TREATMENT OF PERSONAL DATA RELATED TO CUSTOMERS/USERS ("interested parties")
EU Regulation 2016/679
As part of the activities of continuous updating of our procedures aimed at respecting the Privacy of our Customers/Users and the obligations imposed by the legislation on the protection of personal data, we thought it appropriate to summarize in this document all the elements concerning the processing of personal data already present in the documentation made available to users, integrated with more specific information in order to give maximum transparency to our work.
1. WHICH DATA ARE PROCESSED
> data provided by the User / Customer, or by a person / body acting on your behalf (attending physician, ASL / USL) including personal data (name and surname, residence / domicile, place and date of birth, nationality) tax code , identity document details, contact details (telephone / fax number, e-mail address);
> data, always provided by the interested party, contained in any reports / requests;
> dati relativi ai pagamenti effettuati dal Cliente.
The legislation establishes particular safeguards for judicial data (relating to criminal convictions and offenses) and for "particular categories of data" as defined by art. 9 of EU Reg. 2016/679: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a person physical, data relating to the health or sexual life or sexual orientation of the person.
FOR ORDERS RELATING TO specific immunotherapy products intended for identified and identifiable patients, SIVA IGIENE AMBIENTALE SRL will inevitably process data relating to health, which may also appear in the reports sent by users to customer service, for this reason specific consents will be requested from the interested party , where the characteristics or methods of processing require it.
With regard to this point, particular attention was paid in requesting only the data and in carrying out only the treatments necessary to meet the requests of the interested parties
> The data can be processed, always in relation to the purposes indicated below:
> as necessary to fulfill obligations deriving from a contract of which the interested party is a party, and the related legal obligations (in particular for the purposes referred to in point 3 letters a b c below)
> as necessary for the pursuit of a legitimate interest of the data controller, consisting in the optimization of the organization of activities, system security, credit protection (in particular for the purposes referred to in point 3 letters d and f h i below)
> as necessary to assert or defend a right in court or to assess whether there is a right to be usefully protected in court
> as they come from public registers accessible to anyone and / or manifestly made public by the interested party;
> having the interested party expressed his consent, (in particular in relation to the processing of some particular categories of personal data communicated by the interested party and the use of contact details other than the e-mail address provided at the time of signing the contract for commercial and advertising communications referred to in point 3 letters f g h) below
2 DATA SOURCE
Assumption and updating of personal data can take place:
- through the person concerned or, if a minor, through whoever exercises parental authority (parents or guardians);
- through intermediaries authorized by the interested party (eg family members);
- from sources freely accessible to anyone.
3. PURPOSE OF THE PROCESSING - WHY THE DATA ARE PROCESSED
The treatments carried out have the following purposes:
a) satisfy the requests of Bodies (Hospitals, Health Authorities, etc.), which order specific immunotherapy products for identified and identifiable patients, or of private customers who, by means of a medical prescription, order specific immunotherapy products for themselves or for their family members;
b) fulfill obligations deriving from laws, community rules and regulations, regional laws; fulfillment of provisions issued by the Judicial Authority, or by other Authorities to which the current legislation confers this right.
c) fulfill contractual, accounting and tax obligations;
d) customer database management, address books and internal statistical calculations within the company, - Statistical analysis carried out only through the aggregation of previously anonymous data;
e) possibly protect a legitimate interest, assert or defend a right;
f) feed the system for acquiring customer knowledge, necessary for the verification, improvement and therefore the design of a service increasingly suited to demand through surveys and detection, even anonymously, of the degree of customer satisfaction, also carried out with telephone interviews or requests to fill in questionnaires;
g) purposes related to public relations, marketing, advertising, promotional proposals.
In particular, any contact details, postal and e-mail addresses provided may be used for sending communications relating to promotional initiatives and / or the products of SIVA IGIENE AMBIENTALE SRL. It is understood that the user has the right to object to this treatment at any time
In this regard, it should be noted that Paragraph 4 of art. 130 of Legislative Decree 196/2003 allows the use for this purpose of the e-mail address provided by the interested party when purchasing a travel ticket / season ticket provided that he does not refuse such use;
And, as regards the management of user reports:
h) Ensure a certain and timely response to user reports, facilitating the creation of an effective communication channel between the Company and the customer-user
i) Feed the registration system and systematic analysis of the discrepancies of the service to correct the defects
4. HOW THE DATA ARE PROCESSED methods of treatment and storage
In relation to the aforementioned purposes, the processing of personal data may take place with paper, IT and telematic tools. Always guaranteeing the most absolute confidentiality, relevance and not excess with respect to the purposes described above, in terms of registration and data retention periods.
The personal data referred to in point 1 above, without prejudice to the provisions of the regulations on the conservation of administrative documentation, will be kept exclusively for the time allowed / imposed by the current legislation applicable to the specific purpose for which the data are processed.
5. RESPONSIBLE AND RESPONSIBLE
For the same purposes, the data may be processed by the following categories of appointees and / or managers:
- Direction and management, production and logistics personnel, marketing and communication personnel, administration personnel for the management of administrative aspects, company Information Technology which has the task of guaranteeing the functionality of the systems, data security and backup operations, other offices of SIVA IGIENE AMBIENTALE SRL within the limits of their competences, always for the purposes indicated in point 3 above, other subjects (companies / professionals appointed as Managers) who need to access some data as they are responsible for carrying out auxiliary activities for the purposes indicated above, within the limits strictly necessary to carry out the tasks entrusted to them such as: assistance in carrying out or direct execution of fiscal / accounting obligations, management of information systems, financial services, online sales; in this regard, it should be noted that these subjects will always and in any case be bound to full compliance with the rules and procedures aimed at guaranteeing the widest protection and protection of personal data adopted and imposed by the Data Controller also and not only in compliance with the legislation in force. for user reports: in addition to the staff assigned to receive user reports, the data may be processed, with the exception of the identification elements of the interested party, by the company functions involved in the subject of the report for the preparation / implementation of surveys internal and for the resolution of causes always and only within the limits of what is actually necessary to carry out their functions
Without prejudice to the communications made in compliance with legal obligations, the personal data in question can be communicated or made available: to subjects who can access the data by virtue of the provision of law, regulation or of community legislation, within the limits set by these rules, - to the public or private body that placed the order of a specific immunotherapy product intended for the interested party limited to accounting and tax data to banks, credit institutions, data processing companies and credit card issuing companies, for activities relating to the execution of the service provided to users and / or related administrative and financial aspects, to other subjects (companies / consultants) who need to access some data for purposes auxiliary to the management of the services requested by the interested parties, within the limits strictly necessary to carry out the tasks entrusted to them such as: assistance in the fulfillment or direct execution of tax obligations / accounting / assistance, management of information systems, financial services, - to entities, consortia, professionals and companies with the purpose of credit recovery and protection; credit insurance company, commercial information company, Naturally, all the communications described above are limited only to the data necessary for the recipient body / office (which will remain the independent Data Controller for all subsequent processing) for the performance of its duties and / or for the achievement of the purposes connected to the communication itself. 6.1 transfer abroad Personal data will be transferred to subjects located outside the European Union to the country in which the interested party resides or is located exclusively in fulfillment of the legitimacy conditions referred to in point 1 and in compliance with current legislation. . 6.2 DISSEMINATION OF THE DATA IN QUESTION WILL NOT BE DISCLOSED