Information for those using the communication services offered by Ghenos s.r.l.
pursuant to EU Regulation 2016/679
Ghenos s.r.l. with registered office in Via Poliziano 4 – Milan, as Data Controller of personal data, in fulfillment of the obligation to inform interested parties (data subjects) regarding the basic elements of personal data processing, specifies the methods for and purposes of the personal data processing below.
By processing we mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, selection, retrieval, comparison, consultation, use, disclosure by transmission, blocking, dissemination or otherwise making available, restriction, erasure or destruction.
Purpose of the processing
As part of performing the professional functions of communication services and distribution of press releases, personal data collected directly from the Data Subject are processed.
The processing of personal data takes place using physical and IT tools, with methods aimed at preventing violations of the rights, fundamental freedoms and dignity of the Data Subject. This data is kept and archived for only the time necessary for the provision of services or in compliance with legal requirements.
Tax documents will be kept securely archived until the tax assessment deadline expires.
Legal basis for the processing
Pursuant to EU Reg. 2016/679, art. 6, par. 1, letter b), your personal data are processed according to the principles of lawfulness on the legal basis of necessity for the execution of a contract.
Pursuant to art. 6, par. 1, letter f) your personal data will be processed on the legal basis of legitimate interest, with reference to recital 47 the data controller has the right to process its customers’ data also for communications relating to products and/or services previously purchased or similar to those previously purchased.
Ghenos s.r.l. sends periodic press releases or information regarding events to service applicants, in compliance with the purposes of the data processing, these communications can be made by sending e-mails or by non-automated telephone contact.
Any data processing not falling within the parameters specified above will be carried out pursuant to art. 6, para. 1, letter a) with the consent of the Data Subject.
Art. 4, para. 1, number 11 of EU Reg. 2016/679 defines consent as: “any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.”
Mandatory or optional nature of providing data
The provision of data is mandatory if refusal, even partial, could lead to the inoperability or ineffectiveness of the professional service; personal data processed with a request for explicit consent by the Data Subject are to be considered optional.
Scope of communication and dissemination
All of those formally designated and authorized to process data may become aware of your data according to their respective authorization profiles.
The data may also be disclosed to the following categories of persons:
- Tax consultant(s) for the management of accounting activities
- Web platforms for sending press releases
The personal data provided will not be disseminated and are not processed outside the European Union.
Rights of the Data Subject
The Data Subject has the right to exercise at any time those rights referred to in Art. 15, 16, 17, 18, 19, 20, 21 and 22 of EU Regulation 2016/679. In particular, he or she has the right to obtain confirmation as to whether or not personal data are being processed (content and origin), know the purposes of the processing, the recipients or categories of recipient to whom the personal data have been or will be disclosed, the period for which said data will be kept. The Data Subject also has the right to ask for data rectification, erasure, or limitation of processing; to lodge a complaint with a supervisory authority; to know about the existence of automated decision-making and the logic thereof; the right to be forgotten, to data portability, and to know if the data has been transmitted to a third country.
In order to exercise these rights the Data Subject can contact the Data Controller by writing to:
rev.1.0 of 09/10/2018