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In compliance with Article 13 of European Law 2016/679 (the General Data Protection Regulation) we are writing to inform you about the ways in which the personal information about clients visiting the
website will be treated.
This circular does not refer to other websites, web pages or online services that can be accessed through hypertext links published in the corporate website and referring to outside resources, over which the responsible party has no decision-making power with regard to the uses and ways in which the information is treated.
PARTY RESPONSIBLE FOR DATA TREATMENT
The party responsible is
CAPITAL SUITE S.r.l.
headquartered in Via Santa Maria Segreta 6, 20123 Milano (MI), Fiscal and VAT code 09300050961, in the person of its legal representative
RECEIVERS OF THE DATA
The data collected is handled by personnel who act according to specific instructions with regard to the uses and ways in which it is to be treated.
In cases covered by articles 15-22 of European Law 679/16, users have the right to access, correct, cancel or limit the treatment of any personal information that may concern him/her, or to oppose the treatment of such data.
Users may exercise their rights at any time by taking the following action:
– sending a registered letter with proof of receipt to Capital Suite S.r.l., Via Santa Maria Segreta 6, 20123 Milano (MI);
– sending a certified e-mail with the subject “EXERCISE OF PRIVACY RIGHTS” to the following e-mail address: firstname.lastname@example.org
If users believe that their rights have been violated, they may make a complaint to the Italian Data Protection Authority.
CIRCULAR ON THE TREATMENT OF PERSONAL DATA
Dear Client, in compliance with current laws concerning the treatment of personal data, we would like to inform you that the personal information that you have supplied to the company
— in compliance with the above-mentioned standards and the obligations of confidentiality on which the activities of our company are based —will be treated according to the ways defined in Article 4 of the European Law on Data Protection. In particular, we would like to provide you with the following information:
1. Data on the responsible party
The party responsible for handling your personal data is CAPITAL SUITE SRL, a company headquartered in Milan in Via Santa Maria Segreta n. 6
20123 Milano (MI), fiscal and VAT code
MI-2081930, certified e-mail address: email@example.com, in the person of its legal representative
2. Purposes of data treatment
For the purposes listed below, CAPITAL
SRL will treat the following categories of data:
contact details, data on your economic situation or assets, as well as other personal information required or acquired, with the exclusive aim of the purposes associated with exercising the activities requested and those associated with them.
Personal information will be collected and treated in order to:
take action deriving from the contractual relationship and the supply of assistance and general consultancy services, as stated in the contract;
comply with current laws, especially accounting and fiscal laws;
manage the personal relationship with the client (planning activities, making phone calls, arranging meetings etc.);
exercise the rights of the responsible party, such as the right to defend itself in court.
Passing on personal data for this purpose is necessary and, if the client decides not to provide it, the responsible party will be unable to confirm the contract and start to take action.
Treatment of data does not require the client’s permission. The legal basis of data treatment is the execution of a contract to which the client is party, the execution of pre-contractual measures adopted at the client’s request, or fulfilling a legal obligation of the responsible party.
conduct marketing activities (this requires the client’s consent and here the provision of personal data is optional).
The provision of personal information for such purposes
is optional and the client’s refusal to provide it makes it impossible for the responsible party to carry out marketing activities. This kind of treatment requires the client’s consent, which may be withdrawn at any time. The legal basis for data treatment is the client’s consent.
3. Period of conservation
All personal data will be kept throughout the duration of execution of the contract; thereafter, the information will be kept for a period of ten years from the end of the contract,
for the purpose of complying with legal requirements, including the obligation to maintain accounting books and documents (art. 2214 of the Civil Code), and until the company’s relationship with the client has been concluded or at the request of the client to cancel the information for the purposes described in point e).
4. Access, communication to third parties and spread
The information collected will be made available, so that it can be conserved and used for the purposes described above, to the following the employees and collaborators of the responsible party, since they are authorised to treat such data, and/or system administrators;-to third parties, should there be a need to take specific action, or other action in their role as external data treatment collaborators. For the exclusive purposes described above, data may be transmitted and sent to third parties who carry out or provide specific services which are strictly connected with the execution of the terms of the contract, for example :
banks, with regard to methods of payment
companies and experts on which the responsible party relies;
companies and experts on which the client relies, especially services rendered and always at the client’s request.
The names and addresses of those mentioned above are available for clients to consult.
5. Conservation, spread and transfer of data abroad
The management and conservation of personal data will be carried out through the responsible party’s servers or archives located within the European Union and/or third-party companies who have been entrusted with and named as being responsible for the treatment of personal data. The client’s personal data may be transferred abroad to the company CAPITAL SUITE SA, based in Lugano, exclusively for the purposes described in point
2), in compliance with the terms authorised by the Data Protection Authority to protect personal data in resolution n. 37 of 17 October 2001, in which it is stated that Switzerland guarantees an adequate level of protection for personal data transferred from the European Union.
6. Ways of treating data
The responsible party undertakes to treat clients’ personal information in a lawful, correct way so as to ensure that it remains confidential and secure. The data will be treated manually and using information technology tools, using organisational methods and logic that are strictly related to the purposes described in this circular.
7. Client’s rights
With regard to the treatment of personal information, clients have the rights described in Articles 15 to 22 of the European Law on Data Protection N. 2016/679, described below:
– Right of access
– Right of correction
– Right of cancellation («right of removal»)
– Right to restrict treatment
– Obligation to inform the person concerned if personal data is corrected or cancelled or if treatment of the data is restricted
– Right of data portability
– Right of opposition
– Automated decision-making process with regard to individuals
8. Modes in which rights will be executed
The persons concerned (clients) may exercise their rights at any time by taking the following action:
sending a registered letter with proof of receipt to Capital Suite s.r.l., Via Santa Maria Segreta 6, 20123 Milano (MI);
sending a certified e-mail with the subject “EXERCISE OF PRIVACY RIGHTS” to the following address: firstname.lastname@example.org