FLY S.R.L., based in Via G. Galilei, 13/4, 31057 Silea (TV), which can be contacted by e-mail at the following address email@example.com will process personal data provided by the customer in connection with the contract or otherwise obtained in the context of the contractual relationship (including the pre-contractual stage) (“Contract”) for the provision of services and products requested by the customer and included in the Contract (“subject of the contract”) and other activities and services related to the same, unless it is provided in the context of the same a different information on the processing of personal data.
FLY S.R.L. is the owner of the treatment with reference to personal data, obtained by the customer through the services and activities mentioned above, which are processed in accordance with the terms of this statement and the applicable legislation. Consequently, this Policy applies to all Customers.
3. WHAT KIND OF PERSONAL DATA OF USERS ARE COLLECTED BY FLY S.R.L.?
FLY S.R.L. collects the following categories of personal data:
i. the customer’s name, e-mail address, telephone number, address of the registered office, delivery address of the goods, billing address;
ii. fiscal code and VAT number;
iii. identity card (identity card, passport or driving licence);
iv. bank details.
4. HOW IS CUSTOMER PERSONAL DATA USED?
FLY S.R.L. processes the personal data of customers for the following purposes:
a) for the supply of the Products and Services resulting from the Contract;
b) for the analysis and improvement of services;
c) for handling complaints and disputes;
d) to assert and defend its rights, including in the context of debt collection procedures and the assignment of credits to authorised companies, including through third parties;
e) to complete a potential merger, transfer of assets, transfer of business or branch of business by disclosing and transferring the Client’s personal data to the third parties involved;
f) with the prior consent of the User, to send marketing communications about products and services offered by FLY S.R.L. (for example, by sending advertising material, carrying out market research). Marketing communications can be sent either through traditional communication tools such as paper mail or operator phone calls or through automated communication tools such as email, chat, SMS, MMS, video calling, automatic calling, instant message, chatbot, interactive automated intelligent communication systems, banners, notification systems and other remote communication tools;
5. WHAT ARE THE LEGAL BASES FOR THE PROCESSING OF PERSONAL DATA BY FLY S.R.L.?
The processing of the Customer’s personal data is necessary with reference to the Contractual Purposes given its essentiality in order to:
• to execute the Contract with reference to the supply of the Goods and Services requested;
comply with the provisions of the applicable legislation.
If the Customer does not provide the personal data necessary for the Contractual Purposes, it will not be possible to proceed with the stipulation of the Contract by FLY S.R.L.
The processing of the User’s personal data for the purposes of legitimate interest is carried out pursuant to Article 24, paragraph 1, letter d) of Legislative Decree 196/2003 (“Privacy Code”) and, with effect from 25 May 2018, pursuant to Article 6, letter f), the General European Data Protection Regulation 2016/679 (the “Privacy Regulation”) for the pursuit of the legitimate interest of FLY S.R.L. which is fairly balanced with the interest of the customer, as the processing of personal data is limited to what is strictly necessary for the execution of economic transactions requested and services under the Contract.
Processing for the Purposes of Legitimate Interest is not mandatory and the Customer may object to such processing in the manner set out in Section 9 below, but if the Customer objects to such processing his data may not be used for the Purposes of Legitimate Interest.
6. HOW ARE PERSONAL CUSTOMER DATA PROCESSED?
Customers’ personal data may be processed by manual or computerised means, suitable for guaranteeing security and confidentiality and for preventing unauthorised access, dissemination, modification and theft of data, thanks to the adoption of adequate technical, physical and organisational security measures.
7. WHO CAN HAVE ACCESS TO CUSTOMERS’ PERSONAL DATA?
For the Contractual Purposes mentioned above, the personal data of the Customers may be transferred to the following categories of recipients: (a) third party suppliers of assistance and consultancy services for FLY S.R.L. with reference to the activities of the sectors (by way of example only) technological, accounting, administrative, legal, insurance, IT; (b) banks and credit card issuing institutes; (c) the commercial network (e.g., the company’s own network, the company’s own network, the company’s own network, the company’s own network, the company’s own network, etc.); (e.g., the company’s own network); (g., the company’s own network); (g., the company’s own network); (g) the company’s own network. agents, distributors) of FLY S.R.L.; (f) subjects and authorities whose right of access to personal data of customers is expressly recognized by law, regulations or measures issued by the competent authorities.
These receivers, depending on the circumstances, will process personal data as owners, managers or agents of the treatment.
For the purposes of legitimate interest mentioned above, the personal data of customers may be transferred to the following categories of recipients: a) third party providers of assistance and consulting services for FLY S.R.L. with regard to the activities of recovery and assignment of receivables; (b) potential buyers of FLY S.R.L. and entities resulting from the merger or any other form of transformation; (c) competent authorities.
For the Marketing Purposes mentioned above, Users’ personal data may be transferred to the following categories of recipients: (a) third party service providers and FLY S.R.L. consulting with reference to the activities of sending commercial communications.
A complete list of external managers can be obtained, on request, through the procedures indicated in Section 9 below.
8. WHAT ARE THE RIGHTS OF USERS WITH REGARD TO THEIR PERSONAL DATA?
The User may, at any time and free of charge, by sending an email to firstname.lastname@example.org exercise the following rights:
(a) to obtain from FLY S.R.L. the confirmation of the existence or not of data concerning him/her and to be informed about the content and source of the data, to verify its accuracy and to request its integration, updating or modification;
(b) obtain the cancellation, transformation into anonymous form or blocking of any data processed in violation of applicable law;
(c) to object to the processing, in whole or in part, on legitimate grounds;
(d) revoke, at any time, consent to the processing of data (in relation to processing operations for which such consent may be required), without prejudice in any way to the lawfulness of processing based on consent given prior to revocation.
9. TERMS OF RETENTION OF CUSTOMER DATA
Customers’ personal data will be kept for the period of time necessary for the pursuit of the purposes for which such data were collected, as stated in this Policy. In any case, the following retention terms will apply with reference to the processing of personal data of customers for the purposes set out below:
i. for the purposes of Contracts and Legitimate Interest, the Customers’ personal data are kept for a period equal to the duration of the Contract (including any renewals) and for 10 years following the end, termination or withdrawal of the same, unless storage for a subsequent period is required for any disputes, requests by the competent authorities or under applicable law;
ii. for the Marketing Purposes related to the sending of commercial communications and the execution of market research of this Policy, the personal data of the Customers are kept for the duration of the Contract and a period of 24 months after its termination;
iii. for the Marketing Purposes related to the analysis of Customers’ preferences for the marketing purposes of this Policy, Users’ personal data are stored for a period of 12 months from collection.
In addition to the rights listed in this Section of this Notice, you shall have the right, exercisable at all times, to
i. ask FLY S.R.L. to limit the processing of their personal data in the event that:
• the customer disputes the accuracy of their personal data for the period necessary for FLY S.R.L. to verify the accuracy of such data;
• the processing is unlawful and the Customer objects to the deletion of his personal data and requests instead that it be limited in use;
• although FLY S.R.L. no longer needs it for the purposes of processing, the data are necessary for the customer to ascertain, exercise or defend a right in court;
ii. oppose the processing of personal data;
iii. request the deletion of personal data concerning him without undue delay;
iv. receive an electronic copy of their personal data, if the customer wants to transfer personal data about him to himself or to a different service provider, in the event that FLY S.R.L. performs the processing of personal data on the basis of the consent of the customer or on the basis of the circumstance that the processing is necessary for the provision of services and personal data are processed through automated tools;
v. make a complaint to the Data Protection Authority.
10. CHANGES AND UPDATES