Privacy Policy

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Privacy Policy

INFORMATIVA PER IL TRATTAMENTO DEI DATI PERSONALI

Turlo S.r.l., con sede legale in Via Monte Rosa, 5 – 13019 Varallo (VC), CF e P.IVA 00170930028 (in seguito, “Titolare"), as data controller, informs you pursuant to art. 13 D.Lgs. 30.6.2003 n. 196 (hereinafter, "Privacy Code") and art. 13 EU Regulation no. 2016/679 (hereinafter, "GDPR") that your data will be processed in the manner and for the following purposes:

1. Object of the Treatment

The Data Controller processes personal, identifying data (for example name, surname, company name, address, telephone, e-mail, bank and payment details) (hereinafter "data"), provided by you, or otherwise acquired as part of our business.

2. Purpose of the processing

Your personal data are processed:
A) without your express consent (Article 24 letter a), b), c) Privacy Code and art. 6 lett.b), e) GDPR), for the following Service Purposes:
– conclude contracts for the services of the Data Controller;
– fulfill the pre-contractual, contractual and tax obligations deriving from existing relationships with you;
– the management of administration, accounting, orders, shipments, invoicing, services
– fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as in the field of anti-money laundering);
– exercise the rights of the Data Controller, for example the right of defense in court.
B) Only with your specific and distinct consent (art. 7 GDPR), in accordance with the provisions of the law.

Please note that if you are already our customer, we may send you commercial communications relating to services and products of the Data Controller similar to those you have already used, unless you disagree (Article 130 c. 4 of the Privacy Code).

3. Processing methods

The processing of your personal data is carried out by means of the operations indicated in art. 4 Privacy Code and art. 4 n. 2) GDPR and precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subject to both paper and electronic and / or automated processing.
The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes in accordance with the law.

4. Access to data

Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):
– to employees and collaborators of the Data Controller, in their capacity as persons in charge of processing and / or system administrators;
– to third-party companies or other subjects (as an indication, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) that carry out outsourced activities on behalf of the Data Controller, in their capacity as external data processors.

5. Communication of data

Without the need for express consent (pursuant to Article 24 letter a), b), d) Privacy Code and art. 6 lett.b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies (such as IVASS), Judicial Authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is mandatory by law for the fulfillment of the aforementioned purposes.
These subjects will process the data in their capacity as independent data controllers.
Your data will not be disclosed.

6. Rights of the interested party

In your capacity as an interested party, you have the rights referred to in art. 7 Privacy Code and art. 15 GDPR and precisely the rights of:
i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
ii. obtain the indication:
a) the origin of the personal data;
b) the purposes and methods of processing;
c) the logic applied in case of processing carried out with the aid of electronic instruments;
d) of the identification details of the owner, of the managers and of the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR;
e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the territory of the State, persons in charge or external managers;
iii. obtain:
a) updating, rectification or, when interested, integration of data;
b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right;
iv. object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. Please note that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to the traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition even in part. Therefore, the interested party may decide to receive only communications through traditional methods or only automated communications or neither of the two types of communication.
Where applicable, you also have the rights referred to in Articles. 16-21 GDPR (Right to rectification, right to be forgotten, right to limitation of processing, right to data portability, right to object), as well as the right to complain to the Guarantor Authority.

7. Data retention

Common personal data will be deleted after 5 years that you no longer have relationships.
Legal data will be stored in accordance with the provisions of the law.

8. Minors

The Services and the Website of the Data Controller are not intended for children under 18 years of age and the Data Controller does not intentionally collect personal information relating to minors.
In the event that information on minors is involuntarily recorded, the Data Controller will delete it in a timely manner, at the request of users.

9. How to exercise your rights

You can exercise your rights at any time by sending:
– a registered letter with return receipt to Turlo Srl – Registered / operational headquarters Via Monte Rosa, 5 – 13019 Varallo (VC);
– an e-mail to the address mail@turlo.it.

10. Data Controller, persons in charge and external managers

The Data Controller is Turlo S.r.l. with legal and operational headquarters in Via Monte Rosa, 5 – 13019 Varallo (VC).
The updated list of persons in charge of external data processors is kept at the registered office of the Data Controller.

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