The Data Controller is ZPC Srl, a sole shareholder limited liability company (hereinafter "ZPC") with registered office in Vicolo Rensi 3 - 37121 Verona (VR), Tax Code and VAT No. 03550990232.
CATEGORIES AND TYPES OF DATA PROCESSED
The data processed by ZPC may include generic data collected for the purposes of concluding the contract with the data subject and/or as part of its execution and/or stipulation.
In addition, it is possible that the personal data of third-party subjects communicated by the data subject to ZPC may be processed. In such cases, the data subject acts as an independent data controller and accepts the consequent legal obligations and liabilities, holding ZPC harmless against any dispute, claim and/or request for compensation of damage for the data processing received by ZPC from such third parties.
With specific reference to the use of ECP®, the user provides their personal data, via an electonic process of informed consent, to access certain services. This involves the processing by ZPC of the user’s name, address and any other data required for the exclusive purpose of delivering the service.
PURPOSE AND LEGAL BASIS OF DATA PROCESSING
In compliance with the current provisions on the protection of personal data, and without the need for specific consent from the data subject, data will be stored, collected and processed by ZPC for the following purposes: a) the fulfilment of contractual obligations, execution and/or stipulation of the contract and/or the management of any pre-contractual measures; b) the fulfilment of any regulatory obligations, fiscal and tax measures arising from the conduct of the business activity and obligations connected to administrative-accounting activities; c) the sending of communications regarding product news and updates, subject to user consent.
The legal basis for data processing in relation to purposes a) and b) above are articles 6.1.b) and 6.1.c) of the GDPR. The provision of data for such purposes is optional but failure or refusal to comply would make it impossible for ZPC to carry out and/or stipulate the contract and supply the services requested.
The legal basis for personal data processing for purpose c) above is article 6.1.a) of the GDPR, since the processing is based on consent.
METHOD OF DATA PROCESSING
For the purposes indicated above, data processing is carried out using manual, IT and electronic means strictly related to the purpose and, in any event, in such a way as to guarantee the security and confidentiality of such data, in full compliance with the specific obligations laid down by the GDPR.
The data will be processed according to the principles of legality, necessity and proportionality, pursuant to the GDPR. The processing will be carried out by formally-appointed and adequately trained personnel.
TRANSFERS TO THIRD PARTIES AND OUTSIDE THE EUROPEAN UNION
Data may be transferred to companies or third parties that conduct activities strictly connected and instrumental to the management of the commercial relationship between ZPC and the data subject.
The electronic archive connected to ECP® platform is stored in the United States. The European Commission has determined (with Commission Implementing Decision (EU) 2016/1250 of 12 July 2016) that an adequate level of data protection exists in the United States. Other transfers of data to countries outside the EU are not envisaged.
Data will be stored on computer storage media only for the time necessary for fulfilment of the purposes for which it was collected, pursuant to the data minimisation and storage limitation referred to in article 5, paragraph 1, letters c) and e) of the GDPR.
Data will be stored to fulfil regulatory obligations and to fulfil the purposes stated above, according to the principles of indispensability, non-redundancy and relevance. ZPC may store data after the termination of the contractual relationship to fulfil regulatory and/or post-contractual obligations; thereafter, when the reasons for data processing no longer apply, data will be deleted, destroyed or pseudonymised.
RIGHTS OF THE DATA SUBJECT
In relation to the data processing described above, data subjects can exercise the rights referred to in articles 15 to 22 of the GDPR. Specifically, data subjects have the right to ask ZPC for access to their data, the correction or deletion of their data, the right to object to data processing or to request limitation of processing in the cases laid down by article 18 of the GDPR, and to obtain their data in a structured format in common use and readable by automatic devices, in the cases laid down by article 20 of the GDPR.
Data subjects can also revoke at any time the consent given in accordance with article 7 of the GDPR and make a complaint to the Italian Data Protection Authority data in accordance with article 77 of the GDPR, should data subjects deem that the data processing violates the GDPR.
If the data subject objects to data processing in accordance with article 21 of the GDPR, ZPC reserves the right to assess the objection, which will not be accepted if there are mandatory, legitimate reasons for data processing that prevail over the interests, rights and freedom of the data subject. Requests should be sent in writing to the email address firstname.lastname@example.org.