Privacy Policy

Kontractor is committed to protecting the personal data entrusted to it. Consequently, the management and security of such data are ensured with the utmost care, in accordance with data protection legislation, and in full compliance with the principles of lawfulness, fairness and transparency. In accordance with current privacy legislation (in particular EU Regulation 679/2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data), this policy explains who the Data Controller is, for what purposes Kontractor may use the data provided, how it will be processed, to whom it may be disclosed, where it may be transferred, and what rights the data subject has.

WHO WILL PROCESS THE DATA PROVIDED

The data provided will be processed by Kontractor, the data controller, whose registered office is at Via I Maggio 20064, Gorgonzola (MI).

PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

The personal data collected, whether in paper or electronic form, which is subject to processing, relates to:
· personal, administrative, accounting, tax and commercial data relating to the data subjects (such as members of corporate bodies, employees and contractors of third parties with whom the Customer has a business relationship);
· credit card details;
· Usernames and passwords for accessing programmes (e.g. AdWords, Facebook, LinkedIn). This data, which the Customer lawfully holds, is provided by the Customer in the course of establishing and carrying out pre-contractual or contractual relationships with the Data Controller. The data may be processed for the following purposes: A. sending quotations to companies/individuals who are already Clients or potential Clients; B. performing the services requested by Clients; C. monitoring payments; D. compliance with legal obligations (e.g. accounting and tax obligations); E. exercising the Data Controller’s right of defence in legal proceedings; F. sending communications – commercial information (e.g. newsletters, invitations to events, instructions on how to obtain a promotional item or a promotion) to customers – suppliers/potential customers – suppliers of Kontractor’s corporate customers, in the case of data acquired directly by the Company (e.g. via a landing page); G. sending communications – commercial information (e.g. newsletters, invitations to events, other commercial information) to Kontractor’s customers/potential customers. NATURE OF THE PROVISION OF DATA The Company will process the data referred to in the preceding points:
· A., B. and C., as this is necessary for (i) the performance of pre-contractual activities aimed at drawing up a contractual proposal and (ii) the provision of the services requested by the Customer;
· D. where necessary to comply with a legal obligation to which the Company is subject;
· E. insofar as it is necessary for the pursuit of the Company’s legitimate interest in safeguarding its rights in the event of legal disputes;
· F. and G. on the basis of the Customer’s consent; the Customer will always be given the opportunity to withdraw their consent in accordance with the procedures set out in the following paragraphs. The provision of data for the following purposes:
· A., B., C. and E. are necessary for the performance of the Company’s contractual and/or pre-contractual activities;
· D is mandatory, and any refusal by the data subject will make it impossible for the Company to pursue the purposes described in the previous paragraph;
· Points F and G are optional; however, failure to provide such data will make it impossible for the Company to pursue the stated purposes. The scope and adequacy of the data provided will be assessed on a case-by-case basis in order to determine the resulting decisions and avoid the processing of data that goes beyond the purposes pursued. The Company undertakes not to use the personal data provided for purposes other than or in addition to those described in this policy without first informing the data subject and, where necessary, obtaining their consent. METHODS OF PROCESSING Data processing is carried out using computerised or, in any case, electronic procedures or paper-based media, in accordance with logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security of the data and always in compliance with current legislation on the matter, in particular EU Regulation 679/2016. The data will also be:
· processed by company staff who have received appropriate training and are bound by confidentiality obligations, in their capacity as authorised data processors;
· stored in a manner that ensures their security, integrity and confidentiality, through the adoption of appropriate security measures as required by law. RETENTION PERIOD With regard to processing for the following purposes:
· A., B., C., D. and E., the Company will process personal data for as long as is necessary to fulfil these purposes and, in any event, for a period not exceeding 10 years from the termination of the last contractual relationship with the Customer. The data may be retained beyond this period in the event that it is required for use in legal proceedings in the event of a dispute, or in any other case where the Company’s legitimate interests override the interests or fundamental rights and freedoms of the data subject;
· F. and G., the data will be retained until the data subject withdraws their consent in accordance with the procedures provided by the Company for this purpose.

COMMUNICATION AND DISSEMINATION

The data collected will not be disclosed or shared outside the Company. The data may be disclosed, in the course of our dealings with the Customer, to
· public bodies, in order to comply with legal obligations or to exercise the Company’s rights (for example, the right to defend itself in court);
· private entities and organisations established within Italy to which, through contractual agreements, services (technical, IT and administrative/accounting support) are entrusted that are strictly necessary for the purpose for which the data is provided by the data subject. The Company wishes to inform you that should it become necessary, due to changes in its organisation or agreements with new suppliers, to transfer data outside the European Union, such transfer will take place in accordance with the applicable legal provisions (Article 45(1) of the GDPR, Transfer on the basis of an adequacy decision, or Article 46, Transfer subject to appropriate safeguards). RIGHTS

RIGHTS OF THE DATA SUBJECT AND HOW TO EXERCISE THEM

Please be advised that EU Regulation 679/2016 (in particular, Chapter III) grants data subjects specific rights, which they may exercise by contacting the Company in writing at Via I Maggio 20064 Gorgonzola (MI) or by email at info@kontractor.it. Specifically, these rights are set out in the following articles of the GDPR:
· 13. Information to be provided when personal data is collected directly from the data subject. In particular, please note the provisions of paragraph 2(d) concerning the right to lodge a complaint with the Data Protection Authority;
· 15. The data subject’s right of access;
· 16, Right to rectification;
· 17, Right to erasure (‘right to be forgotten’);
· 18, Right to restriction of processing;
· 19. Obligation to notify in the event of the rectification or erasure of personal data or the restriction of processing;
· 20, Right to data portability;
· 21, Right to object;
· 22, Automated decision-making concerning natural persons, including profiling. The data controller undertakes to handle the data subject’s request in the best possible manner in order to ensure that the data subject’s rights are effectively exercised.

HOW TO CONTACT THE DATA CONTROLLER

Any further information regarding the processing of your data and this privacy policy may be requested by writing to Via I Maggio 20064 Gorgonzola (MI) or by emailing info@kontractor.it.

CHANGES AND UPDATES

This Privacy Policy may be subject to amendments and additions, including as a result of updates to the applicable legislation on the protection of individuals with regard to the processing of personal data and the free movement of such data. The most up-to-date version of the policy is available at www.kontractor.it/privacy.