We would like to inform you that Regulation (EU) 2016/679 (“European Regulation on the Protection of Personal Data”) provides for the protection of persons and other data subjects with regard to the processing of personal data. According to this regulation, this processing shall be based on the principles of fairness, lawfulness and transparency in order to protect your privacy and rights. In accordance with article 13 of Regulation EU 2016/679, therefore, we inform you that:
Purpose of the processing:
MASTER SpA has been operating in the home automation market since 1992, offering solutions to satisfy any automated system requirements for outdoor awnings, roller shutters and blinds.
The data you provide will be used with regard to the supply of products and services relating to contractual requirements and the consequent fulfillment of legal and tax obligations, as well as to allow effective management of financial, commercial and operational relationships, for purposes which are strictly connected with and instrumental to establishing relationships between customers and suppliers (for example, to obtain information prior to the completion of a contract, and to fulfill the terms of the contract once the work has been completed, etc..). The data will be processed for the entire duration of the contract and subsequently (5 years after expiry of the contractual relationship or the performance of services) also for the fulfillment of legal obligations including those for administrative and commercial purposes.
Method of processing:
The data is processed using tools and protocols that guarantee security and confidentiality; data may be processed in both hard copy and electronic form in compliance with the provisions of Regulation (EU) 2016/679 relating to the provision of appropriate security measures.
Obligation or right to provide data and consequence in the event of refusal
Providing data is mandatory for the first consent, which is only related to essential data required to confirm estimates, offers, agreements and commercial contracts; the refusal, even partial, to provide such data could result in the agreement and/or contract either not being carried out or only being partially carried out.
Providing data is optional for the second consent, which is related to sending commercial communications regarding updates on products and services of MASTER SpA.
Processing of personal data for business profiling purposes
MASTER SpA may process so-called “profiling” data for marketing purposes and to improve the services it provides. For this type of processing, and for reasons of completeness, we refer to the definition in Article 4, paragraph 1, n°4 of Regulation (EU) 2016/679. Profiling may be about ‘individual’ personal data or ‘aggregate’ personal data obtained from identified individual personal details. In order to clarify what profiling means, we refer to the following parameters as examples:
- Data is structured and coordinated according to pre-defined regularly established parameters, according to business requirements (regardless of any marketing, contractual or administrative purposes, etc. …)
- Only after profiling (i.e. Organizing according to pre-defined parameters) is it possible to deduce additional details referring to each data subject (i.e. the “profile”, for example, market segment, active communication and marketing services, business acumen, etc. …), which would not be identified simply from the nature of the data whether considered individually or separately.
As for the obligations on the part of MASTER® SpA to provide, – pursuant to Article 13, paragraph 2, letter f) of the Regulation –, information on the logic of profiling as well as the importance and consequences of such processing, we would like to further clarify that
The fundamental elements of profiling will be:
- The pre-definition of parameters for the structuring of data individually considered;
- The comparison, cross-referencing and linking of this data to other data and the comparative analysis carried out on the basis of pre-defined parameters, including by means of automated processes;
- The creation of a profile through the above activities which enables you to identify the profile of a client company.
The above processes are referred to in the following as “Profiling”.
In order to proceed with Profiling, it is mandatory to obtain prior, specific, express, documented and entirely voluntary consent. The provision of personal data to MASTER SpA and the provision of consent to the processing for profiling purposes and for the purposes and in the manner described above are entirely voluntary as well as easily rescindable even after the service has been provided.
The data subjected to Profiling and the relevant authorized profiles will not be circulated.
Sharing data with third countries
The Data Controller will not share your personal data with a third country or an international organization.
Processing of personal data of children
No data will be collected and processed from persons under 18 years of age.
Communication of data to third parties:
MASTER SpA does not “disseminate” the data collected and authorized, i.e. it will neither communicate it to unknown parties nor will it make it available to them and/or allow them to consult it.
MASTER SpA may communicate the data collected and authorized to one or more specific individuals or companies, in the following terms:
- Within MASTER SpA persons responsible for processing the above data and, in particular, the employees of the Administration/Secretariat/Customer Services/Commercial Office and Technical staff.
- Individuals who can access the data under the provisions of the law, regulations or EU legislation, within the limits provided for by these requirements (established public bodies).
- Individuals who need access to this data for purposes that are connected to the relationship between you and MASTER SpA, within the restrictions required to carry out any additional tasks entrusted to them (for example: credit institutions, forwarding agents, etc..)
- Persons advising MASTER SpA, within the restrictions required to carry out their duties at MASTER® SpA, after our letter of appointment, who are required to respect both the confidentiality and security of personal data processing (e.g. accountant, employment consultant)
Exercise of rights by the data subject
Pursuant to articles 13, paragraph 2, letters (b) and (d), 15, 18, 19 and 21 of the Regulation, we inform the data subject that:
(a) he/she shall have the right to request MASTER SpA, as data controller, to give him/her access to his/her personal data, to amend or erase such data or to limit its processing or to object to its processing in the cases provided for;
- b) he/she shall have the right to lodge a complaint with the Guarantor for the protection of personal data, following the procedures and indications published on the official website of the Authority on https://www.garanteprivacy.it/en/home_en
(c) any amendment, erasure or limitation of the processing carried out at the request of the data subject, unless this proves impossible or involves a disproportionate effort, – will be communicated by MASTER SpA to each of the recipients to whom the personal data has been disclosed. MASTER SpA shall inform the data subject about the recipients of the data if requested.
The exercise of these rights is not subject to any restriction and is free of charge. For convenience, articles 15 to 23 of the Regulation are available at this link: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0679
Data Controller and Data Processor:
The Data Controller is MASTER SpA, Via Sandro Pertini, 3 – 30030 Martellago (VE) – Italy, Tel. +39 041 64 0187, P.I. IT 03014380277 as legal representative.
Your Data Processor is Mr. Renato De Pazzi, e-mail: firstname.lastname@example.org