Pursuant to and for the purposes of the current legislation on the processing of personal data, defined in accordance with the provisions contained in the
EU Regulation 2016/679 of April 27, 2016 supplemented by the Legislative Decree No. 101 of August 10, 2018. ,
We inform you that the processing of data provided or otherwise acquired will take place in full respect of fundamental freedoms, always adopting principles based on correctness, lawfulness and transparency, and for purposes not exceeding the purposes of collection, so as to ensure the protection and confidentiality of the data.
Categories of data processed
For the specific services provided by TERMINTER S.R.L., a retail, door-to-door sales company of water refining equipment and infini apparatus, the categories of personal data processed may be:
– data allowing direct identification, such as personal data (for example: first and last name)
– data allowing indirect identification, such as an identification number (for example: reference address)
– data related to electronic and non-electronic communications (for example: email addresses, telephone)
0 -Source from which personal data NOT collected directly from the Data Subject originate.
Where personal data are NOT collected directly from the Data Subject, they originate from:
- Electronic communication received via information request format on the company website
- Communications of the network of distributors/dealers through which Farmacqua products are marketed
1 – Identity and contact details of the data controller and its representative:
The Data Controller is TERMINTER S.R.L.
Plant -headquarters (administrative and operational): Industrial Zone, San Filippo del Mela (ME) – VAT number 01145290837
Legal Representative: Sole Administrator Mr. INTERDONATO Orazio (Data Processing Contact Person)
Phone: + 39 090.938.54.64 /80 Contact email addresses: info@farmacqua.com and commercial@terminter.com , websites: www.terminter.com and www.farmacqua.com
2 – Purposes of the processing for which personal data are intended – Legal basis for processing
Personal data of Customers, purchasers of products and equipment produced by TERMINTER S.R.L., are acquired to fulfill a legal and/or contractual obligation.
Legal basis -contractual:
The delivery of the data is a necessary requirement for the assignment of the provision of technical support and maintenance services included in the warranty of the products manufactured by TERMINTER S.R.L. and purchased by the Customer and are processed by the Data Controller without the need for documented express consent, considering that, in the absence of such data, the company cannot proceed with the conclusion of the assignment and ensure the provision of the service.
Legal basis -legal:
Customers’ personal data are also processed without the need for documented express consent:
– when necessary to comply with legal obligations to which the economic operator is subject, such as during tax compliance or satisfaction of requests from control and/or supervisory bodies.
3 – legitimate interests pursued by the Data Controller and acquisition of consent
The Data Controller does not pursue any further interest in processing Customers’ personal data for purposes beyond the provision of warranty service activities, such as sales promotion and/or Direct Marketing activities, for which it is NOT required to seek Documented Express Consent.
4 – any recipients or any categories of recipients of personal data
They are third parties, involved in the scope to the specific needs of satisfaction of the task of providing technical support and maintenance services: the distributors / dealers of the sale of products, transportation and shipping companies for the possible delivery of goods to the buyer.
Only the personal data of the interested party strictly necessary for the performance of the requested service or prescribed by the applicable legislation are communicated to the above-mentioned recipients.
The personal data of Customers collected by TERMINTER S.R.L., are also processed by the internal staff of the organization, duly instructed to do so, who need to have knowledge of them in the performance of activities necessary to pursue the purposes expressed above.
5 – retention period of personal data or criteria used to determine this period
The data processed in the exclusive interest of satisfaction of the supply contract (see paragraph 2), will be processed until the conclusion of the warranty period and for the further duration of any technical assistance assignments signed. Data will then be retained for the sole satisfaction of legal and/or tax obligations.
The Data Controller ensures periodic verification of data integrity and updating and defines the time limit by which it will automatically proceed to data deletion in 5 years after the termination of the relationships.
TERMINTER S.R.L. declares that it:
– NOT to transfer personal data of Customers to a third country or international organization
– NOT to manage or activate on its own or through third parties, automated decision-making processes, including profiling
RIGHTS OF THE INTERESTED PARTY
Exercise of right
In order to ensure the exercise of the Data Subject’s right, the Data Controller has specifically identified the dedicated email address and contact reference given in this Notice.
Requests must be formally transmitted by the Interested Party, by registered mail AR or email pec to the addresses specified in point 1 of the information notice, stating “Type of Right exercised“ (e.g., Right to Access) as the subject line.
The notice must include the identifying data of the interested party, details of the request, and be accompanied by a copy of the applicant’s ID.
Within 3 working days and before proceeding to the different requests, the TERMINTER S.R.L. will activate internal protocols to verify that the sender of the transmission actually coincides with the Data Subject, to guarantee the same.
Right to Access
The Data Subject has the Right to obtain confirmation from the data controller as to whether or not personal data concerning him or her is being processed.
In the event of a positive outcome of active processing, the Data Controller will ensure that the data subject, within 10 working days of the sender’s successful confirmation check, can obtain access to the personal data, providing a copy of the same together with the specific information in the latest update.
If additional copies are requested by the data subject, the data controller may charge a reasonable fee based on administrative costs. If the data subject submits the request by electronic means, and unless otherwise specified by the data subject, the information will be provided in a commonly used electronic format.
Right to Rectification
The Data Subject has the Right to obtain from the Data Controller the correction of inaccurate personal data or for integration of incomplete personal data.
In the case of active processing, the Data Controller will ensure to the data subject, within 5 working days from the successful confirmation of the sender, the corrections and additions of the requested data in its databases and files.
Right to Cancellation
L’Interested Party has the right to obtain from the data controller The deletion of personal data concerning him/her in the following cases:
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- personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed (see section 2);
- the data subject objects to the processing and there is no further legitimate reason to proceed with the processing;
- personal data have been unlawfully processed;
- personal data must be deleted to fulfill a legal obligation prescribed in the EU framework.
TERMINTER S.R.L. will activate internal protocols to verify the legitimacy of the request and the characteristic of the data that can be deleted. Following the verifications, the Data Controller guarantees the data subject, within 15 working days, to obtain confirmation that the personal data has been deleted.
Right to Limitation
The data subject has the Right to obtain from the data controller to temporarily transfer his or her personal data to a system of alienation that tends to freeze them by making them no longer accessible and unrelated to any further form of processing itself.
TERMINTER S.R.L. will activate internal protocols to verify the legitimacy of the request and the characteristic of the data that can be restricted. Following the verifications, the Controller will ensure that the data subject will be able to obtain confirmation of the restriction of the processing of personal data within 5 working days.
Right to Portability
The Data Controller recognizes that the Right to Portability represents the possibility for data subjects not only to obtain and reuse personal data provided to a data controller, but also to transmit these data to a different service provider (belonging to the same or a different business sector).
The status of entitlement is recognized for all data that the data subject has provided to the Data Controller, including information obtained from observation in the activities carried out for the data subject, within the scope of the supply relationship and the provision of services.
The data will be transmitted in a structured format on *.pdf file format to ensure them commonly used and machine-readable requirements.
The request for the exercise of the right to portability must include in detail the data that are the subject of the request, together with the identifying data of the person to whom it is eventually requested to be transmitted.
TERMINTER S.R.L. will ensure within 15 working days from the successful confirmation check of the sender, the transmission of the required data.
It should be noted that data controllers who follow up on portability requests are not responsible for the processing carried out by the individual data subject or the company to which the data in question are transmitted as a result of exercising the right of portability. In fact, data controllers act on behalf of the data subject, even if the personal data are transmitted directly to a different data controller. In this sense, the data controller who complies with the portability request is not responsible for the receiving data controller’s compliance with data protection rules, since the latter is not selected by the data controller.
The Data Controller will notify each of the recipients, to whom personal data have been transmitted, of any rectification or erasure or restriction of processing, unless this proves impossible or involves disproportionate effort.
The Data Controller will notify the Data Subject of these recipients if he or she requests it.
Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, a data subject who considers that processing concerning him or her is being carried out in violation of his or her rights has the right to lodge a complaint with the supervisory authority.
The Data Protection Authority (Privacy Guarantor) is the Italian national supervisory authority in the field of personal data protection.
The procedures for submitting a complaint to the supervisory authority, are clearly stated in full transparency at https://www.garanteprivacy.it/
TERMINTER S.R.L.
Orazio Interdonato
Sole Director – Contact person for treatment