Privacy policy

Dear Sir/Madame,
We would like to inform you that EU Reg. 2016/679 (“European Regulation on the protection of personal data”) provides for the protection of individuals and other entities and respect for the processing of personal data.
Pursuant to Art. 13, therefore, we provide you with the following information:

1. Purpose, legal basis of the processing to which the data are intended

a) The processing of the personal data provided by you is aimed solely at fulfilling the contractual obligations and to fulfill your specific requests, as well as to fulfill the regulatory obligations, in particular the accounting and tax obligations foreseen by our activity.

2. Methods of treatment

In relation to the aforementioned purposes, your data is subject to computer and manual processing. The processing operations are carried out in such a way as to guarantee the logical, physical security and confidentiality of your personal data.

3. Legitimate interests pursued by the controller or third parties

The legitimate interests pursued by the Data Controller in the processing of data are given by having to respect
and honour the contractual obligations signed between the parties.

4. Nature of personal data

Your personal data processed in the performance of the service requested by you are subject to processing.

5. Compulsory or optional nature of the provision

Your personal data are processed: without your consent, with a mandatory nature, to fulfill pre-contractual,
contractual and tax obligations; to fulfill the obligations provided for by law, regulation, community legislation or
an order of the Authority; to exercise the rights of the Data Controller, for example the right of defense in court.

6. Scope of data communication and dissemination

Your data may be communicated to:

• all subjects to whom the right of access to such data is recognized by virtue of regulatory measures;
• to our collaborators and employees, in the course of their duties;
• to all those natural and/or legal, public and/or private persons when the communication is necessary or functional to the performance of our business and in the ways of and for the purposes described above, for example: banks, insurances, audit bodies, control bodies, credit recovery companies, etc.

7. Transfer of personal data to a third country

The data will not be transferred outside the European Union.

8. Method and duration of storage of personal data

Your personal data will be kept for as long as is strictly necessary. Specifically, tax and accounting data from the
end of the relationship 11 years.

9. Existence of automated decision-making:

There is no automated decision-making process.

10. Identifying details of the owner.

THE “DATA CONTROLLER” according to article 28 of the Code on the protection of personal data is SRS Spindle Research & Service s.r.l. con socio unico with registered office in VIA REDIPUGLIA, 77 – 24047 TREVIGLIO (BG), tel. +39 0363351602,
e-mail ilaria.bona@srs-srl.it in the person of the legal representative SIG. MAURIZIO MOLTENI

11. Rights of the data subject

11.1 Art. 15 (right of access), 16 (right of rectification) of EU Reg. 2016/679The data subject has the right to obtain from the controller confirmation as to whether or not personal data
concerning him or her is being processed and, in this case, to obtain access to and the personal data and
information contained in this policy.

11.2 Art. 15 (diritto di accesso), 16 (diritto di rettifica) del Reg. UE 2016/679
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay if one of the following grounds applies:

a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) the data subject withdraws consent on which the processing is based in accordance with Article 6(1)(a) or Article 9(2)(a) and there is no other legal basis for the processing;
c) The data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate
grounds for the processing, or objects to the processing in accordance with Article 21(2);
d) The personal data have been unlawfully processed;
e) The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
f) the personal data have been collected in relation to the offer of information society services referred to in
Article 8(1) of the EU Regulation 2016/679.

11.3 Right referred to in art. 18 Right to restriction of processing
You have the right to obtain from the controller the restriction of processing where one of the following applies:

a) The accuracy of the personal data is contested by the data subject, for a period necessary for the controller to
verify the accuracy of the personal data;
b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the
restriction of their use instead;
c) although the controller no longer needs the personal data for the purposes of the processing, but the data
subject needs the personal data to establish, exercise or defend legal claims;
d) the data subject has objected to the processing pursuant to Article 21(1) EU Reg 2016/679 pending
verification as to whether the legitimate grounds of the controller outweigh those of the data subject may prevail.

11.4 Right referred to in art.20 Right to data portability
The data subject has the right to receive the personal data concerning him or her, which has been provided to a controller, in a structured, commonly used and machine-readable format and has the right to transmit these data to another controller without hindrance from the controller.
If you wish to have more information about the processing of your personal data, or exercise the rights referred to in point 11 above, you can contact us at the following email address: SRS@ALAPEC.IT
Before we can provide you, or modify any information, in the shortest possible technical time, it may be necessary to verify your identity and answer some personal questions about the data provided.

12. Withdrawal of consent to processing
The data subject has the right to withdraw his or her consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to the withdrawal.
You have the right to withdraw your consent to the processing of your personal data by sending a pec to the following e-mail address: SRS@ALAPEC.IT, accompanied by a photocopy of your identity document, with the following text: “revocation of consent to the treatment of all my personal data”. At the end of this operation, your personal data will be removed from the archives as soon as possible.