Dear Customer,

hereby to inform you about the methods of processing the personal data of your contacts / employees / collaborators pursuant to the European Regulation EU 2016/679 for privacy. With reference to it, we will report any need to process the same data outside the EU. Finally, we remind you that once you have concluded the legal terms for the custody of the personal data that you will provide us (eg for tax or other legal purposes), you can ask us to delete them from our archives.

Therefore, the data transmitted by you or transmitted by your contact persons / employees / collaborators will be managed and processed by us as reported in this informatio

1. Object of treatment

The Data Controller processes personal, identifying and non-sensitive data (in particular, name, surname, tax code, VAT number, email, telephone number – hereinafter, “personal data” or even “data”) communicated during the contract or of work.

2. Purpose of the processing

Personal data are processed:

• without your express consent (Article 24 letter a, b, c Privacy Code and Article 6 letter b, and GDPR), for the following purposes:
• fulfill commercial, pre-contractual, contractual and tax obligations deriving from existing relationships with you;
• fulfill the contract, the service requested by you and carry it out according to correct working methods;
• fulfill the obligations established by law, by explicit requests from law enforcement or the judiciary, by a regulation, by community legislation or by an order of the Authority;
• prevent or discover fraudulent activities or abuses harmful to existing activities; promptly inform your contacts in case of operational and administrative needs;
• exercise the rights of the owner, for example the right to defense in court.

• Solo previo il Suo specifico e distinto consenso (artt. 23 e 130 Codice Privacy e art. 7 GDPR), per le seguenti Finalità:
• accesso di dati a terzi da Voi esplicitamente indicati (es. dati su accessi luoghi di lavoro, recapiti personali, foto, ecc..)

3. Methods of processing

The processing of personal data is carried out by means of the operations indicated in art. 4 of the Privacy Code and art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Personal data are subjected to both paper and electronic and / or automated processing.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 5 years from the termination of the activity for the purposes of service and for fiscal-administrative management.

4. Access to data

The data may be made accessible for the purposes referred to in art. 2.A) and 2.B):

• to employees and collaborators of the Controller or of the Shareholders of the Controller, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators;
• to service companies essential to the Data Controller to provide your service (for example, for organizational management activities, for telecommunications activities, for technical management activities, for the storage of personal data, etc.)
• to third parties (for example, providers for the management and maintenance of the website, suppliers, credit institutions, professional firms, etc.) who also carry out outsourced activities on behalf of the Data Controller, in their capacity as external data processors.

5. Communication of data

Even without your express consent (pursuant to Article 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies, Judicial Authorities as well as to all other subjects to whom communication is mandatory by law for the accomplishment of the aforementioned purposes.

6.Data transfer

The management and storage of personal data will take place on servers located within the European Union, owned by the Owner and / or by third party companies duly appointed as Data Processors. The servers are currently located in Italy and the EU in general. The data will not be transferred outside the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the location of the servers to Italy and / or the European Union and / or non-EU countries. In this case, the Data Controller ensures from now on that the transfer of data outside the EU will take place in compliance with the applicable legal provisions by stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided for by European Commission.

7. Nature of the provision of data and consequences of refusing to respond

The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we will not be able to guarantee the provision of the services requested and contracted by you.

The provision of data for the purposes referred to in art. 2.B) is optional. You can therefore decide not to allow access to any data by third parties, even if previously authorized.

7. Rights of the interested party

The staff referring to you, in your capacity as an interested party, have the rights referred to in art. 7 of the Privacy Code and art. 15 GDPR and precisely the rights of:

• obtain confirmation of the existence or not of personal data concerning him, even if not yet registered, and their communication in an intelligible form;
• obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) the logic applied in case of processing carried out with the aid of electronic tools; d) the identification details of the owner, managers and designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and 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 territory of the State, managers or agents;
• obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those which need not be kept for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment is proves impossible or involves the use of means that are manifestly disproportionate to the protected right;
• object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you for the purposes referred to in Article 2B)

Where applicable, they also have the rights referred to in Articles. 16-21 GDPR (Right of rectification, right to be forgotten, right to limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

9. How to exercise rights

You and your contact persons can exercise the rights at any time by sending:

• a registered letter a.r. in Via Novara, 7/9/11 – 20814 Varedo (MB)
• a pec to the address: vema.automotive@pec.it

10. Owner, manager and agents

The Data Controller is Vema S.r.l, The updated list of data processors and persons in charge of processing is kept at the headquarters of the Data Controller.

11. Changes to this Notice

This information may be subject to changes.
In this case, the most updated version will be promptly sent.

The Chief Executive Officer
Vema S.r.l.