with registered office in Milan, via Don Giovanni Verità 25, C.F.- P.IVA: IT-12878090153 (“POLI.design S.c.r.l.” or “Controller”)
1. Scope of the processing
POLI.design S.c.r.l (or the “Company”) treats the personal data of personas (or "Data Subjects") who contact the Company to receive the various services offered by the Company itself. In this regard, before the processing of data, POLI.design S.c.r.l. issues specific information for the various processing purposes (e.g. information for training, employees, suppliers, newsletters, etc.) and collects, where required, the written consent of the interested party.
2. Data Controller and Data Processor
POLI.design S.c.r.l., via Don Giovanni Verità 25, 20158 Milano P. IVA 12878090153, is the Data Controller. Furthermore, the Company has appointed a Data Processor (email@example.com) and maintains available for the Data Subject an updated list of the various external Processors involved in the various purposes for which processing is carried out.
3. Personal data subject to the processing
The Company processes the data of the Data Subjects to the extent that such processing is necessary for the execution of the requested services.
4. Purpose and modalities of the processing
The processing of personal data is aimed at the correct and complete execution of the requested services. The data will also be processed in order to:
- fulfill the contractual obligations inherent to the service;
- fulfill the obligations provided for by law (eg in tax, accounting, etc.);
- possibly fulfill the requests of the Data Subject even if they do not fall within the specific contract.
Personal data may be processed by means of both paper and computer files and with the modalities that are strictly necessary ways to meet the purposes outlined above.
5. Legal basis of the processing
The Company lawfully processes personal data of the Data Subject, if processing:
- is necessary for the execution of a contract to which the Data Subject is a party;
- is necessary to fulfill a legal obligation incumbent on the Company;
- is based on the express consent of the Data Subject (e.g.: consent to receive the Company's newsletter)
6. Consequences of failure to provide personal data
With regard to personal data relating to the execution of the contract or to the fulfillment of a regulatory obligation (e.g., obligations of accounting and tax records), failure to communicate personal data prevents the execution of the contract itself.
7. Retention of personal data
The personal data of the Data Subjects will be kept for the duration indicated in the various information notices and in compliance with the retention obligations established by law or regulation.
8. Disclosure of personal data
Personal data may be disclosed, by way of example, to consultants and accountants or lawyers who provide functional services for the purposes indicated above, to the subjects who process the data in execution of specific legal obligations, to the judicial or administrative authorities, for the fulfillment of the legal obligations.
If necessary for the purposes listed above, personal data may also be disclosed to public and private Entities interested in any recruitment, to the proponents of training courses, to the Politecnico di Milano for the purposes related to the enrollment of the Data Subject in a specializing master and for the management of the course; to other companies and public or private universities for the management of training activities when required.
The Company does not adopt automated decision-making processes, including the profiling referred to in Article 22, paragraphs 1 and 4 of the GDPR.
10. Rights of the Data Subject
The Data Subject, at any time, can:
- request confirmation of the existence of his/her personal data;
- obtain information about the purposes of the processing, the recipients or categories of recipients to whom the personal data have been or will be communicated;
- obtain the identification details of the Processors and of the designated Representative;
- request explanations on any IT tools used for the processing of personal data;
- oppose an automated decision-making process relating to natural persons, including profiling;
- ask the Company for access to personal data and for the correction or cancellation of the same or limitation to their treatment or oppose the processing;
- request data portability;
- withdraw consent at any time without affecting the legality of the relationship based on the consent given before the revocation;
- request cancellation, transformation into anonymous form or blocking of data processed in violation of the law.
11. Exercise of rights and complaints
The Data Subject, at any time, can:
- exercise his/her rights listed in paragraph 10) above, by sending an email to the email address firstname.lastname@example.org
- submit a complaint to POLI.design in addition / or to the Guarantor for all matters concerning the processing of personal data in relation to their protection.