Policy Privacy

Version 1.0 of 26 May 2018

Dear User, in accordance with Articles 12, 13 and 14 of the European Regulation No. 679/2016 "General Regulation for the Protection of Personal Data", we are providing you with the Information regarding the processing of Your Personal Data.

We remind you that you have the right to read it before communicating your Personal Data to us, or to exercise your Right to object to one or more of the purposes (aims) of the processing indicated in this Information Notice in the relevant section.

The Data Controller is:

Alfabeta Snc di Centola Oriana Lucia e C.
Viale Marazza, 30
28021 Borgomanero (NO)
Tel. +39 0322 846442
E-mail: info@alfa-beta.org

The main processing operations carried out relate to the fulfilment of the Employment Contract and all obligations relating thereto (both of a fiscal and legal nature, and of an organisational and operational nature), the fulfilment of the contract with the customer and all obligations relating thereto (both of a contractual and of a fiscal and operational nature), as well as the procurement of new customers and the increase in business volume through those already acquired, by means of contact through the website, marketing initiatives and other means.

The main risks connected to the aforesaid processing operations are identifiable in the possibility that one or more actions aimed at procuring new business may infringe the rights and freedoms of the Data Subjects, for instance by causing annoyance to the Data Subject due to the receipt of undesired commercial offers. Alfabeta Snc di Centola Oriana Lucia e C. does, however, take all technical and organisational measures to ensure that those who receive the advertisements or commercial offers do in fact give their consent. Furthermore, it will ensure that the frequency of sending and the methods chosen do not exceed what is considered a lawful propaganda activity.
In general, an identifiable risk is the possibility that unauthorised persons or third parties come into contact with personal data of Data Subjects of which Alfabeta Snc di Centola Oriana Lucia e C. is the Data Controller. However, in accordance with the applicable law, Alfabeta Snc di Centola Oriana Lucia e C. takes all technical and organisational measures to reduce the risk of the above-mentioned eventuality occurring to an acceptable minimum.

The purposes (aims) for which we process your Personal Data are as follows:

1) If you are an employee or collaborator of Alfabeta Snc di Centola Oriana Lucia e C. Fulfilment of the obligations foreseen by the Contract of Employment or Collaboration. For example: processing of pay slips, management of work shifts, management of sick days, holidays, contributions, training courses etc. In this case, the Consent is not required since the Legal Basis for the Processing is the Execution of the Labour Contract itself or, in some cases, the Legitimate Interest of the Data Controller, if it is necessary to carry out processing activities involving Interested Parties who are employees or collaborators of Alfabeta Snc di Centola Oriana Lucia e C. and at the same time it is impossible to ask them for their free Consent.

2) Should the Client of Alfabeta Snc di Centola Oriana Lucia e C. Fulfilment of obligations relating to the sales, assistance and/or service contract signed with the Interested Party and all pre-contractual measures relating to the same, such as quotation, negotiation, insertion in internal management etc. In this case, Consent is not required since the Legal Basis of Processing is to be found in the contract signed with the Data Subject and in all the pre-contractual measures relating thereto.

3) In the case of natural persons who are not customers of Alfabeta Snc di Centola Oriana Lucia e C. Procurement of new customers, such as the sending of commercial communications by e-mail, telephone, ordinary mail, etc.. In this case Consent is required and constitutes the Legal Basis for the Processing itself.

4) Management of the acquired customer base, including natural person resellers. In this case the Legal Basis of Processing is the Contract signed between the parties, and therefore Consent is not required, as well as Legitimate Interest as "there is a relevant and appropriate relationship with the Data Subject".

A full list of Recipients with whom we may need to share your Personal Data in accordance with applicable law is available upon your request. Your request must be made to the Data Controller without any special formalities.

The categories of recipients to whom your Personal Data will be disclosed are:

1) Public Bodies in charge of Social Security, Workers' Insurance and Tax Assessment (e.g.: INPS, INAIL, Agenzia delle Entrate etc.) and any public body to which Alfabeta Snc di Centola Oriana Lucia e C. is obliged to provide the Data of its employees, collaborators, retailers or customers by law.

2) Companies and Professionals in charge of the management, maintenance and remote assistance of Alfabeta Snc di Centola Oriana Lucia e C.'s IT system.

3) Professionals in the Accounting and Payroll Management sector.

4) Companies managing the web equipment of Alfabeta Snc di Centola Oriana Lucia e C.

5) Software Houses and Producers of Software Solutions used by Alfabeta Snc di Centola Oriana Lucia e C. for the processing of Personal Data.

6) The clients of Alfabeta Snc di Centola Oriana Lucia e C. themselves, should it be necessary, due to pressing operational needs, to communicate to them the contact details of employees or collaborators of Alfabeta Snc di Centola Oriana Lucia e C.

All the Recipients will be, from time to time, appointed as Responsible Parties and instructed by Alfabeta Snc di Centola Oriana Lucia e C. in accordance with the provisions of the Law, as well as obliged to keep the information transmitted confidential and to cancel or return it once the processing has been completed.

Alfabeta Snc di Centola Oriana Lucia e C. does not and will not transfer your Personal Data to international organisations or data controllers located outside the European Economic Area. If it decides to do so, it will scrupulously comply with the provisions dictated by EU Reg. 679/2016 regarding the foreign transfer of personal data and will take care to inform you, in accordance with the provisions of the Law, before making the transfer.

Alfabeta Snc di Centola Oriana Lucia e C. will store your Personal Data according to these criteria:

1) In case of Personal Data subject to storage obligations established by Italian or European Law: within and not beyond the limits dictated by the reference legislation, after which they will be deleted or made anonymous.

2) In case of Personal Data referring to Employees or Collaborators (except for point 1): until the end of the working relationship or collaboration with Alfabeta Snc di Centola Oriana Lucia e C., after which they will be deleted or made anonymous.

3) In case of customers' Personal Data of natural persons granted for the purposes (aims) under point 3) of the Purposes: until the Data Subject revokes his/her Consent and in any case not later than 5 years from the Consent given.

4) In the case of retailers of Alfabeta Snc di Centola Oriana Lucia e C. natural persons: until the end of the subscribed contract, subject to point 1), at the end of which they shall be deleted or made anonymous.

We will set out below the rights you have under European Regulation no. 679/2016. To exercise one or more of the following rights, simply contact Alfabeta Snc di Centola Oriana Lucia e C. at the contacts indicated above without any particular formality.

RIGHT OF ACCESS
Art. 15 EU Reg. 679/2016

The data subject has the right to obtain from the data controller confirmation as to whether or not personal data relating to him are being processed and, if so, to obtain access to the personal data and to the following information:

1) the purposes of the processing;
2) the categories of personal data concerned
3) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if they are recipients in third countries or international organisations
4) where possible, the period for which the personal data will be retained or, if this is not possible, the criteria used to determine that period
5) the existence of the data subject's right to request from the controller the rectification or erasure of personal data or the restriction of the processing of personal data concerning him or her or to object to their processing
6) the right to lodge a complaint with a supervisory authority;
7) where the data are not collected from the data subject, all available information on their origin
8) the existence of an automated decision-making process, including profiling as referred to in Article 22(1) and (4), and, at least in such cases, meaningful information on the logic used, as well as the importance and the envisaged consequences of such processing for the data subject.

RIGHT OF RECTIFICATION
Art. 16 EU Reg. 679/2016

The data subject shall have the right to obtain from the controller the rectification of inaccurate personal data concerning him/her without undue delay. Taking into account the purposes of the processing, the data subject shall have the right to obtain the integration of incomplete personal data, including by providing a supplementary declaration.

RIGHT TO CANCELLATION

Art. 17 EU Reg. 679/2016

The data subject shall have the right to obtain from the controller the erasure of personal data concerning him/her without undue delay and the controller shall be obliged to erase the personal data without undue delay if any of the following grounds applies:

the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
the data subject withdraws the consent on which the processing is based in accordance with Article 6(1)(a) or Article 9(2)(a) and if there is no other legal basis for the processing;
the data subject objects to the processing pursuant to Article 21(1) and there is no overriding legitimate ground for processing, or objects to the processing pursuant to Article 21(2);
personal data have been unlawfully processed;
the personal data must be erased in order to comply with a legal obligation laid down by Union or Member State law to which the controller is subject;
the personal data were collected in connection with the provision of information society services as referred to in Article 8(1).

RIGHT TO RESTRICTION OF PROCESSING
Art. 18 EU Reg. 679/2016

The data subject shall have the right to obtain from the controller the restriction of processing when one of the following cases occurs:

the data subject disputes the accuracy of personal data, for the period necessary for the controller to verify the accuracy of such personal data;
the processing is unlawful and the data subject objects to the erasure of the personal data and requests instead that their use be restricted;
although the controller no longer needs the personal data for the purposes of processing, the personal data are necessary for the establishment, exercise or defence of legal claims by the data subject;
the data subject has objected to the processing pursuant to Article 21(1), pending verification as to whether the legitimate reasons of the controller prevail over those of the data subject.
For the purposes (Purposes) for which You have given Your Consent, You are granted the right to withdraw Your Consent, i.e. to unilaterally withdraw from the processing operations related to the Purposes for which You have given Your Consent. Processing carried out before Your Revocation will, in accordance with the law, still be lawful.

If you believe that any processing carried out by us has caused you harm or damage, or if you believe that impropriety or unlawfulness has occurred in the processing of your Personal Data carried out by us, you are granted the right to lodge a Complaint with the Supervisory Authority, in accordance with the modalities established by the latter, available at the following address

https://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-tuoi-dati-personali

The partial or complete refusal to provide your Personal Data to Alfabeta Snc di Centola Oriana Lucia e C. will result in:

1) If you are an Employee or Collaborator of Alfabeta Snc di Centola Oriana Lucia e C.: the impossibility to establish any working relationship or collaboration.

2) If a customer who is a physical person of Alfabeta Snc di Centola Oriana Lucia e C.: the impossibility of completing the sale phase or the signing of any service and/or assistance contract.