INFORMATION
pursuant to European Regulation 2016/679 Information pursuant to Article 13 of EU Regulation 2016/679 (personal data collected from the interested party

We wish to inform you, pursuant to Articles 12, 13, and 14 of European Regulation 2016/679, also known as the “General Data Protection Regulation” (hereinafter “GDPR”), on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, that the information and data provided by you or otherwise acquired as part of the services provided by PADA srl will be processed in compliance with the aforementioned provisions and the confidentiality obligations that inspire our organization’s activities. By processing of personal data, we mean any operation or set of operations, performed even without the aid of electronic tools, concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, erasure, and destruction of data, even if not recorded in a database. The purpose of this policy is to provide you with complete transparency regarding the purposes for which we may use your data, how we will manage it, to whom it may be disclosed, where it may be transferred (within or outside the EU), and what your rights are.

Who processes your data?
Your data will be processed by PADA srl as the Data Controller. In addition to PADA srl, we would like to inform you that there are external data processors who have been appropriately mapped, registered, contracted, and appointed by PADA srl in accordance with the provisions of Article 28 of the GDPR. The list of external data processors is available at the PADA srl headquarters.

Why do we need your data? PADA srl will use your data exclusively for the following purposes:

Purposes related to the management of the contractual relationship and the provision of 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 controls); anti-money laundering controls; tax and accounting audits; dispute management; provision, support, updates, and information regarding the Services offered and available features. Purposes related to marketing activities and newsletters. With your specific consent, your data will be processed for the following purposes: sending newsletters, advertising, informational, promotional materials, and updates on PADA srl initiatives, promotions, and offers.

PADA srl will carry out the processing

on the basis of your consent; because it is necessary for the contractual obligations referred to in point 1; because it is necessary to fulfill the legal obligations to which you are subject (e.g. accounting, salary, social security obligations, anti-terrorism controls;

because the processing is necessary to pursue a legitimate interest (e.g., anti-money laundering checks, use of video surveillance tools to protect company assets, fraud prevention, safeguarding strategic corporate interests and related business relationships).

It follows that the provision of Personal Data is mandatory for the purposes referred to in point 1. Failure to provide such data will make it impossible to achieve the previously indicated purposes and therefore to continue with the contractual relationship. Purpose 2 does not arise from a legal obligation, and providing the relevant consent is optional. The scope and adequacy of the Data provided will be assessed on a case-by-case basis to determine the resulting decisions and avoid processing Data exceeding the intended purposes. PADA srl undertakes not to use your personal data for purposes other than those described in this policy, unless we inform you in advance and, where necessary, obtain your consent.

How will we use your data?
PADA srl aims to protect its customers’ data, basing its processing on the principles of fairness, lawfulness, and transparency. We therefore inform you that your personal data will be processed using tools and procedures designed to ensure maximum security and confidentiality, using archives and paper-based media, as well as digital, IT, and telematic means. We would like to remind you that you have the right to object, which, unless you indicate otherwise, will apply to both traditional and automated communications. How long will we retain your information? Your personal data will be retained, starting from its receipt/update, for a period appropriate to the processing purposes described above and in compliance with the provisions of the law. In the interest of full transparency, the “Data Retention Policy” document, an integral part of the company’s Data Protection Management System, is available at the PADA srl headquarters. You have the right to request a copy by contacting the company at the following email address: info@pa-da.it. The same document also contains information on the criteria used to determine this period. Will we share your information with other parties? For the purposes indicated above (“Why we need your data”), your data may be disclosed to third parties [including debt collection agencies, user companies, professionals, bilateral sector bodies (pursuant to art. 24, paragraph 2, letter h), collective bargaining agreements for temporary employment agencies, public bodies, auditing or supervisory bodies], to fulfill obligations arising from the law, regulations, EU legislation, or for aspects relating to the management and execution of the contractual relationship. For all the purposes indicated in this policy (points 1 and 2), your data may also be disclosed to our carefully selected business partners who operate in the applicant’s country of residence and who offer an adequate level of data security, all in order to offer the applicant a more efficient service. The data will also be processed by appropriately trained internal resources of PADA srl, who operate as personnel authorized to process the data. Access to archived data may only be granted to public authorities, in the cases and ways provided for by applicable laws, in the event of legal disputes. Your personal data will not be disclosed.

What are your rights?
At any time, you will have the right to ask:

access to your personal data; rectification of inaccuracies;                           erasure;                                                                                                                                                                                      and limitation of processing.

You will also have:

the right to object to their processing unless they are processed for the pursuit of a compelling legitimate interest of PADA srl; the right to data portability, i.e., to receive the personal data you have provided in a structured, commonly used, and machine-readable format.

We will process your request with the utmost commitment to ensure the effective exercise of your rights. Finally, you have the right to lodge a complaint with the national supervisory authority (Data Protection Authority). For complete information on all data subject rights, please refer to Chapter III of the GDPR. Can you withdraw your consent once given? Yes, you can withdraw your consent at any time, without, however;

affect the lawfulness of processing based on consent given before its withdrawal; affect further processing of the same data based on other legal bases (for example, contractual obligations or legal obligations to which PADA srl is subject).

The identifying details of the Data Controller for the processing of the data provided by you are as follows:

PADA srl, with headquarters in Arluno, Via E. Ferrari 16, which you may contact at any time to exercise the rights provided for by the GDPR and listed above. The Data Controller is PADA srl.