Drafted in accordance with Legislative Decree no. 196 dated 30 June 2003
Policy for the processing of personal data
In accordance with and for the purposes of Article 13 of Legislative Decree no. 196 dated 30 June 2003, the Company PVS Services Italia S.r.l. (hereinafter, PVS) is providing you with all the necessary information relating to the purposes and methods of processing your personal data, disclosure and dissemination of the same, and the nature and granting of the data in our possession.
1. Purposes of the processing.
The data you provide us with, or which is collected in any of the following ways, will be processed by PVS for the purpose of:
1. providing the integrated logistics services requested;
2. complying with tax obligations;
3. detecting the degree of customer satisfaction through the forwarding of printed material by telephone, email, text message or any other way;
4. sending informative and promotional material, plus marketing and advertising activities regarding the products and services offered by our company.
In particular, by way of example, the data collected may be used for:
- Making it possible to transport and deliver the goods, as well as collect any returns from the final customer.
- Replying to questions and requests for assistance by the final customer.
- Making payment for the purchases or other services.
- Sending the interested party email messages and/or letters by ordinary mail containing information regarding the PVS activities and other contents that we believe to be of interest for the customer.
- Analysing the use and satisfaction with our products and services.
2. Processing method.
PVS collects the personal data to be processed from different sources. More specifically:
- Information collected directly from the interested party.
- Information collected when the interested party visits our premises, uses our applications or services and views our online communications.
- Information collected from our own clients in order to carry out the logistics activities.
- Information collected directly from the interested party.
We also collect information directly from the interested party when the latter chooses to make use of our services, creates an account on our websites, calls us or contacts us by email, or supplies information in any other way.
Examples of the type of data we may collect directly from the interested party include:
- Name and tax code.
- Email address.
- Residential address.
- User name and password if created.
- Telephone, mobile and fax numbers.
- Date of birth.
- Payment information.
- Future communication preferences.
- Telephone number and any recordings made when the interested party calls our customer assistance service.
- Information relating to questions for which assistance is required.
- Matters relating to the above-mentioned questions.
As regards these data collected directly from the interested party, the Data Controller is the undersigning company, PVS Services Italia S.r.l., with office in Parma, Piazzale Balestrieri, 31/A.
3. Information we collect when the interested party visits our websites or views our contents online.
Examples of data and information that we may collect through these technologies include:
- Information about the browser and operating system of the interested party’s computer.
- IP address.
- Web pages viewed by the interested party.
- Links clicked on by the interested party.
As regards these data collected from the interested party, the Data Controller is the undersigning company, PVS Services Italia S.r.l., with office in Parma, Piazzale Balestrieri, 31/A.
4. Information collected by PVS from our own clients .
Wherever necessary for performing the logistics services and/or customer service on behalf of our own clients, the latter must communicate the personal data regarding the user/purchaser/final consumer.
Examples of data that may be communicated by our clients include:
- Name and tax code of the interested party.
- Residential address.
- Email address.
- Telephone, mobile and fax numbers.
- Date of birth
In relation to said data, the Data Controller is the subject with whom the interested party has stipulated the online purchase contract for goods or services and to whom he/she has conferred his/her personal data for the purpose of performing the contract.
All personal data collected will be used in compliance with the applicable regulations.
In particular, the processing may entail operations for recording, storing, consulting, communicating or deleting data.
The processing will mainly be carried out via use of modern computer systems.
At PVS your data will be processed by personnel assigned to the customer service, as well as technical and sales staff. These collaborators will have received appropriate operating instructions with specific reference to the adopting of the minimum security measures.
5. Nature of the data conferred
It is compulsory for you to confer the data indicated in Points 1 and 2 of the Purposes of the Processing above, as they are necessary for performing all contractual, accounting and tax obligations.
The conferring of data in reference to Points 3 and 4 of the Purposes of the Processing above is instead optional and subject to your consent. Further to your refusal in this regard, PVS will only process your data for the purposes indicated in Points 1 and 2.
PVS also wishes to inform you that any failure to communicate or incorrect communication of any of the obligatory information will have the following consequences:
- The impossibility of supplying the services requested;
- Possible incompliance of the processing results with the obligations enforced by the taxation, administrative or labour regulations to which said processing refers.
6. Communication and dissemination.
The data to be processed may subsequently be communicated to specific third parties for the fulfilling of contractual, administrative, accounting and tax obligations.
In particular, your data may be communicated to the following subjects:
- Subjects delegated and/or entrusted by PVS to perform activities or parts of activities for supplying the services we offer, such as the customer service and client service where managed in outsourcing, the logistics structure in charge of packaging the goods, the carrier assigned to deliver the goods, or any other external collaborator to whom the communication is necessary for fulfilling the obligations assumed by PVS in relation to the supply of the service;
- Individuals, companies and professional firms that provide assistance and consultancy activities to PVS regarding accounting, management, taxation, legal and financial affairs;
- When required by law and/or the public authorities.
Your personal data may also be transferred abroad in compliance with and for the purposes of articles 42 and 43 of Legislative Decree 196/2003.
In any case, dissemination of the data being processed is prohibited.
7. Data Controller.
In relation to the data indicated in Points 1 and 2 of the Processing Methods above, the controller of the data processing is the undersigning company, PVS Services Italia S.r.l., with office in Parma, Piazzale Balestrieri, 31/A.
In relation to the data indicated in Point 3 of the Processing Methods above, communicated to PVS by its own clients, the Data Controller is the subject with whom the interested party has stipulated the online purchase contract for goods or services, and to whom he/she has conferred his/her personal data in the aim of performing the contract.
8. Rights of the interested party.
You may exercise your rights as expressed in Sections 7, 8, 9 and 10 of Legislative Decree no. 196 dated 30 June 2003, by contacting the Data Controller.
Following are the essential regulations regarding your rights in accordance with Legislative Decree no. 196 dated 30 June 2003.
Section 7. Right to access personal data and other rights.
1. The data subject shall have the right to obtain confirmation as to whether or not personal data concerning him/her exist, regardless of their being already recorded, and communication of such data in intelligible form.
2. The data subject shall have the right to be informed:
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning the data controller, data processors and representatives designated as per Section 5, paragraph 2 ;
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or persons in charge of the processing.
3. The data subject shall have the right to obtain:
a) the updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymisation or blocking of data that have been processed unlawfully, including data the retention of which is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
4. The data subject shall have the right to object, in whole or in part:
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
Art. 8. Exercise of Rights.
1. The rights referred to in Section 7 may be exercised by making a request to the data controller or processor without formalities, also by the agency of a person in charge of the processing. A suitable response shall be provided to said request without delay.
2. The rights referred to in Section 7 may not be exercised by making a request to the data controller or processor.oor else by lodging a complaint in pursuance of Section 145, if the personal data are processed:
a) pursuant to the provisions of decree-law no. 143 of 3 May 1991, as converted, with amendments, into Act no. 197 of 5 July and subsequently amended, concerning money laundering;
b) pursuant to the provisions of decree-law no. 419 of 31 December 1991, n as converted, with amendments, into Act no. 172 of 18 February 1992 and subsequently amended, concerning support for victims of extortion;
c) by Parliamentary Inquiry Committees set up as per Article 82 of the Constitution;
d) by a public body other than a profit-seeking public body, where this is expressly required by a law for the purposes exclusively related to currency and financial policy, the system of payments, control of brokers and credit and financial markets and protection of their stability;
e) in pursuance of Section 24, paragraph 1, letter f), as regards the period during which performance of the investigations by defence counsel or establishment of the legal claim might be actually and concretely prejudiced;
f) by providers of publicly available electronic communications services in respect of incoming phone calls, unless this may be actually and concretely prejudicial to performance of the investigations by defence counsel as per Act. No. 397 of 7 December 2000;
g) for reasons of justice by judicial authorities at all levels and of all instances as well as by the Higher Council of the Judiciary or other self- regulatory bodies, or else by the Ministry of Justice;
h) in pursuance of Section 53, without prejudice to Act no. 121 of 1 April 1981.
3. In the cases referred to in paragraph 2, letters a), b), d), e) and f) the Garante, also following a report submitted by the data subject, shall act as per Sections 157, 158 and 159; in the cases referred to in letters c), g) and h) of the same paragraph, the Garante shall act as per Section 160.
4. Exercise of the rights referred to in Section 7 may be permitted with regard to data of non-objective character, on condition that it does not concern rectification or additions to the personal evaluation data in connection with judgements, opinions and other types if subjective assessment, or else the specification of policies to be implemented or decision-making activities by the data controller.
Art. 9. Mechanisms to Exercise Rights.
1. The request addressed to the data controller or processor may also be conveyed by means of a registered letter, facsimile or email. The Garante may specify other suitable arrangements with regard to new technological solutions, if the request is related to exercise of the rights referred to in Section 7, paragraphs 1 and 2, it may also be made verbally; in this case it will be written down in summary fashion by either a person in charge of the processing or the data processor.
2. The data subject may grant, in writing, power of attorney or representation to natural persons, bodies associations or organisations in connection with exercise of the rights as per Section 7. The data may also be assisted by a person of his/her choice.
3. The rights as per Section 7, where related to the personal data concerning a deceased person, may be exercised by any entity that is interested therein or else acts to protect a data subject or for family-related reasons deserving protection.
4. The data subject’s identity shall be verified on the basis of suitable information, also by means of available records or documents or by producing or attaching a copy of an identity document. The person acting on instructions from the data subject must produce or attach a copy of either the proxy of the letter of power of attorney, which shall have been undersigned by the data subject in the presence of a person in charge or else undersigned and produced jointly with a non-certified copy of an ID document of the data subject.
5. The request referred to in Section 7, paragraphs 1 and 2, may be worded freely without any constraints and may be renewed at intervals of not less than ninety days, unless there are well-grounded reasons.
Art. 10. Response to data subjects.
1. With a view to effectively exercising the rights referred to in Section 7, the data controller shall take suitable measures in order to, in particular:
a) facilitate access to personal data by the data subjects, even by means of ad hoc software allowing accurate retrieval of the data concerning individual identified or identifiable data subjects;
b) simplify the arrangements and reducing the delay for the responses, also with regard to public relations departments of offices.
2. The data processor or the person(s) in charge of the processing shall be responsible for the retrieval of the data, which may be communicated to the requesting party also verbally, or else displayed by electronic means – on condition that the data are easily intelligible in such cases also in the light of the nature and amount of the information. The data shall be reproduced on paper pr electronic media, or else transmitted via electronic networks, whenever this is requested.
3. The response provided to the data subject shall include all the personal data concerning him/her that are processed by the data controller, unless the request concerns with a specific processing operation or specific personal data of categories of personal data. If the request is made to a health care professional or health care body, Section 84, paragraph 1 shall apply.
4. If data retrieval is especially difficult, the response to the data subject’s request may also entail the producing or delivering of copies of records or documents containing the personal data in question.
5. The right to obtain communication of the data in intelligible form does not apply to personal data concerning third parties, unless the breaking down of the processed data or elimination of certain items from the latter prevents the data subject’s personal data from being understandable.
6. Data are communicated in intelligible form also by using legible handwriting. If codes or abbreviations are communicated, the criteria for understanding the relevant meanings shall also be made available by the agency of the persons in charge of the processing.
7. Where it is not confirmed that the personal data concerning the data subject exist, further to a request referred to in Section 7, paragraphs 1 and 2, letters a), b) and c) the data subject may be charged a fee which shall not be in excess of the costs actually incurred for the inquiries made in the specific case.
8. The fee referred to in paragraph 7 may not be in excess of the amount specified by the Garante in a generally applicable provision, which may also refer to the lump sum to be paid in case the data are processed by electronic means and the response is provided verbally. Through said instrument the Garante may also establish that the fee be charged if the personal data are contained on special media, and the reproduction of which is specifically requested, or else if a considerable effort is required by one or more data controllers on account of the complexity and/or amount of the requests and existence of data concerning the data subject can be confirmed.
9. The fee referred to in paragraphs 7 and 8 may also be paid by bank or postal draft, or else by debit or credit card, if possible upon receipt of the relevant response and in any case within fifteen days after said response.