EXTENDED CUSTOMER DATA INFORMATION
1. Identity and contact details of the Data Controller and Data Supervisors The data controller is Murru Trainer with registered and operational headquarters in Kruisplein 922, 30122 CC – Rotterdam (NL) VAT number NL427466489B01 The updated list of managers and The persons in charge of processing are kept at the registered office of the Data Controller.
Murru Trainer with registered and operational headquarters in Kruisplein 922 – 3012CC – Rotterdam (NL) VAT number NL427466489B01, as data controller, informs you pursuant to art. 13 EU Regulation n. 2016/679 (hereinafter “GDPR”) that your data will be processed in the following manner and for the following purposes:
2. Subject of Treatment
Murru Trainer processes personal, identifying data (for example, name, surname, address, telephone, e-mail,) – later, “personal data” or even “data” communicated by you on the occasion of the conclusion of contracts between the parties
3. Purposes of the processing and legitimate interests
Your personal data are processed without your express consent (art. 6 letter b), e) GDPR), for the following Service Purposes: the data is processed by Murru Trainer as a data holder as the processing is necessary for the execution of a contract of which the interested party is a party or to the execution of pre-contractual measures dictated at the request of the same (personal data relating to contracts or pre-contractual activities or functions) to fulfill to the obligations provided for by law, by a regulation, by EU legislation or by an order of the Authority (such as for example in the field of anti-money laundering); exercise the rights of the Owner, for example the right to defend in court;
4. Recipients of personal data and communication of data
Your data may be made accessible for the purposes referred to in art. 2 to employees and collaborators of the Data Controller, including external ones, in their capacity as appointees and / or data processors and / or system administrators;
In the case of personal data of the Murru Trainer employee, the data can be transmitted to the following recipients: Internal representative who handles the data for the provision of the service (commercial employee, purchasing agent) Fiscal Consultant, legal, Banks for provision of their services (accounting, contracts, etc.), which act as Data Controllers
Personal data is stored on servers located within the European Union. In any case, it is understood that the owner, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller now ensures that the extra-EU data transfer will be in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses envisaged by the European Commission.
Without the need for an express consent art. 6 lett. b) and c) GDPR), the Owner may communicate your data for the purposes referred to in art. 2 to Supervisory Bodies (such as IVASS), Judicial Authorities, insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is obligatory by law for the fulfillment of the said purposes. These subjects will treat the data in their capacity as independent data controllers.
5. Processing methods and storage period
The processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2) GDPR and more precisely: collection, recording, organization, storage, consultation, processing, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subjected to both paper and electronic manual processing.
The Data Controller will process the personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the Service Purposes.
6. Rights of the interested party
As an interested party, you have the rights set forth in art. 15 GDPR and precisely the rights to: obtain confirmation of the existence or not of personal data concerning you, even if not yet recorded, and their communication in intelligible form; obtain the indication: a) of the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with the aid of electronic instruments; d) of the identification data concerning the data controller, data processors and the representative designated pursuant to art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or appointees; get: a) the update, the correction or, when interested, the integration of the data; b) the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including data which does not need to be kept for the purposes for which the data was collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the event that such fulfillment occurs it proves impossible or involves a manifestly disproportionate use of resources with respect to the protected right; object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by phone and / or mail. Please note that the interested party’s right of objection, set out in the previous point b), for direct marketing purposes by automated means, extends to the traditional ones and that the possibility for the interested party to exercise the right of opposition also remains valid only partially. Therefore, the interested party may decide to receive only communications using traditional methods or only automated communications or none of the two types of communication. Right to rectification of your personal data if they are modified and do not correspond to those previously acquired or communicated (art. 16) Right to the deletion of data (“right to be forgotten”, art. 17). Murru Trainer, if one of the following cases exists, proceeds to delete the data from all databases and archives where it is contained: a) personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed; b) the data subject revokes the consent and if there is no other legal basis for the processing; c) the data subject opposes the processing pursuant to Article 21, paragraph 1, and there is no legitimate prevailing reason to proceed with the processing, or he opposes the processing pursuant to Article 21, paragraph 2; d) personal data have been unlawfully processed; e) personal data must be deleted in order to fulfill a legal obligation established by Union law or the Member State to which the data controller is subject; f) personal data has been collected in relation to the offer of information society services referred to in Article 8, paragraph 1. Right to limitation of processing (Article 18). The interested party has the right to obtain the processing limitation from the data controller when one of the following hypotheses occurs: a) the data subject disputes the accuracy of the personal data, for the period necessary for the data controller to verify the accuracy of such personal data; b) the processing is unlawful and the data subject opposes the deletion of personal data and requests instead that its use be limited; c) although the data controller no longer needs it for the purposes of processing, personal data is necessary for the data subject to ascertain, exercise or defend a right in court; d) the data subject has opposed the processing pursuant to Article 21, paragraph 1, pending verification regarding the possible prevalence of the legitimate reasons of the data controller with respect to those of the data subject. Opposition right (art. 21-22): The interested party has the right to object at any time, for reasons connected to his particular situation, to the processing of personal data concerning him / her pursuant to Article 6, paragraph 1, letters e) of), including profiling on the basis of such provisions. Murru Trainer does not submit data to decisions based solely on automated processing.
Murru Trainer notifies each data subject of any data adjustments, limitations or cancellations.
Murru Trainer refrains from further processing personal data unless there are legitimate cogent reasons for processing that prevail over the interests, rights and freedoms of the data subject or for the assessment, exercise or defense of a right in court.
For the data that Murru Trainer treats for marketing purposes I the rights of the interested party are expressed in the specific Information on data processing for marketing purposes
7. Procedures for exercising the rights You
may at any time exercise your rights by sending: – an e-mail addressed to: [email protected]
7. Nature of the provision of data and consequences of the refusal to reply Providing data for the purposes of referred to in art. 2. is mandatory. In their absence, we cannot guarantee the Services of art. 3