PRIVACY DISCLOSURE
Disclosure pursuant to Article 13 of the 2016/679 EU Regulation
(personal data collected from the interested party)
We wish to inform you, pursuant to articles 12,13 and 14 of the 2016/679 European Regulation, also known as “General Data Protection Regulation” (hereinafter “GDPR”) concerning the protection of individuals with regard to the processing of personal data, as well as free circulation of such data, that the information and data supplied by You or otherwise acquired within the services provided by Tendercapital LTD will be processed in compliance with the above-mentioned provisions and with the confidentiality obligations that inspire the activity of our organization .
By processing of personal data we mean any operations or complex of operations, carried out also without the aid of electronic tools, concerning the collection, the registration, the organization, the storage, the consultation, the processing, the modification, the selection, the extraction, the comparison, the use, the interconnection, the blocking, the communication, the dissemination, the deletion and the destruction of data, even if not recorded in a database.
The purpose of this disclosure statement is to make known in full transparency the purposes for which we could use Your data, how we will handle them, whom could they be communicated to, where could they be transferred (inside or outside the EU) ) and which are Your rights.
WHO PROCESSES YOUR DATA?
Your data will be processed by Tendercapital LTD as Data Controller.
In addition to Tendercapital LTD we are hereby informing You that External Managers of the processing of personal data are present, which have been appropriately mapped, registered, contracted and nominated by Tendercapital LTD on the basis of the provisions of art. 28 of the GDPR. The list of External Managers for the processing of personal data is available at the headquarters of Tendercapital LTD.
WHY DO WE NEED YOUR DATA?
RUSTIONI&PARTNERS will use your data exclusively for the following purposes:
1. Purposes related to the management of the contractual relationship and the provision of the Services. Your data will be processed for the following purposes: establishment, management and termination of the contractual and commercial relationship; fulfillment of accounting and tax obligations; fulfillment of legal obligations (for example: anti-terrorism checks); anti-money laundering controls; audits of fiscal and accounting nature; management of disputes; provision, support, updating and information regarding the offered Services and the available features.
2. Purposes related to marketing activities and newsletters. With Your specific consent, Your data will be processed for the following purposes: sending monthly newsletters with updates on the strategies and performance of Tendercapital products, sending weekly and monthly newsletters on market trends and financial indices, sending of “special” single-issue newsletters in the event of particular occurrences in the world that may have repercussions in the financial sector, sending of quarterly newsletters on the performance of specific investment sectors, sending advertising material, invitation to corporate events and updates on company initiatives like the TenderToArt projects.
3. Purposes related to recording and processing of the image: with Your explicit consent, the data You provide (for example: images taken by filming and / or photographing, interviews during events organized by Tendercapital LTD in which You will take part) will be processed for promotion activities and increase of Tendercapital LTD brand reputation.
Tendercapital LTD will carry out the treatment:
• based on Your consent;
• because it is necessary for the contractual obligations referred to in point 1;
• because it is necessary in order to fulfill the legal obligations which You are subject to (eg accounting, retributive, social security obligations, anti-terrorism checks);
• because the treatment is necessary to pursue a legitimate interest (eg anti-money laundering checks, use of video surveillance tools to protect corporate assets, fraud prevention, safeguarding strategic corporate interests and related business relationships).
Therefore the provision of personal data is mandatory for the purposes referred to in point 1.
Failure to provide the data will make it impossible to achieve the purposes previously mentioned and therefore to follow up the contractual relationship.
The purposes 2 and 3 do not constitute a legal obligation and the conferment of the relative consent is optional.
The entity and the adequacy of the provided Data will be assessed from time to time, in order to determine the resulting decisions and avoid the processing of data exceeding the purposes pursued.
Tendercapital LTD undertakes not to use Your personal data for any other purpose other than those described in this statement, unless we inform You in advance and, where necessary, obtaining Your consent.
HOW WE WILL USE YOUR DATA?
Tendercapital LTD aims to protect the data of its customers, shaping their treatment around the principles of correctness, lawfulness and transparency. We inform You, therefore, that your personal data will be processed, by means of tools and procedures suitable to ensure maximum security and confidentiality, through archives and in paper form, with the aid of digital media, computer and telecommunications.
We would like to remind You that you have the authority to exercise the right of opposition that, in the absence of Your opposite indication, will be referred to both traditional and automated communications.
HOW LONG WILL WE HOLD YOUR INFORMATION?
Your personal data will be stored, starting from their receipt / update, for a period consistent with the purposes they are intendent to (5 or 10 years depending on the document as prescribed by law for accounting documents and up to unsubscribing from the newsletter for other purposes) and respecting what is required by law in the first place.
WILL WE SHARE YOUR INFORMATION WITH OTHER PARTIES? ?
For the purposes previously indicated (“Why do we need your data”) your data may be disclosed to third parties, [including Debt Collection Companies, User Companies, Professionals, Sector Bilateral Bodies (ex art.24 , paragraph 2, letter h), CCNL Administration Agencies, Public Authorities, Auditing or Supervision Organizations], to fulfill obligations deriving from the law, regulations, community regulations or for aspects concerning the management and implementation of the contractual relationship.
For all the purposes indicated in this statement (points 1 and 2) Your data may also be transferred to our Business Partners, duly selected, operating in the country of relevance of the applicant and offering a level of data security considered “adequate”, all in order to offer the applicant a more efficient service.
The Data will also be processed by internal resources of Tendercapital LTD, adequately trained, operating as authorized staff to process the Data.
Access to the stored Data may be carried out only by public authorities, in the cases and methods provided for by the governing laws, in the event of legal disputes.
Your personal data will not be subject to disclosure.
WHICH ARE YOUR RIGHTS?
At any time, you will have the right to ask:
• access to Your personal data;
• their correction in case of inaccuracy;
• cancellation;
• the limitation of their processing.
You will also have:
• the right to deny their processing;
• the right to their transferral, i,.e to receive, in a structured format, of common use and readable by automatic device, the personal data supplied by You.
We will handle your request with the utmost care to ensure the effective exercise of Your rights.
Finally, you will have the right to file a complaint with the National Supervisory Authority (Privacy Guarantor).
For comprehensive knowledge of all the rights of the interested party refer to Chapter III of the GDPR.
CAN YOU WITHDRAW YOUR CONSENT ONCE GIVEN?
Yes, you can revoke Your consent at any time. Such withdrawal, however, will be wihout prejudice to any of the following:
• any preoviuos lawwfull act of data processing based on the consent given before the revocation;
• further processing of the same data based on other legal entitlements (for example, contractual obligations or legal obligations to which RUSTIONI&PARTNERS is subject to).
The details identifying the Data Controller for the processing of data provided by You are as follows:
RUSTIONI&PARTNERS Piazza Borromeo, 10
Milano 20123 – ITALY
T. +39.02.58303994 which You can contact at any time to exercise the rights required by the GDPR and listed above in detail.
The Data Controller
RUSTIONI&PARTNERS