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PRIVACY POLICY RENDERED PURSUANT TO ART. 13 OF THE REGULATION (EU) 2016/679 AND TO THE E-PRIVACY DIRECTIVE 2009/136/EC AND SUBSEQUENT AMENDMENTS

Dear Data Subject,
we provide you some information hereunder that it is necessary to bring to your attention, not only to comply with the obligations referred to in the Regulation (EU) 2016/679, but also because the transparency and the fairness towards our customers are fundamental parts of our activity.

The Controller of your personal data is Sweden & Martina S.p.A., responsible to you for the legitimate and proper use of  your personal data and that you may contact for any information or request at the following addresses:

Sweden & Martina Spa
Via Veneto, 10, 35020 Due Carrare PD, IT   
Contacts and addresses:  
Phone +39.049.9124300
E-Mail privacy@sweden-martina.com
Web www.sweden-martina.com
 
Data Protection Officer (DPO):
dpo@ sweden-martina.com


1. PRIVACY POLICY - CUSTOMER PRIVACY POLICY

Intended use of data
Your personal data are collected and processed for the intended purposes listed hereunder together with the applicable legal basis:

Processing: Sale
Purpose Processed data Legal Basis Duration
Promotional activities Name, address or other personally identifiable information; Contact details (telephone number, email, etc.) Legitimate interest of the controller to promote goods and services 10 years from the performance year
Supply of goods and services Name, address or other personally identifiable information; Contact details (telephone number, email, etc.) Pre-contractual, contract 10 years from the performance year
Recipients: Your data will not be disclosed to any recipient.
 
Purpose Processed data Legal Basis Duration
Customer Relationship Management Tax code and other personal identification numbers; Name, address or other personally identifiable information; Contact details (telephone number, email, etc.) Contract 10 years from the termination year of the last contract
Recipients: Your data may be disclosed to consultants and freelance professionals as natural persons or associated; Banks and credit institutions; Companies and businesses;


Processing: Reception
Purpose Processed data Legal Basis Duration
Tracking of the people who
enter company premises
Name, address or other personally identifiable information;
Contact details (telephone number, email, etc.); Stated profession
Legitimate interest of the controller 1 year from the year of data acquisition
Filtering of telephone calls Name, address or other personally identifiable information;
Contact details (telephone number, email, etc.); Stated profession
Legitimate interest of the controller 1 year from the year of data acquisition
Recipients: Your data will not be disclosed to any recipient.


Processing: Accounting
Purpose Processed data Legal Basis Duration
Keeping of financial records Tax code and other personal identification numbers; Name, address or other personally identifiable information; Economic, commercial, financial, insurance activities Legal obligation 10 years from the relevant accounting period
Tax obligations Tax code and other personal identification numbers; Name, address or other personally identifiable information; Economic, commercial, financial, insurance activities Legal obligation 10 years from the relevant accounting period
Categories of recipients: Your data may be disclosed to consultants and/or freelance professionals as natural persons or associated;


Processing: Billing and Transport Document
Purpose Processed data Legal Basis Duration
Delivery of goods Name, address or other personally identifiable information Contract 10 years from the performance year
Recipients: Your data will not be disclosed to any recipient


Processing: Management Control
Purpose Processed data Legal Basis Duration
Internal control system Tax code and other personal identification numbers;
Name, address or other personally identifiable information; Economic, commercial, financial, and insurance activities;
Work (present, previous occupation, curriculum vitae, etc.); Position in the company
Legitimate interest of the controller in the analytical verification of economic and financial management 10 years from the performance year
Recipients: Your data will not be disclosed to any recipient


Processing: Quality Control
Purpose Processed data Legal Basis Duration
Quality control of goods and services Tax code and other personal identification numbers; Name, address or other personally identifiable information; Product quality certificates Legitimate interest of the controller to check the provided and received goods and services 10 years from the performance year
Recipients: Your data may be disclosed to health organizations, medical and paramedical staff; Other public authorities.


Processing: Customer Service
Purpose Processed data Legal Basis Duration
Measurement of customer satisfaction Name, address or other personally identifiable information; tax code and other personal identification numbers; Data on behaviour, users', consumers', contributors', etc. profiles; Contact details (telephone number, email, etc.); Contract 10 years from the termination year of the last contract
Technical assistance to customers Name, address or other personally identifiable information; tax code and other personal identification numbers; Data on behaviour, users', consumers', contributors', etc. profiles; Contact details (telephone number, email, etc.); Contract 10 years from the termination year of the last contract
Recipients: Your data will not be disclosed to any recipient


Processing: Marketing and assignment to a Partner
Purpose Processed data Legal Basis Duration
Marketing (market analysis and surveys) Tax code and other personal identification numbers; Name, address or other personally identifiable information; Economic, commercial, financial, insurance activities; Contact details (telephone number, email, etc.) Consent Until withdrawal of consent. The data will be stored for 10 years from the year of withdrawal.
Sending of information and/or advertising material also via telephone or  internet Tax code and other personal identification numbers; Name, address or other personally identifiable information; Economic, commercial, financial, insurance activities; Contact details (telephone number, email, etc.) Consent Until withdrawal of consent. The data will be stored for 10 years from the year of withdrawal.

Recipients: Your data may be disclosed to social security and welfare entities, banking institutions, freelance professionals also associated, companies or businesses. Disclosure to some of these entities may be carried out only in case of a contractual and/or legal obligation.


Processing: Online Pubblication
Purpose Processed data Legal Basis Duration
Online publication in a specific special area inside portals related to the controller of the customer's contact data   Name, tax code, address, other contact details Consent Until withdrawal of consent. The data will be stored for 10 years from the year of withdrawal
Recipients: the data will be subject to dissemination.


Processing: Video surveillance
Purpose Processed data Legal Basis Duration
Protection of company
assets
Images;
Video recordings
Legitimate interest of the controller 7 days
Safety of persons Images;
Video recordings
Legitimate interest of the controller 7 days
Perimeter security,
against trespassing and
damage to the property
Images;
Video recordings
Legitimate interest of the controller 7 days

Categories of recipients: Your data will not be disclosed to any recipient, except in case of need.


Processing: Activities planning and checking
Purpose Processed data Legal Basis Duration
Activities planning and checking NIN or any other personal identification number;
Name, address, or any other identification element;
Economic, commercial, financial, insurance activities;
Role in the company;
Quality/professional  certificates;
Quality certificates of the products
Legitimate interest of the controller 10 years from the performance year

Categories of recipients: Your data will not be disclosed to any recipient


Besides this information, in order to assure that your data is processed in the most fair and transparent manner, you should be aware that:
  • Except for the purposes based on consent, the provision of your data is compulsory, otherwise it will not be possible to supply the good or to deliver the requested service
  • you have the right to request the data controller to be given access to your personal data and rectification or erasure of the same or the restriction of the processing that concerns you or to object to their processing
  • if you have given your consent to one or more specific uses, you have the right to withdraw such consent anytime
  • you have the right to lodge a complaint with the following Supervisory Authority: Garante per la protezione dei dati personali (Italian Data Protection Authority)
  • the data will be processed by full automated, semi-automated and non-automated means
Where required by this privacy policy you have the legal obligation to provide your data otherwise you are subject to sanctions as required by law

2. PRIVACY POLICY FOR MARKETING INITIATIVES
Your personal data are collected and processed for the intended purposes listed hereunder together with the applicable legal basis:

Processing: Marketing and assignment to a Partner
Purpose Processed data Legal Basis Duration
Marketing (market analysis and surveys) Tax code and other personal identification numbers; Name, address or other personally identifiable information; Economic, commercial, financial, insurance activities; Contact details (telephone number, email, etc.) Consent Until withdrawal of consent. The data will be stored for 10 years from the year of withdrawal
Sending of information and/or advertising material also via telephone or  internet Tax code and other personal identification numbers; Name, address or other personally identifiable information; Economic, commercial, financial, insurance activities; Contact details (telephone number, email, etc.) Consent Until withdrawal of consent. The data will be stored for 10 years from the year of withdrawal
Recipients: Your data may be disclosed to social security and welfare entities, banking institutions, freelance professionals also associated, companies or businesses. Disclosure to some of these entities may be carried out only in case of a contractual and/or legal obligation.

Besides this information, in order to assure that your data is processed in the most fair and transparent manner, you should be aware that:
  • Except for the purposes based on consent, the provision of your data is compulsory, otherwise it will not be possible to supply the good or to deliver the requested service
  • you have the right to request the data controller to be given access to your personal data and rectification or erasure of the same or the restriction of the processing that concerns you or to object to their processing
  • if you have given your consent to one or more specific uses, you have the right to withdraw such consent anytime
  • you have the right to lodge a complaint with the following Supervisory Authority: Garante per la protezione dei dati personali (Italian Data Protection Authority)
  • the data will be processed by full automated, semi-automated and non-automated means
Where required by this privacy policy you have the legal obligation to provide your data otherwise you are subject to sanctions as required by law

3. PARTICIPATION IN COURSES AND EVENTS-COURSES AND EVENTS PRIVACY POLICY
Your personal data are collected and processed for the intended purposes listed hereunder together with the applicable legal basis:

Processing: Accounting
Purpose Processed data Legal Basis Duration
Tax obligations Tax code and other personal identification numbers; Name, address or other personally identifiable information; Economic, commercial, financial, insurance activities Legal obligation 10 years from the relevant accounting period
Categories of recipients: Your data may be disclosed to consultants and/or freelance professionals as natural persons or associated

Processing: Customer Relationship Management
Purpose Processed data Legal Basis Duration
Customer Relationship Management Tax code and other personal identification numbers; Name, address or other personally identifiable information; Contact details (telephone number, email, etc.) Contract 10 years from the termination year of the last contract
Recipients: Your data may be disclosed to consultants and freelance professionals as natural persons or associated; Banks and credit institutions; Companies and businesses;

Processing: Marketing
Purpose Processed data Legal Basis Duration
Marketing (market analysis and surveys) Tax code and other personal identification numbers; Name, address or other personally identifiable information; Economic, commercial, financial, insurance activities; Contact details (telephone number, email, etc.) Consent Until withdrawal of consent. The data will be stored for 10 years from the year of withdrawal.
Sending of informational and/or advertising on training courses and products material also via telephone or  internet Tax code and other personal identification numbers; Name, address or other personally identifiable information; Economic, commercial, financial, insurance activities; Contact details (telephone number, email, etc.) Consent Until withdrawal of consent. The data will be stored for 10 years from the year of withdrawal.
Recipients: Your data may be disclosed to social security and welfare entities, banking institutions, freelance professionals also associated, companies or businesses. Disclosure to some of these entities may be carried out only in case of a contractual and/or legal obligation.

Besides this information, in order to assure that your data is processed in the most fair and transparent manner, you should be aware that:
  • Except for the purposes based on consent, the provision of your data is compulsory, otherwise it will not be possible to supply the good or to deliver the requested service
  • you have the right to request the data controller to be given access to your personal data and rectification or erasure of the same or the restriction of the processing that concerns you or to object to their processing
  • if you have given your consent to one or more specific purposes, you have the right to withdraw such consent anytime
  • you have the right to lodge a complaint with the following Supervisory Authority: Garante per la protezione dei dati personali (Italian Data Protection Authority)
  • the data will be processed by full automated, semi-automated and nonautomated means





4. STAFF SEARCH

Processing
: Staff Search
Purpose Processed data Legal Basis Duration
Search of the staff to be hired by the company Tax code and other personal identification numbers; Name, address or other personally identifiable information;  Work (present, previous occupation, curriculum vitae, etc.);  Education and knowledge;  Professional certifications; E-mail address; Province of residence; Stated profession; Topics of interest; Sex m/f; Work Pre-contractual 2 years from the year of data acquisition

Recipients: Your data could be disclosed to other societies of the Group Sweden & Martina.

Processing: Staff Selection
Purpose Processed data Legal Basis Duration
Staff recruitment and selection Tax code and other personal identification numbers; Data on criminal convictions and offences;  Work (present, previous occupation, curriculum vitae, etc.);  Education and knowledge; Fitness for work; E-mail address; Province of residence; Stated profession; Topics of interest; Sex m/f; Work Pre-contractual 2 years from the the year of data acquisition

Recipients: Your data could be disclosed to other societies of the Group Sweden & Martina.


Processing: Activity planning and control
Purpose Processed data Legal Basis Duration
Activity planning and control Tax code and other personal identification numbers;
Full name, surname, personal address, shipping address, other data of personal identification;
Economic, commercial, financial, insurance activities;
Role covered in the company;
Professional quality certificates;
Product quality certificates;
Legitimate interest of the owner 10 years from the the year of data acquisition

Recipients: Your data could be disclosed to other societies of the Group Sweden & Martina.

Processing: Staff Evaluation
Purpose Processed data Legal Basis Duration
Staff performance evaluation Tax code and other personal identification numbers;
Full name, surname, personal address, shipping address, other data of personal identification;
 Work (present, previous occupation, curriculum vitae, etc.);  Education and knowledge;
Role covered in the company;
Contractual 10 years from the year of termination of the contract

Recipients: Your data could be disclosed to other societies of the Group Sweden & Martina.

Processing: Generic Training
Purpose Processed data Legal Basis Duration
Staff training Tax code and other personal identification numbers;
Full name, surname, personal address, shipping address, other data of personal identification;
 Work (present, previous occupation, curriculum vitae, etc.);  Education and knowledge;
Role covered in the company; Fitness for work;
Professional quality certificates;
Legitimate interest of the owner 10 years from the year of termination of the contract

Recipients: Individual or associated consultants and freelancers (Consultants or professionals who practice specific personnel training activities), Companies and enterprises (Companies or organizations that practice specific personnel training activities).

Processing: Video surveillance
Purpose Processed data Legal Basis Duration
Heritage protection Images;
Video recordings
Legitimate interest of the owner 7 Days
People safety Images; Legitimate interest of the owner 7 Days
Perimeter security, against intrusions and property damage Video recordings Legitimate interest of the owner 7 Days

Recipients: Your data will not be disclosed to any recipient, except in cases of necessity.
 
Duration: In addition to the time necessary for the maturity of the statute of limitations in relation to mutual rights


CHANGES TO THIS PRIVACY POLICY
The Data Controller reserves the right to make changes to this privacy policy at any time, notifying the interested parties. In case of non-acceptance of the changes made to this privacy policy, the interested party may request the Data Controller to remove their Personal Data.
Unless otherwise specified.

Besides this information, in order to assure that your data is processed in the most fair and transparent manner, you should be aware that:
  • Except for the purposes based on consent, the provision of your data is compulsory, otherwise it will not be possible to supply the good or to deliver the requested service
  • you have the right to request the data controller to be given access to your personal data and rectification or erasure of the same or the restriction of the processing that concerns you or to object to their processing
  • if you have given your consent to one or more specific uses, you have the right to withdraw such consent anytime
  • you have the right to lodge a complaint with the following Supervisory Authority: Garante per la protezione dei dati personali (Italian Data Protection Authority)
  • the data will be processed by full automated, semi-automated and non-automated means

Where required by this privacy policy you have the legal obligation to provide your data otherwise you are subject to sanctions as required by law

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