V-COLLECTIVE NEWSLETTER SUBSCRIPTION
Privacy Notice pursuant to Article 13 of Regulation (EU) 2016/679
Introduction
This Privacy Notice is provided pursuant to Article 13 of Regulation (EU) 2016/679 (“GDPR”) and sets out the purposes and methods of the processing of your personal data. Your personal data will be processed by Cromology Italia S.p.A. in full compliance with the principles of confidentiality, fairness, necessity, relevance, lawfulness and transparency. Personal data may be processed manually, using paper records, as well as by electronic and IT systems, in accordance with this Privacy Notice.
Data Controller and Data Protection Officer (DPO)
Your personal data are processed by Cromology Italia S.p.A., with its registered office at Via 4 Novembre, 4, 55016 Porcari (LU), Italy, acting as the Data Controller pursuant to Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR). Should you have any questions or requests regarding the processing of your personal data, you may contact Cromology at any time using the following contact details:
E – Mail: complianceofficeritalia@cromology.it
Contact details for submitting complaints: dpo@cromology.it
Telephon number: 0583 2424
Categories of Personal Data and Purposes of Processing
Personal data processed by Cromology Italia includes, in particular:
• personal data (first name, last name, profession, address, Country);
• contact data (email address, telephone number).
your personal data will be processed for:
a) direct marketing purposes, namely for the sending – via newsletter – of promotional material, commercial information, offers, initiatives, events, and updates relating to Cromology Italia products and services, with reference to the Viero Decoratives Brand and within the V – Collective Community (link: https://www.vierodecoratives.com/v-collective/);
b) profiling activities, based on the information received (professional activity and geographical area, brand/products of interest).
The consent given below for the sending of advertising or direct sales material, or for the carrying out of market research or commercial communications by Cromology Italia S.p.A., will relate to the Viero Decoratives brand and will take place within the Community called “V Collective”. Those who consent to receiving the newsletter will be identified as members of the Community.
The legal basis for the processing is the data subject’s consent pursuant to Article 6(1)(a) of the Regulation.
The data will also be processed for the protection, in judicial or extrajudicial proceedings, of the Controller’s rights, pursuant to Article 6(1)(f) of the Regulation.
Your personal data are processed by Cromology Italia staff specifically authorized pursuant to Article 4(10) of the Regulation and only on specific instructions from the Data Controller and/or by personnel of entities appointed as data processors pursuant to Article 28 of the GDPR, as further specified in the section “Categories of recipients”.
Optional or mandatory nature of data provision
The provision of data is optional; however, if you do not provide your data, the Data Controller will not proceed with the processing described in this notice. Any consent you may give in this context may be withdrawn at any time by submitting a written request to the Data Controller at complianceofficeritalia@cromology.it . Processing carried out prior to the withdrawal of consent shall be considered lawful. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Data retention period
The personal data provided will be processed until consent is withdrawn. Any further retention will be carried out in accordance with legal, contractual, or judicial obligations, in order to establish, exercise, or defend legal claims in court, or to fulfil other public interest requirements (orders from public or judicial authorities).
Categories of recipients of personal data
Your personal data may be disclosed to third parties we use to provide our services; such parties have been appropriately selected by us and offer suitable guarantees of compliance with personal data protection regulations. These parties have been appointed as Data Processors pursuant to Article 28 of the Regulation and are required to carry out their activities in accordance with the specific instructions provided by Cromology Italia and under its supervision.
These third parties may belong to the following categories: companies, entities, or consortia appointed as data processors pursuant to Article 28 of the aforementioned Regulation, which, on behalf of Cromology Italia, provide activities related to, instrumental to, or supporting the Company’s operations.
Data may also be disclosed to:
• parties who are granted access to personal data by law, regulations, or EU legislation
• parties to whom disclosure is required by law or regulation, or public authorities for the performance of their institutional duties, as well as to allow Cromology to exercise or defend its rights or those of third parties before competent authorities, and for other reasons related to the protection of the rights and freedoms of others.
Transfer of data outside the EU
The Data Controller, for the purposes described above, transfers your Data to third countries. In such cases, appropriate safeguards will be implemented in accordance with adequacy decisions issued by the European Commission and/or the national Data Protection Authority and/or, in any case, all necessary measures required for each specific transfer, as appropriate from time to time. Further information regarding any transfers of Data to countries outside the European Union, the safeguards adopted, as well as information regarding companies appointed as Data Processors, may be requested from the Data Controller using the contact details provided in this notice.
Your rights
We inform you that you have the right to exercise the following rights in relation to the personal data covered by this notice, as provided and guaranteed by the Regulation:
• Right of access and rectification (articles 15 and 16 of the Regulation): you have the right to access your personal data and to request that it be corrected, modified, or supplemented. If you wish, we will provide you with a copy of the data we hold about you.
• Right to erasure (article 17 of the Regulation): in the cases provided for by applicable law, you may request the deletion of your personal data. Upon receipt and review of your request, we will cease processing and delete your personal data where the request is deemed legitimate.
• Right to restriction of processing (article 18 of the Regulation): you have the right to request the restriction of the processing of your personal data in the case of unlawful processing or where the accuracy of the personal data is contested by the data subject.
• Right to data portability (article 20 of the Regulation): you have the right to request to receive your personal data from the Data Controller in order to transmit them to another controller, in the cases provided for by the aforementioned article.
• Right to object (article 21 of the Regulation): you have the right to object at any time to the processing of your personal data, explaining the reasons justifying your request; before accepting it, Cromology Italia will assess the grounds of your request.
• Right to lodge a complaint (article 77 of the Regulation): you have the right to lodge a complaint with the competent Data Protection Authority if you believe that a violation of your rights in relation to the processing of your personal data has occurred or is ongoing.
At any time, you may exercise your rights in relation to the specific processing of your personal data by Cromology Italia. Further information regarding data subject rights may be obtained by requesting from the Data Controller the full text of the articles referred to above.
Without prejudice to the above, please note that the rights listed may also be exercised by any person having a legitimate interest, or acting on your behalf as your authorised representative, or for duly protected family reasons, pursuant to Article 2-terdecies of Legislative Decree 101/2018.
Security measures
Cromology adopts appropriate and preventive security measures designed to safeguard the confidentiality, integrity, completeness, and availability of the data subject’s personal data. Technical, physical, and organisational measures are implemented with the aim of preventing damage, including accidental loss, alteration, improper use, and unauthorised access to the processed data.