Privacy Policy Newsletter

DISCLOSURE PURSUANT TO ART. 13 OF THE GDPR 2016/679
(European Regulation on the protection of personal data)

 

Dear Data Subject, in implementation of art. 13 of the GDPR 2016/679 (European Regulation on the protection of personal data), this disclosure is provided regarding the processing of personal data relating to the scope of newsletter management.

 

1) IDENTITY and CONTACT DETAILS OF THE DATA CONTROLLER: the Data Controller is the Company Sipol S.p.A. – Via Leonardo Da Vinci, 5 – 27036 Mortara (PV) – VAT no. 01842120188 | Tax Code 01669490037 – Tel. +39 0384 295237 – privacy@sipol.com.

 

2) DATA PROCESSED: first name, surname, e-mail address, role in the Company, company name of the Company at which the data subject works.

 

3) PURPOSE AND LEGAL BASIS OF PROCESSING: we process personal data in accordance with the provisions of the General Regulation (EU) no. 2016/679 on data protection for the following purposes:

1. 1. 1. For the pursuit of the legitimate interest of the data controller (art. 6 para. 1 lett. f of the GDPR):
         – for general information activities relating to institutional communications;
         – for commercial information activities by e-mail to the e-mail address provided during the sale, concerning the same type of product and/or service (soft spam) similar to the product/service object of the sale (art.130, paragraph 4 of Italian Legislative Decree196/03) on the basis of legitimate interest unless opposed.
         Your prior consent is not required for this purpose.

       

      2. Purposes for which the express consent of the data subject is required (art.6, para.1, letter a) of the GDPR):
         – for marketing purposes for the sending by the Data Controller, through newsletters, of commercial/ advertising material and communications having informative and/or promotional content in relation to products and/or services provided and/or promoted by the Data Controller.
          
         Express consent may be revoked at any time. The revocation is valid for the future and does not concern the processing that took place previously. You can request the list of consents given at any time and manage it through the “Manage Preference” link at the bottom of each newsletter.

 

4) RECIPIENTS OF PERSONAL DATA: personal data will be processed by subjects who operate as Data Processors and/or as natural persons who operate and act under the authority of the Data Controller and/or the Data Processor, such as, by way of example but not limited to: associated companies, communication agencies, manager of the newsletter sending platform, hosting service provider, etc.; the same data may be communicated to subjects entitled to access them by virtue of legal provisions, regulations and standards.

 

5) PROCESSING METHODS: the data will mainly be processed through electronic/digital aids and web and similar platforms and we assure you that we have put in place all the organisational, physical and logical measures deemed necessary and/or appropriate to guarantee the integrity, confidentiality and availability of the data.

 

6) DATA TRANSFER: the management and retention of personal data takes place on servers located within the European Union.

 

7)  DATA RETENTION: the Data Controller stores and processes personal data for the time strictly necessary and/or until your objection/withdrawal of consent; for marketing purposes, personal data will be retained for a maximum of twenty-four (24) months from collection.
Verification of the obsolescence of the data retained in relation to the purposes for which they are processed is performed periodically.

 

8)  PROVISION OF DATA: the provision of data is optional. The lack of consent/objection does not entail any consequence with respect to the execution of the contractual and pre-contractual relationships. You will simply not receive any marketing communication from Sipol S.p.a. .

 

9) RIGHTS OF THE DATA SUBJECT AND REVOCATION OF CONSENT: in accordance with arts.15 et seq. of Regulation (EU) 2016/679, the Data Subject may exercise their rights by writing to the Data Controller at the above address or by e-mail to privacy@sipol.com.
The data subject has the right to ask the Data Controller, at any time, for access, correction, erasure, restriction of processing and, where appropriate, data portability. In the event of a data portability request, the Data Controller provides the personal data being processed in a structured, commonly used and readable format.

The User may, at any time, exercise the rights expressed by arts.15 et seq. of the GDPR, such as:

1. 1. • access to personal data: to obtain confirmation or not that a processing of data concerning you is in progress and, in this case, access to the following information: the purposes, categories of data, recipients, the retention period, the right to lodge a complaint with a supervisory authority, the right to request the correction, deletion or limitation of the processing or opposition to the processing itself as well as the existence of an automated decision-making process;
      • request for correction or deletion of the same or limitation of the processing that concerns the data subject; “limitation” means marking of the data retained with the aim of limiting their processing in the future;
      • objection to the processing: to object for reasons related to your particular situation to the processing of data for the execution for the pursuit of a legitimate interest of the Data Controller;
      • data portability: in the case of automated processing performed on the basis of consent or in execution of a contract, to receive in a structured format, commonly used and readable by an automatic device, the data concerning the data subject; in particular, the data will be provided by the Data Controller in .xls or similar format;
      • revocation of consent (art.7 of the GDPR) to the processing for marketing purposes, both direct and indirect; the exercise of this right does not affect in any way the lawfulness of the processing performed before the revocation.

 

10) NEWSLETTER CANCELLATION AND PREFERENCE MANAGEMENT: consent to processing may be revoked at any time by using the link at the bottom of each newsletter to unsubscribe from the newsletter or it may be managed through the “Manage Preference” link at the bottom of each newsletter or by writing an e-mail to privacy@sipol.com.
If you unsubscribe/manage preferences through a direct link to the platform, your request is managed automatically and, at most, you may receive another newsletter if it has already been scheduled by the Data Controller within 72 hours.

 

11) RIGHT TO LODGE A COMPLAINT: the data subject has the right to lodge a complaint with the Supervisory Authority of the country of residence.