Privacy policy updating

Data: 24 May 2018

We inform You that, because of instauration and execution of contractual agreements in progress with You, or organization holds Your data, which have been acquired also verbally, directly or by means of thirds, qualifided as personal data from “General Data Protection Regulation 2016/679” from (GDPR).

In accordance with the regulations indicated above, this treatment will follow the principles of fairness, lawfulness, transparency and protection of Your privacy and Your rights.

Hence, under article 13 of GDPR 2016/679, we give You the following information:

Nature of treated data: We treat your personal, tax and economic data necessary to the progress of contractual agreements, outstanding or future, with your company, as well as in order to achieve an efficient management of commercial dealing. 

Your data are treated without Your permission (art. 24 lett, a, b, c Privacy Code and art. 6 lett. b and GDPR), only for the following Service Finalities: to fulfill pre-contractual, contractual and fiscal duties deriving from outstanding relationships with You; to fulfill duties which are expected either from the law, from a set of rules, from community legislation or from an order from Authority; to exert the rights of the Holder, such that the right of defense in court.

We don’t own Your data which are eligible as particular or of judicial nature (arts. 9 and 10 of GDPR).

Finality and duration of the treatment: Your data will be treated for all the duration of the contractual agreement and also afterwards, in order to fulfill contractual needs and related fulfillments of legal and fiscal duties and, moreover, to manage finantial and commercial dealings efficiently; these operations are indicated in art. 4 Privacy Code and in art. 4 n. 2) GDPR.

The Holder will treat Your personal data for an amount of time which will be necessary to fulfill the finalities mentioned above and, however, for no longer than 10 years since the cessation of the dealing for Service Finalities.

Modality of the treatment: The treatment will be done either with manual and/or informatic and telematic instruments with organization and processing methods highly correlated with the finalities themselves and, however, in order to guarantee security, integrity and confidentiality of the data, respecting organizative, physical and logical measures, which are expected by current provisions.

Duty or capability to confer data: as regards the data we are forced to know, in order to fulfill duties expected by the law, your missed treatment of these data leads to the impossibility to establish or to continue with our relationship, if they are necessary for the fulfillment of the contract.

Knowledge scope of Your data: the following categories of prones are allowed to know Your data, as responsibles or delegates of the treatment, nominated by the company which is holder of the treatment: managers and mayors; internal secretary offices; contability and billing employees; commercialization of services employees; agents and representatives.

Communication and diffusion: Your data won’t be spread by us to undetermined subjects making them know or consult Your data.

We could communicate Your data, regarding their specific competence, to entities and, in general, to every pubblic and private prone in case we have an obbligation (or an acknowledged capability either from laws or from minor or community set of rules) or necessities to communicate, as well as to our consultants, respecting the necessary limits to let them perform their task by our organization, prior our engagement letter which imposes the duty to privacy and security.

Your rights: In Your virtue of interested, having rights reported in art. 7 Privacy Code and art. 15 GDPR and, precisely, the rights of: i. obtaining confirm about the existence (or, either, inexistence) of presonal data regarding You, even though they aren’t still registred, and their communication in intellegible form; ii. obtaining indication: a) about the origin of personal data; b) about finalities and modalities of the treatment; c)about the logics applied in case of the treatment was done with electronic instruments; d) about the idendity of the holder, of responisbles and of the appointed agent (as regards art. 5, comma 2 Privacy Code and art. 3, comma 1, GDPR); e) about prones to whom personal data can be communicated or who can become aware of them as  appointed representatives in the State territory, as responsibles or as charged; iii. obtaining: a) updating, rectification, that is to say integration of data; b) deletion, transformation in anonymous form or the block of data which are treated violating the law, including whose conservation regarding the goals for which the data have been collected or successively treated is not necessary; c) acknowldegement that operations at points a) and b) have become known, also with respect to their content, to the ones for which data have been communicated and spread out, except the case in which this fulfillment becomes impossible or deals with an use of means hugely incommensurate with respect to the protected right; iv. opposition, which can be total or partial: a) for reasons that are justified for the treatment of personal data regarding Yourself in order to send advertising materials or to sell directly or to do marketing researches or commercial communication, by the use of automated systems of call without the intervention of an operator through email and/or through traditional marketing modalities through telephone and/or paper mail.

Where appliable, you’ll have the rights related to arts. 16-21 GDPR (right of rectification, right of oblivion, right of putting limitation in the treatment, right of portability of data, right of opposition), as well as the right of complaint to the Guarantot Authority. In every moment You will be able to obtain confirmation about the existence (or inexistence) of personal data regarding You and about the communication of the data and the finalities on which the treatment is based. Moreover, you’ll be able to obtain the cancellation, the trasformation in anonymous form or the block of data which have been treated violating the law, as well as the updating, the rectification or, in case You have an interest about it, the integration of data. You’ll be able to oppose to the treatment itself, for rightful reasons.

We kindly ask You to promptly report to the Office of reference of the company every possible variation of Your personal data, so that art. 11, letter (c) of the aforesaid normative, which requires that your collected data must be exact and, hence, updated, can be respected.


Holder and responsible of the treatment:

The holder of the treatment is ZAVA SRL

with head office in Via dell’Industria 43/bis, 31041 Cornuda (TV)

The Responsible of the Treatment, to whom is possible to profess their rights and/or to ask about the protection of personal data is approachable at the address:

Best regards