Information for the data subject on the processing and protection of personal data – Privacy policy
Dear User, this Information on the processing of personal data for the Data Subject is provided for the protection of privacy in compliance with the legislation on the protection of personal data (EU Regulation no. 2016/679 GDPR, Legislative Decree no. 196/2003 Privacy Code and Provisions of the Italian Data Protection Authority GDPD).
1. Identity and contact details of the data controller
The Data Controller is Agricola Borduito Società Semplice Agricola (VAT no. 08104770725) with headquarters in Via Corato 193 – 76123 Andria, BA, Telephone +39 328 478 5806 (hereinafter, also “Borduito”); Hereinafter and for brevity, the Controller, having as its sole point of contact the following e-mail: info@borduito.com
2. Purposes, legal bases of the processing and communication of personal data
The personal data of users uploaded to the contact form and for registration to the newsletter service (identifying and common personal data: name, surname, e-mail, city, telephone) are managed for specific processing purposes (the purpose is the objective for which the personal data are processed) as described below:
• Registration in the general database
PURPOSE OF THE PROCESSING OF PERSONAL DATA: the purpose of the correct and complete execution of the registration in the company’s general database present in the reserved area of Borduito.com
LEGAL BASIS: the processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures.
The communication of data is mandatory; otherwise, the service cannot be provided.
• Subscription to the newsletter and marketing activities (DEM)
PURPOSE OF THE PROCESSING OF PERSONAL DATA: in order to receive information on scientific dissemination activities on IT topics and other related subjects.
LEGAL BASIS: the processing is necessary for the pursuit of the legitimate interest of the Data Controller regarding information and the dissemination of information concerning the services offered, without prevailing over the interests or fundamental rights and freedoms of the data subjects who have the right to the protection of personal data, after considering the balance between the interests of the Controller and the rights and freedoms of the Data Subjects.
The Data Subject may legitimately exercise their right to object to such processing at any time.
The communication of data is not mandatory, but without the provision of data, it will not be possible to provide the newsletter/marketing service.
• Marketing Activities (Promotional)
PURPOSE OF THE PROCESSING OF PERSONAL DATA: in order to receive information from the Controller regarding promotions and for the direct sale of products and services via e-mail, paper mail, and operator-assisted telephone calls.
LEGAL BASIS: the processing is based on the consent provided for this specific purpose and until its withdrawal. The communication of data is not mandatory, but without the provision of data, it will not be possible to provide the newsletter/marketing service. The processing will involve identifying personal data (e.g., name, surname, e-mail address, mobile number, and address) and at any time the user may verify and modify or terminate active services or request additional ones.
3. Dissemination and recipients of personal data
The data will be disseminated, but only through the highlighted channels (the Controller’s website, dedicated social pages e.g., Facebook, Instagram, LinkedIn, in print and digital newspapers, leaflets, brochures, and information booklets) and communicated to Partners necessary for the provision of the service: Subjects within the Company specifically authorized who carry out activities connected and instrumental to the management of the requested services; Subjects who provide services for the management of the information system and telecommunications networks, including e-mail, newsletters, and website management, and third parties who collaborate with the Controller for direct marketing activities.
4. Data retention period and criteria used for its determination
Users’ personal data will be kept as long as the user account remains active; in compliance with the principles of proportionality and necessity, personal data will be kept in a form that allows the identification of data subjects for a period of time not exceeding the achievement of the purposes for which they are processed, namely taking into account: the need to continue to store users’ personal data to fulfill requests and to provide the agreed services (contractual obligations) and for which consent has been expressed (Partner marketing) and to comply with current regulations (regulatory obligations).
5. Rights of the data subject and the right to lodge a complaint with the supervisory authority
The Data Subject may send a communication to the Data Controller at the e-mail address info@borduito.com to exercise the following rights:
– to withdraw consent, where provided;
– to access personal data to obtain all information and copies of any processing of personal data;
– to the rectification of personal data;
– to the erasure (so-called right to be forgotten) of personal data;
– to the restriction of processing of personal data;
– to object to the processing of personal data and to data portability;
– to lodge a complaint with the Italian Data Protection Authority and/or another Supervisory Authority, if they believe that their rights have been violated by the Controller and/or a third party.
6. Methods of processing personal data
Users’ personal data are processed through electronic databases and paper archives involving authorized external subjects such as Data Processors (Partners and categories of recipients of personal data). Processing for marketing purposes will take place via e-mail, paper mail, or operator-assisted telephone calls. Decision-making processes based on automated processing, including profiling, are not used.
7. Place of processing and transfer of data outside the EU
Users’ personal data are processed at the headquarters of the Data Controller and at the authorized Data Processors, stored on servers within the territory of the European Union. The Controller does not intend to transfer personal data to territories outside the EU.
8. Information to be provided where data are obtained from other data controllers (Art. 14 GDPR)
With reference to Your Data, You have the right to ask the Joint Controllers, in the manner indicated by the Regulation, for:
• access in the cases provided for;
• the rectification of inaccurate Data and the integration of incomplete Data;
• the erasure of Data for the reasons provided for, such as when they are no longer necessary for the purposes indicated above or are not processed in compliance with the Regulation;
• the restriction of processing for the hypotheses provided for, such as in the event that the accuracy of the Data is contested and its correctness needs to be verified;
• portability, i.e., the right to receive, in the cases provided for, the Data in a structured, commonly used, and machine-readable format and to transmit said Data to another data controller;
• objection to processing, in the cases provided for. We remind you that the sending of newsletters can be interrupted at any time by selecting the “unsubscribe” option at the bottom of each newsletter received. From that moment on, you will no longer receive newsletters from the Joint Controllers. The newsletter communication platforms will nonetheless maintain a list of unsubscribed users to avoid being able to force re-insertion into the newsletter service; should you wish to be permanently deleted from this list as well, we invite you to contact the Company, according to the methods indicated in point 9. below, which will proceed with manual deletion.
9. Procedures for exercising rights
We inform you that you may exercise the rights referred to in point 8. above through the following methods:
• by writing to the Data Controller, for the attention of the Privacy Office;
• by sending an e-mail to the individual addresses of the Data Controller: info@borduito.com; The deadline for the response is one (1) month, extendable by two (2) months in case of particular complexity; in these cases, the Data Controller shall in any case provide at least an interlocutory communication within one (1) month. The exercise of rights is, in principle, free of charge. The Data Controller nevertheless reserves the right to request a contribution in the case of manifestly unfounded or excessive (including repetitive) requests. The Data Controller also reserves the right to request information necessary for the identification of the applicant.
10. Complaint
In the event that you believe the processing of Data violates the provisions contained in the Regulation, you have the right to lodge a complaint with the Data Protection Authority or, alternatively, to file an appeal with the competent judicial Authority.
11. Transfer of data abroad
Your Data will be stored at the headquarters of the Data Controller and on servers located in the European Union. For strictly operational needs connected with the management of marketing services, your identifying data will also be communicated to suppliers in third countries. The transfer to non-EU countries, in addition to cases where this is guaranteed by adequacy decisions of the European Commission, will be carried out in such a way as to provide appropriate and suitable guarantees pursuant to Articles 46, 47, or 49 of the Regulation.
12. Protection of minors
By internal company policy, the Data Controller does not manage data of minors under 14 years of age. The Data Controller will in no way be responsible for any untruthful statements that may be provided by the minor during the provision of personal data. Should the falsity of the statements made by the minor be ascertained, the Data Controller will proceed with the immediate deletion of any personal data referable to them.
