing for the subscription to the newsletter and you will not be subscribed to the mailing list of Poltrona Frau Spa.
The provision of personal data and consent to the processing for purpose C -for the direct marketing from Poltrona Frau Spa – is optional. The non-submittal of personal data will not prevent you from registering to the personal area (purpose A) but your personal data will not be processing for direct marketing.
The provision of personal data and consent to the processing for purpose D – assigned of your Personal Data to the other companies of the Group Poltrona Frau for promotional/marketing purposes- is optional. The non submittal of personal data will not prevent you from registering to the personal area (purpose A) but your personal data will not be assigned to the other companies of the Group Poltrona Frau for marketing activities.
The provision of personal data and consent to the processing for purpose E – for the profiling- is optional. The non submittal of personal data will not prevent you from registering to the personal area (purpose A) but your Personal Data will not processing for profiling purpose.
7. DATA SUBJECT’S RIGHTS
You may exercise your rights as indicated in the Regulation EU 2016/679, by contacting the data Controller, sending an e-mail to firstname.lastname@example.org contacting the Data Protection Officer by sending an e-mail to email@example.com In particular, you have the right to: obtain confirmation that a treatment is underway and if so, to request the data Controller to access of this Data and obtain other information like: kind of Personal Data; recipients or categories of recipients of personal data; data retention period or relevant criteria; the right to ask to rectification, cancellation of your personal data or the limitation of the processing of them; the right to object the processing of your data; the right to lodge a complaint with the Data Protection Authority; if the Personal Data has not been collected by the Data Subject, all the information concerning the origin; the existence of authomated decision-making (profiling also art.22 GDPR); appropriate safeguards in case of data transfer to a third country or international organization art 44 and subsequent of GDPR; the right to obtain a copy of your Personal Data.
Upgrade date: 26th June 2018