In accordance with Art. 12 of the REGULATION (EU) 679/2016 – Transparent Information, Communication and Modalities for the exercise of the rights of the data subject – Information pursuant to articles 13-14 of the REGULATION (EU) 679/2016.
In accordance with Regulation (EU) 2016/679 on “General Data Protection Regulation” (hereinafter “Regulation EU/679/2016”), Sound Public relations (hereinafter “the Company”), as Data Holder, is required to provide notice on use of the personal data of its customers.
This notice also refers to processing carried out by subjects which perform services of a technical and organisational nature, described in paragraph 1, on behalf of our Company.
- Purposes of processing and methods. Nature of providing data.
The personal data in possession of our Company are supplied directly by the persons the personal data refer to (“Data Subject”). Our Company can also obtain personal data while carrying on its business or from third parties.
Personal data are processed during normal activities of the Company for the following purposes:
a) purposes strictly connected with and instrumental to handling relations with the Data Subject.
Providing personal data necessary for such purposes is not obligatory, but refusing to provide them can make it impossible for our Company to perform the service due to the relationship between the data and the requested service. The Data Subject’s consent is not required for processing them;
b) fulfillment of obligations imposed by law, regulations or community provisions
Providing personal data necessary for such purposes is obligatory and the data subject’s consent is not required for processing;
c) other purposes functional to the activities of the Company such as:
- surveying the degree of customer satisfaction with the quality of services rendered and the job done by the Company, at times carried out through specialised businesses, by means of interviews in person or over the phone, questionnaires, etc.;
Providing data necessary for the purposes referred to in letter c) is not obligatory and the data subject’s consent is required for processing.
In relation to the purposes described, personal data shall also be processed by using manual or electronic or automated instruments, with logics strictly connected to the above purposes and in a manner guaranteeing the privacy and security of the personal data.
For some services, the Company uses trustworthy companies which, as Data Processing Officers, perform tasks of a technical and organisational nature such as: the performance of printing, envelop stuffing, transmission, transport and message sorting services; the performance of IT services related to supply, development and maintenance of software and hardware systems which are necessary or functional to carrying out the services provided by our company, survey of the degree of customer satisfaction and requirements; accounting processing, accounting audit and financial statement certification; sending marketing emails; etc.
- Categories of data transferred.
In relation to the purposes described in paragraph 1 above, our Company and other subjects that carry out the tasks described in paragraph 1 on our behalf process personal data related to: first name, last name, address and other personal identifying elements; tax ID; e-mail; phone number; bank account details (e.g. IBAN); data related to family and personal situations; data related to level of education and the occupation of the Data Subject as well as the personal data of the legal representative or proxy of businesses.
For supplying the services and tasks specified in this notice, our Company does not need to process personal data Art. 9 of the above Regulation defines as “sensitive” (such as personal data likely to reveal state of health, political and trade union opinions, religious beliefs, etc.).
- Categories of subjects whom personal data may be disclosed to or who may learn them in their capacity as processing officers or delegates.
For pursuing the aims described in paragraph 1, our Company needs to disclose the personal data of Data Subjects to third parties belonging to the following categories:
- subjects which perform tasks of a technical and organisational nature, specified in paragraph 1, on behalf of our Company, the firm providing accounting services included;
- Supervisory Authorities and Organs, Judicial Authorities and in general public and private subjects with important publicistic functions;
- external companies and/or professionals our Company uses for assistance and consulting services;
- third party companies for processing intended for promotional actions, when the Data Subject has given his or her consent.
Addressees of the messages described in this notice work independently as distinct data holders or in some cases are designated by our Company as data processing officers. Their list is constantly updated and is available at our Company.
Some categories of persons, designated as data processing delegates, can gain access to the personal data of customers while carrying out their duties. Our Company has designated our employees, system administrators included, as data processing delegates of customer data for carrying out their duties, temporary workers used by our Company and interns.
Subjects designated by our Company as Data Processing Officers can also know the personal data while carrying out the tasks given to them. You can find out the identities of the data processing officers designated by our Company in the manners specified in paragraph 5.
The personal data processed by our Company and by subjects which perform tasks of a technical and organisational nature, described in paragraph 1, on behalf of our Company will not be diffused.
- Storage deadlines for personal data.
Personal data will be processed for the duration of established contractual relationships and thereafter for fulfillment of all legal obligations for a time not exceeding 10 years from termination of the contractual relationship or longer in cases specifically required by law. In case of processing for promotional purposes, up until the data subject makes a request not to receive commercial messages, and when the latter wants to stop receiving them.
- Rights of the Data Subject set out in Articles 15 et seq. of Regulation (EU) 2016/679.
You should know that the data protection regulation gives Data Subjects the possibility to exercise certain rights. In particular, each data subject has:
- the right to access i.e. the possibility of gaining access to his or her personal information, specifically provided by Art. 15 of Regulation 679/2016;
- the right to correct, i.e. the possibility of obtaining update of inaccurate personal data without unjustified delay, specifically provided by Art. 16 of Regulation 679/2016;
- the right to oblivion consisting of the right of the data subject to ask for deletion of his or her personal data, specifically provided by Art. 17 of Regulation 679/2016;
- the right to restrict processing when one of the conditions provided by Art. 18 of the above Regulation are met;
- the right to portability of data, i.e. the right of the data subject to obtain his or her data in an interoperable format and/or the right to have the data sent to another data holder without impediments by this Company, specifically provided by Art. 20 of the above Regulation;
- the right to withdraw consent at any time, specifically provided by Art. 7 of Regulation 679/2016;
- the right to file a complaint to the Data Protection Authority in case of a violation in the way the data were processed pursuant to Art. 77 of Regulation 679/2016;
- the right to file an appeal in the concerned jurisdiction in case of unlawful data processing, even against acts assumed by the Data Protection Authority in accordance with Art.78 of Regulation 679/2016;
- the right at all times to oppose processing for sending commercial and direct sales messages and advertising material by sending an email to the address below firstname.lastname@example.org, asking for deletion of your name from the advertising list.
- Data Holder and Processing Officer.
The Data Holder of your personal data referred to in this notice is Name of Company, with head office at Via Antonio Stradivari, 7 Milan – Italy – Phone: +39 02 2056951.
Requests for exercising the rights provided in Art. 7 of the Act can be forwarded in writing by electronic mail message to this address email@example.com to the attention of the Data Holder.
Requests concerning the identity of the other Data Processing Officers designated by the Name of Company and requests referred to in paragraph 5 may be made orally. You can also ask for a complete list of Data Processing Officers appointed by our Company by sending an electronic mail message to the address firstname.lastname@example.org