1. DATA CONTROLLER

1.1     KENFITT SRL in its capacity of Data Controller (here by referred to as “KENFITT S.r.l.”) is pleased to inform you that the Legislative Decree n. 196/2003 (hereby referred to as “Privacy Code”) and the Regulation (EU) n. 679/2016 (hereby referred to as “GDPR”) govern the protection of personal data in all relevant processing activities.
Any processing of personal data by KENFITT S.r.l. is strictly compliant with the principles of correctness, lawfulness, transparency and necessity, in order to provide you with an adequate protection to your rights.
To this end, and pursuant to art. 13 of the Privacy Code and art. 13 of the GDPR, we provide you with the following information.

2. OBJECT OF THE PROCESSING

The data processing, as defined in the Privacy Code and in the GDPR, will be conducted on your personal data, already in our possession or that will be in possession of KENFITT S.r.l. in the future by virtue of the commercial relationships in place.

3. PURPOSE OF THE PROCESSING

The processing of Your data has the following purposes:

1. carrying administrative and management activity for the fulfillment of the relevant tax, accounting and any other obligation provided by the current legislation;
2. fulfillment of pre-contractual and contractual obligations set forth by any relevant agreement;
3. marketing activity: only and exclusively with your specific consent, for the purposes of market research, economic and statistical analysis, sending advertising/information/promotion material, sending of newsletters, also in relation to programs and promotions, including online, communications, development and maintenance of business relationships.

The transfer of data for the purposes of clause 3, lett. a), b) is mandatory and the related processing, pursuant to the current legislation, is authorized even without consent of the data subject.
The lack of transfer of the data will procure the impossibility to comply with our obligations arising out in connection to contractual and pre-contractual relations.
The data transfer for the purposes of clause 3, let. c) is discretional and shall be authorized pursuant to the modalities provided by art. 23 and 130 of the Privacy Code and art. 7 of the GDPR.
Ordinary means (i.e. mail delivery, telephone calls), automatized means (i.e. automatized telephone calls) and any related means (i.e. fax, e-mail, short messages, newsletter) can be used for the delivery of the marketing related notices.
Should you be in our list of clients, we reserve the right to send you commercial notice for the delivery of services similar to the one already offered, provided however your right to disagree (art. 130 c.4 Privacy Code).

4. PROCESSING MODALITIES

The data processing shall be conducted pursuant to art. 4 n.2) of GDPR, through the following operations: collection, recording, mining, comparison, use, exchange, blocking, communication, cancellation and destruction of data.
Your data will be subject to a paper and electric/automated processing.
Your data will be retained from the date of the relevant receipt/update for a period appropriate for the purpose of the processing, as indicated in clause 3, and in any case not longer than 10 years starting from the termination of the relationship for the purposes of lett. a) and b) and until withdrawal of consent or until exercise of the right of objection for the purposes of lett. c).

5. DISCLOSURE AND COMMUNICATION OF DATA

Your data will not be disclosed to the public being understood, however, that any relevant disclosure of the latter to third parties, amongst other commercial partners, consultants, banks, credit institution and insurance, financial, factoring, leasing, services, management, debt collection, audit companies, public Entities, audit and supervisory body, is authorized in order to comply with the obligations provided by the relevant laws, regulation, European provisions and for aspects related to the management and fulfilment of the obligations related to the contractual relationships in place.
Your data will be processed by the following subjects:

• • Employees of companies of KENFITT S.r.l., acting as authorized persons to the processing of the data by virtue of the job tasks assigned to them and properly trained.
  • External data processors pursuant to art. 29 of the Privacy Code and art. 28 of the GDPR.

The list of external data processors is available at the registered office of the Company.
For the purposes of this notice, your data can be disclosed abroad, within and outside the European Union, in compliance with the rights and the warranties provided by the current regulations, subject to the existence of provision within the relevant country of an adequate level of data protection, pursuant to the GDPR.

6. RIGHTS OF THE DATA SUBJECT

In your quality of data subject, you are entitled to at any time:

1. To request the access to your personal data;
2. To request the related amendment in case incorrectness;
3. To request the cancellation of the data;
4. To request the limitation of the processing;
5. To exercise the right to oppose the processing of your data, upon recurrence of the requested requirements;
6. To exercise the right to data portability (consisting in receiving the transferred data in a structured form of common usage and readable from any device).

For anything not expressly provided in the present clauses, please refer to the current legislation on Privacy and specifically to art. 7 of the Privacy Code and art. 15, 16, 17, 18, 20 and 21 of the GDPR.
You also have the right to lodge a complaint with the Data Protection Supervisory Authority of Piazza di Montecitorio n.121, 00186 Rome.

7. WITHDRAWAL OF CONSENT

You have the right to withdraw your consent, at any time, without any prejudice to:

• • the lawfulness of the processing, based on the consent given before the revocation;
  • further processing of the same data based on other legal bases such as, for example, contractual or legal obligations.

For further information about this policy or any privacy issues, or if you wish to exercise your rights or revoke your consent, please contact privacy@kenfitt.it.