Privacy Policy Statement
This policy statement, pursuant to the obligations under EU Regulation no. 679 of 2016 (“GDPR”).
Premise
This Policy Statement on the Processing of Personal Data (hereinafter, “Policy Statement”) is provided by Colombo Green Industries Srl in compliance with the obligations under EU Regulation no. 679 of 2016 (“GDPR”).
Why does Colombo Green process Customer data?
The Customer’s personal data may be processed for marketing purposes, including by email, market analysis, as well as for statistics and monitoring Customer satisfaction for the purposes of improving the products and services offered and to preserve voluntary quality certification only subsequent to the explicit consent of the Customer.
Which personal data categories does Colombo Green process and how are data collected?
In cases where Colombo Green Industries receives personal information which it does not need, it will delete same or ensure that said data cannot be identified or traced back to the Customer or Data Subject. Colombo Green Industries does not receive personal data from Third Parties.
The personal data provided by the Customers may include but are not limited to:
- contact details, such as: name, email address, telephone (land line and cellphone), billing address;
- tax ID code, VAT reg. no. or other personal identification codes;
- information for payment purposes, such as bank details and invoicing details;
- addresses for residence/offices/sites where services must be performed;
- Customer Satisfaction, i.e., data concerning the satisfaction/opinion of the customer regarding the service received;
- maps and floor plans for the places where the service is performed;
- images of the places and facilities involved in the service.
- data inherent to any infestation;
- GPS coordinates, following the activation of chat services with Colombo Green Industries;
- IP addresses, through the use of cookies in some countries;
- maps and floor plans for the places where the service is performed;
- images of the places and facilities involved in the service.
Legal basis and purpose of processing
- the data subject has expressed consent to the processing of their personal data for one or more specific aims (Marketing);
- the processing is necessary for the performance of a contract of which the data subject is part, or the performance of pre contractual measures implemented at the request of same;
- processing is necessary to fulfil a legal obligation to which the Data Controller is subject;
- processing is necessary to pursue a legitimate interest of the Data Controller or of third parties, provided that the interests, rights, or fundamental liberties of the data subject which required the protection of personal data, especially if said subject is a minor. This hypothesis, includes:
- verification, exercise or protection of one’s own right;
- monitoring of customer satisfaction, for example, for the purposes of ISO 9001 certification (quality) and improvement of service;
- processing of statistics in anonymous form and/or with aggregate data, as required for the general analysis of the business.
The Data Subject’s refusal to provide personal data or to consent to processing
Refusal to provide the necessary data for the performance of the service requested (Art. 13, subsection 2, lett. e of the GDPR).
The collection and processing of specific personal data are needed to complete performance of the services required, as well as to provide the Service and/or supply of the Product required. In the event that the Data Subject refuses to or in any case does not provide personal data indicated as essential for satisfying the request, Colombo Green Industries cannot follow up same, since it is impossible to carry out the processing operations related to same.
Refusal to provide consent to processing of personal data for marketing purposes.
In the event the Data Subject does not consent to the processing of their personal data for marketing purposes, the processing will not take place for these purposes. The Data Subject always has the right to withdraw any consent given and at any time.
The above does NOT impact the provision of the services requests or on the ones for which the Data Subject has already consented, where requested.
In the event the Data Subject has consented and successively withdrawn consent to processing for marketing purposes, Colombo Green Industries will suspend all processing for this activity without this having any adverse consequences or effects for the Data Subject or the services requested.
Data retention time
More specifically:
- Data will be stored solely for the time necessary for the purpose for which they were collected, compliant with the purpose limitation principle, as in article 5, subsection 1, letter e) of the Regulation;
- Data will be stored to comply with the regulatory obligations and to achieve the above aims, in compliance with the principles of indispensability, relevance and not exceeding their purpose;
- Colombo Green Industries may retain some data after the contractual relationship ceases to be in order to comply with regulatory and/or post-contractual obligations, and/or to ascertain, exercise or defend own rights; subsequently, if the above reasons for processing should cease to be, said data will be deleted, destroyed or anonymised;
- customer satisfaction data, however collected, will be retained for a maximum of five years in order to improve and implement services in line with feedback from Customers. The retention period is also defined in compliance with the Customer Satisfaction service provider.
Communication, circulation and transfer of data abroad
As part of the service, the Customers personal data may be forwarded to agents, suppliers, subcontractors and/or partners of Colombo Green Industries, if this is necessary for the provision and supply or services or support for commercial, technical or operational activities or IT system management.
Some personal data can be communicated to other companies in the Colombo Green Industries Group, for the aims stated in point 4.
The parties to which Colombo Green Industries can transfer personal data can in some cases be located in a Third Company to the European Union (non-EU) and therefore, in a country located outside the European Economic Area (EEA), where the GDPR applies. This means that personal data can be transferred to countries not subject to the provisions in this latter. In cases in which personal data are transferred to suppliers outside the EU, such as in case of the use of Microsoft Services, Colombo Green Industries undertakes to implement measures to ensure that personal data continue to be protected and processed in compliance with the provisions of the GDPR.
To guarantee the lawfulness and correctness of personal data processing, Colombo Green Industries has drawn up specific Agreements, including the undertaking for confidentiality, with all suppliers processing personal data on its behalf.
Colombo Green Industries may also disclose personal data to comply with a legal obligation or when required to do so by the competent authorities, i.e. In case this disclosure is otherwise necessary to cooperate with a legal enquiry.
In the case in which Colombo Green Industries is part of extraordinary company operations, such as mergers or acquisitions, Colombo Green Industries may transfer the personal data to a pertinent third party, provided that said third party undertakes to process the aforementioned personal data in compliance with this policy statement and in any case, according to the GDPR.
Security of personal data
Data Subject’s rights
1. a) Confirmation as to whether or not data related to him or her are being processed, as well as the following information:
2. the purpose of processing;
3. the categories of personal data being processed;
4. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular, recipients in third countries or international organisations;
5. when possible, the retention period or, if not possible, the criteria used to identify this period;
6. the existence of the right to request from the Data Controller correction, or erasure of personal data or the limitation of processing data concerning him or her, and to oppose said processing;
7. the right to submit complaint to a supervisory authority;
8. If the data are not collected from the Data Subject, all information available on their origin;
9. The existence of an automated decision-making process and if this is the case, information on the logic at the basis of same, as well as the relevance and consequences of this processing for the Data Subject;
10. the guarantees that the Third Country (non EU) or international organisation provides to protect any data transferred.
11. b) The right to obtain a copy of the personal data being processed. For any copies required by the Data Subject after the first, Colombo Green Industries Srl has the right to charge a reasonable amount for administration, based on the costs sustained. Unless otherwise agreed with the Data Subject, the information will be provided in a commonly used electronic format.
12. c) The right to obtain from the Controller without undue delay, the correction of any imprecise personal data.
13. d) The right to obtain from the Controller, the erasure of personal data concerning him or her without undue delay, for reasons set down in Art. 17 of the GDPR – including, for example, the case in which they are no longer needed for the purposes for which they were collected – under the conditions envisaged by the GDPR, provided that the processing is not required by law or in any case is not justified by any other equally legitimate grounds.
14. e) The right to obtain limits to treatment in the hypothesis stated in Art. 18 of the GDPR, for example, in case the exactness of same is contested, for the period necessary to the Controller for the resulting checks.
15. f) The right to obtain from the Controller, the indication of the recipients to which the requests for any corrections or erasures or limitations to processing carried out, unless it is impossible or requires a disproportionate effort.
16. g) The right of data portability, in the cases envisaged in Art. 20 of the GDPR, with the methods and in the forms required by this latter.
17. The right to submit complaint to a supervisory authority.
Connection to other websites
Availability of the privacy policy and changes to same
Data Controller and Contacts
For more information concerning the privacy policy of Colombo Green Industries regarding the processing of personal data as well as to exercise the rights above envisaged by the GDPR, please write to the dedicated email address: info@colombogreen.it.