Version: 2 - Policy date: 28/06/2018
Disclosure on the personal data processing policy
Pursuant to arts. 13 and 14 of Regulation (EU) 2016/679, General Data Protection Regulation (hereinafter referred to as “GDPR”), in relation to the personal data of which K.L.A.IN. robotics S.r.l. will enter into possession as Data Processor, the following information is provided:
1. Personal data
The data will be processed for institutional, connected or instrumental purposes for the activity of K.L.A.IN. robotics S.r.l. and in particular:
- for purposes strictly related to the management of the contractual relationship whose processing is necessary for the execution of the Contract to which the concerned party is subject (art. 6 lett. b) of the GDPR) and to the persecution of a legitimate interest of the Data Processor (art. 6 lett. f) of the GDPR). This legitimate interest is constituted by the execution of the economic activity of K.L.A.IN. robotics S.r.l. (contractual purposes);
- for the fulfilment of the obligations provided for by the laws and regulations to which the Data Processor is subject (art. 6 lett. c) of the GDPR) (legal obligations);
- to communicate and/or send, even with automated mode, advertising and informative material and commercial information via telephone channels, SMS, email, fax, whose legal base lies in the explicit consent of the concerned party (art. 6 lett. a) of the GDPR) (direct marketing purposes);
- to communicate the data to the commercial partners of K.L.A.IN. robotics S.r.l. for sending, even with automated mode, advertising material via telephone channels, SMS, email, fax, whose legal base lies in the explicit consent of the concerned party (art. 6 lett a) of GDPR) (commercial partners marketing purposes);
- to identify, also by means of electronic processing, habits and propensities for consumption, to improve the service provided, to meet specific Customer needs by offering new services and products of K.L.A.IN. robotics S.r.l.. The legal basis of which lies in the explicit consent of the concerned party (art. 6 lett a) of the GDPR) (profiling purposes).
3. Communication of data
The data will be communicated within K.L.A.IN. robotics S.r.l. to the persons in charge of the activity related to the K.L.A.IN. robotics S.r.l. services offered and communicated to third parties (for example banks, consultancy services, technical partners, commercial partners) for the purposes of the protection of the credit risk, information, commercial communications, in order to ensure the provision of K.L.A.IN. robotics S.r.l. services and provide the necessary technical and operational support. This communication is necessary for the conclusion of the contract and for the fulfilment of the same.
The scope of the communication of the data will be limited to what is strictly necessary for the execution of the task that we have conferred to the third party subjects mentioned above in the context of the objectives of letters 2.a and 2.b) and, in the case of letters 2.c), 2.d and 2.e), with prior consent expressed by the Customer.
Moreover, K.L.A.IN. robotics S.r.l., upon special request, communicates the data to the competent authorities for the fulfilment of the obligations imposed by law.
K.L.A.IN. robotics S.r.l. has provided for the due designations and appointments pursuant to the provisions of the GDPR.
4. Nature of the data provision
The consent to the processing of the data for the purposes referred to in the previous letters 2.a and 2.b) is not necessary pursuant to art. 6 of the GDPR. The consent to the processing of data for the purposes referred to in letters 2.c), 2.d and 2.e), instead, is optional and the eventual refusal will prevent K.L.A.IN. robotics S.r.l. from the sending of commercial communications, profiling activities or communication to their partners for third party commercial purposes.
5. Processing methods
The data will be processed both on paper and in electronic and/or automated mode, directly and/or through the third party subjects indicated above.
The data may be processed and organised in databases, processed for the time strictly necessary for the delivery of the services covered by the Contract and to provide technical and operational assistance.
6. Retention period
The retention period of the processing for the purposes of the contract coincides with the duration of the contractual relationship, while the one linked to the fulfilment of legal obligations is prescribed by the law.
In relation to the purpose of direct marketing, commercial partners and profiling, the retention period of the processing is 10 years, in any case, the concerned party has the right to revoke this consent at any time without affecting the lawfulness of the processing based on the consent given before the revocation.
7. Data controller and Data protection Supervisor
The data processor is K.L.A.IN. robotics S.r.l. with registered office in via F.lli Porcellaga 3 - 25122 Brescia.
8. Rights of the concerned party
At any time the Customer may exercise his/her rights with regard to the Data Processor, pursuant to articles 15 and following of the GDPR. In particular, all concerned parties have the right to ask for the access to their personal data, correction or cancellation of the same or the limitation of the processing that concerns him/her, or to oppose their processing, in addition to the right to the portability of the data.
The Customer also has the right to lodge a complaint with the competent Supervisory Authority for the protection of the Personal Data.