Privacy Policy

Information pursuant to Art. 13 of the new European Regulation 2016/679

We hereby inform you that Regulation (EU) 2016/679 of the Parliament and of the Council provides for the protection of persons and other subjects with regard to the processing of personal data.

In accordance to the aforementioned legislation, the processing of personal data will be based on the principles of correctness, lawfulness and transparency and the protection of confidentiality and rights.

In accordance with Art. 13 of the G.D.P.R., we provide you with the following information:

Legal basis, purposes and methods of data processing

The legal basis of the processing for the purpose referred to in (a) is Article 6(1)(b) of the Regulation (“processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject’s request”).

Personal data will be processed exclusively for purposes strictly connected with and instrumental to the fulfilment of the obligations under the existing relationship. Specifically:

– for entering master data into the company’s computer databases;
– for bookkeeping;
– for the management of receipts and payments;
– for fiscal management;
– to fulfil obligations under civil and tax laws, regulations, and EU legislation;

Personal data shall be processed by means of paper and computer media by the data controller, the person in charge and the persons in charge in compliance with all precautionary measures guaranteeing their security and confidentiality.

Nature of data collection and consequences of failure to provide data

The provision of personal data is obligatory in order to fulfil the obligations arising from the contract and, in general, legal obligations.

Failure to provide them may make it impossible for us to fulfil our contractual obligations or the activities provided for by the regulations in force.

Disclosure and dissemination of data

Personal data for the performance of the contract and for the above-mentioned purposes may be disclosed:

– to all natural and legal persons (legal, administrative, tax consultancy firms, auditing firms, couriers and forwarding agents, data processing centre, etc.) in cases where communication is necessary for the above-mentioned purposes;

– to banking institutions for the management of collections and payments and for any credit/credit applications;
– to factoring or debt collection companies;
– to our specially appointed collaborators and employees and within the scope of their duties;
– other natural or legal persons that may need to be involved for the fulfilment of the above-mentioned purposes.

Territorial scope

Your personal data will not be transferred to recipients outside the European Economic Area. Should they be in the future, the Data Controller assures you that your Personal Data will be processed in accordance with Applicable Law. Indeed, transfers will be based either on an adequacy decision or on the ‘Standard Model Clauses’ approved by the European Commission.

Length of treatment

The data relating to you are kept in a form that permits identification of the person concerned for a period of time no longer than is necessary for the purposes, listed in point 1, for which they were collected or subsequently processed and in accordance with the requirements laid down by the regulations in force.

Rights of the data subject Articles 12 to 22 of 2016/679 (G.D.P.R.)

You may at any time exercise your rights vis-à-vis the data controller pursuant to Articles 12 to 22 of the New European Regulation 2016/679, which we reproduce here for your convenience.

• The controller shall take appropriate measures to provide the data subject with all the information referred to in Articles 13 and 14 and the notices referred to in Articles 15 to 22 and Article 34 relating to the processing in a concise, transparent, intelligible and easily accessible form, using plain and intelligible language, in particular in the case of information specifically addressed to children. Information shall be provided in writing or by other means, including, where appropriate, by electronic means. If requested by the data subject, the information may be provided orally, provided that the identity of the data subject is proven by other means.
• The person concerned has the right to be informed:
• a) the origin of the personal data;
• b) the purposes and methods of processing;
• c) the logic applied in the event of processing carried out with the aid of electronic instruments;
• d) the identification details of the holder, the persons responsible and the representative designated pursuant to Article 5(2);
• e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, as managers or appointees.
• The data subject has the right to obtain:
• a) the updating, rectification or, where interested therein, the integration of data;
• b) the deletion, transformation into anonymous form or blocking of data processed in breach of the law, including data whose storage is not necessary in relation to the purposes for which the data were collected or subsequently processed;
• c) certification that the transactions referred to in points a) e b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where this proves impossible or involves the use of means manifestly disproportionate to the right protected.
• The data subject has the right to object, in whole or in part:
• a) for legitimate reasons to process personal data concerning him/her, even if pertinent to the purpose of collection;
• b) the processing of personal data concerning him/her for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.

The rights referred to in Article 12 shall be exercised by making a request to the data controller or processor without formalities, including through an agent, which shall be answered without delay.

Data processor

The data controller is Full Spectrum 130 S.r.l., with registered office in Milan, Via Giovanni Pascoli, 70/4 20133 Milan MI – Italy, Tel. (+39) 320 426 2174, e-mail info@fullspectrum130.com.

Complaint Privacy Guarantor

Data subjects who consider that the processing of personal data relating to them carried out through this site is in breach of the Regulation have the right to lodge a complaint with the Garante, as provided for by Art. 77 of the Regulation itself, or to take appropriate legal action (Art. 79 of the Regulation), the contact details of which are published at www.garanteprivacy.it .

The data controller

Full Spectrum 130 S.r.l.