INFORMATION ON PERSONAL DATA PROCESSING PURSUANT TO ART. 13-14 REG. (EU) 2016/679
DEMA Solutions S.r.l., in its capacity as the data controller of personal data, pursuant to and for the purposes of Regulation (EU) 2016/679 (hereinafter referred to as ‘GDPR’), hereby informs you that the aforementioned legislation provides for the protection of data subjects regarding personal data processing and that such processing will be based on the principles of fairness, lawfulness, transparency, and protection of your privacy and your rights.
All personal data provided will be processed in accordance with the legal provisions of the previously mentioned legislation and the confidentiality obligations provided for therein.
The data controller is DEMA Solutions S.r.l. with registered office in Via Antonio Gramsci n°10/12 20900 Monza MB – Italy – VAT no. 0399467678 – firstname.lastname@example.org.
The updated list of those responsible for and authorized to process data is kept at the data controller’s registered office.
A data protection officer has not been appointed.
LEGAL BASIS OF PROCESSING
- The data controller shall process personal data only if and to the extent that at least one of the following applies:
- The data subject has given consent to the processing of his/her personal data for one or more specific purposes;
- Processing is necessary for the performance of a contract or prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation to which the controller is subject;
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.
However, the data subject has the right to request from the controller clarification of the concrete legal basis for the processing and, in particular, whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
PURPOSE OF PROCESSING
All personal data voluntarily provided by data subjects to the addresses available on the site and requests for information or direct contact by the company are used for the sole purpose of fulfilling the request and are disclosed to third parties only if necessary for that purpose.
Data will be processed for the following purposes related to the performance of a contract and compliance with statutory or contractual obligations:
- Customer management
- Translation of technical documentation with occasional personal data content (mixed data)
- Supplier management
- Provider management
Data will be processed for the following purposes related to the legitimate interests pursued by the controller, taking into account the reasonable expectations of the data subject based on the relationship with the controller:
- CVs received from spontaneous applications
- Social Network Contacts
- Prospect Management
The data subject is free to provide or not provide any personal data that may be requested, but failure to provide such data may make it impossible to perform the services requested.
The site uses “cookies” to anonymously analyze site traffic and improve user browsing experience. The Dema Solutions website uses third-party JS cookies to collect data (Google Analytics and Hubspot) to analyze trends, administer the website, track user activities, and gather demographic information about our user base as a whole.
When you browse our website, we acquire some data, including your computer’s IP address and the pages you visit. The data are collected exclusively to ensure that the site is functioning and can be navigated correctly. Therefore, we do not collect any data for commercial purposes or to identify the user, who remains anonymous.
WHAT ARE COOKIES?
Cookies are information exchanged between the server and your computer to anonymously create statistics on the areas of the site visited by users. The collected data are then read in aggregate form to understand website efficiency and the level of browsing experience. The cookies used, therefore, do not contain any personal user information. Most browsers are able to detect new cookies and ask whether or not you accept them. If your browser is set to reject cookies, it may be difficult to navigate the website.
WHAT COOKIES DO WE USE AND WHY?
We use the following Google Analytics cookies to measure navigation data:
- _gid – 1 day – Used to distinguish users.
- _ga – 2 years – Used to distinguish users.
Instead, to disable Google Analytics cookies, visit: https://tools.google.com/dlpage/gaoptout
And to disable technical cookies from HubSpot analytics, visit:
For more information on the contents of HubSpot cookies, visit:
METHODS OF PROCESSING
Personal data are processed electronically and kept for no longer than is necessary for the purposes for which they were collected. Processing is done according to the procedures set out in Articles 6, 32 of the GDPR and ensuring appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
In accordance with the principles of lawfulness, purpose limitation, and data minimization, pursuant to art. 5 of the GDPR, personal data are kept for no longer than is necessary for the specific purposes for which they were collected and processed for the performance and fulfillment of contractual purposes, and in compliance with the mandatory time limits prescribed by law (10 years from the termination of the contractual relationship).
ACCESS TO DATA
All personal data provided will be processed exclusively by personnel expressly authorized and informed by the controller, in particular by the following categories of employees:
- Collaborators, as persons in charge and/or internal data processors and/or system administrators
- Third-party companies or freelance professionals in charge of and/or responsible for “external” processing
- IT service providers
- Administrative and accounting service providers
All personal data provided will be shared exclusively with competent persons who are duly appointed to render the services necessary to properly manage the relationship, guaranteeing that the rights of the data subject are safeguarded. Depending on the service provided, they may also be shared with third parties duly appointed as data processors, in particular to:
Public and/or private individuals for whom data sharing is mandatory or necessary in the fulfillment of legal obligations or, in any case, functional to the administration of the relationship (supervisory bodies, INAIL, Labor Inspectorate, insurance companies)
- Constitutional bodies or bodies of constitutional importance
- Consultants and freelancers, also in associated form
- Supervisory authorities
- Professional consultants of the data subject
- Law enforcement authorities
Personal data provided will not be disclosed in any way.
Personal data may be transferred to third countries belonging to the European Union and, therefore, subject to the regulatory obligations set out in the GDPR. Personal data may also be transferred to non-EU third countries, in which case the transfer is guaranteed by standard contractual clauses, EU adequacy decisions, and, wherever necessary, explicit consent from the data subject.
RIGHTS OF THE DATA SUBJECT (GDPR: ARTICLES 15, 16, 17, 18, 19, 20, 21, 22)
RIGHT OF ACCESS BY THE DATA SUBJECT
- The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
- Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
- The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
- The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
RIGHT TO RECTIFICATION
- The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
RIGHT TO ERASURE (‘RIGHT TO BE FORGOTTEN’)
- The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
- the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
- the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
- Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
- Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defense of legal claims.
RIGHT TO RESTRICTION OF PROCESSING
- ) The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
- the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims;
- the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
- ) Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
- ) A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
NOTIFICATION OBLIGATION REGARDING RECTIFICATION OR ERASURE OF PERSONAL DATA OR RESTRICTION OF PROCESSING
- The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.
RIGHT TO DATA PORTABILITY
- The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
– the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
– the processing is carried out by automated means.
- In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
- The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
- The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
RIGHT TO OBJECT
- The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
- Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
- At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
- In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
- Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
PROCESSO DECISIONALE AUTOMATIZZATO RELATIVO ALLE PERSONE FISICHE, COMPRESA LA PROFILAZIONE
- The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
- Paragraph 1 shall not apply if the decision:
- is necessary for entering into, or performance of, a contract between the data subject and a data controller;
- is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
- is based on the data subject’s explicit consent.
- In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
- Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.
PROCEDURE TO EXERCISE DATA SUBJECT’S RIGHTS
Data subjects may exercise the rights listed above via:
Certified letter with return receipt to DEMA SOLUTIONS S.r.l. – Via Antonio Gramsci n°10/12 20900 Monza MB or email to email@example.com.
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