Policy on personal data processing

Pursuant to the art. 13 of EU Regulation n. 2016/679 and concerning the data provided by customers or collected from the Company during the contractual and pre-contractual relationship, we inform our customers that data will be used with the terms and for the purposes described in the following paragraphs.

Data Controller (art.13 co.1 lett.a)

The Data Controller is ERGA, having its registered office in Siracusa, via Monsignor G. Carabelli 33, CF e P.IVA 01821410899, with whom you stipulated or will stipulate a service contract (hereinafter “Company”). The Company can be contacted on the website www.secretsi.it or via e-mail at info@secretsi.it.

Purpose of the processing and legal ground (art.13 co.1 lett.c)

We use the personal data that we collect about you only for specific purposes to comply with a legal or contractual obligation:

- To comply with legal obligations in the field of taxation and accounting

-  to perform the contract and the provision of the services

-  Payment Management

-  After-sales assistance

-  To contact you or send you messages

-  Clients invoice history

 - Where it is necessary for Company’s legitimate interest or that of third parties

For these purposes, the provision of the data is necessary for a proper management of the relationship and data processing is required to implement the above-mentioned purposes. The Data Controller informs you that any failure to communicate, or incorrect communication of, any of the mandatory information may make it impossible for the Data Controller to guarantee the adequacy of the processing itself.

Your personal data may also, with your consent, be used for the following purposes:

- Newsletter

- Commercial information, market research and advertising of our products and services.

The consent for the abovementioned purposes is optional. With this specific consent, you authorize ERGA to process the data of the contract (Name, Surname, phone number, email address etc.) that you provided of your own accord through the channels supplied by ERGA and the data provided during services offered by ERGA and that provided in order to receive commercial information through automated communication channels (SMS, e-mail, etc) and traditional channels (phone call with operators, post) concerning promotions and offers of ERGA’ services and products. Thanks to this consent you will receive special offers and exclusive discount. You have the right to withdraw your consent at any time, even after the termination of the contract, on the website or through the other channels provided by ERGA.

Processing modality and data retention (art.13 co.2 lett.a)

Personal data will be handled on paper, by electronic and automated means and databases, in order to guarantee security and confidentiality in compliance with principles of fairness, lawfulness and transparency.

The data provided to us or collected by ERGA may be also processed by subjects entitled to access personal data in accordance with the applicable law.

Your personal data will be archived only for the time necessary to fulfil the above-mentioned purposes, relevantly and not excessively.

Recipients (art. 13 co.1 lett.e)

In order to perform the contract with you, to comply with legal obligations and for its legitimate interest, ERGA can communicate your data to the following categories:

- to companies or third parties that provide outsourced activities on behalf of the Data Controller;

- to its clients, public or private, should the communication be necessary to perform the activities related to the contract;

- to public subjects, in order to comply with legal obligations;

- to subjects that perform data entry and archiving;

- to subjects that offer services for the management of the information system of ERGA and administrative, accounting and legal services;

- to subjects that manage payment services.

The subjects of the categories listed above operate as autonomous data controller or as processor or person in charge of the processing, expressly nominated by ERGA.

If necessary, also the employees/consultants of ERGA nominated as processor or person in charge of the data processing know your data.

The complete list of the Data Processors is available upon request.

Within the Company, your data will be processed by the employees indicated in the above-mentioned list and they operate as person in charge of the processing under the direct authority of the Data Processor.

Transfer of data (art.13 co.1 lett.f)

Your personal data are stored on server located inside the European Union. The Company, if necessary, can move servers outside the EU. In that case, the Company guarantees that the transfer of data is in compliance with the applicable law, also providing for standard clauses approved by European Commission.

Right of the subject

At any time, you have the right to request access to your personal data, to request to correct or delete data or to object to the processing. You have the right to request to restrict the processing of your personal data in the cases provided for by art.18 of the Regulation, or to obtain your personal data in a structured and commonly format and legible from automatic device.

You can contact the Company via e-mail at info@secretsi.it and in the same way you can withdraw your consent at any time.

You also have the right to lodge a complaint to the supervisory authority (Granting Authority for the Treatment of the Personal Data) pursuant to the art.77 of the Regulation, if you consider the processing contrary to the current regulation.