BILLO S.R.L., with registered office in Merlara (PD), Viale dell ‘Industria, no. 155, Tax Code and VAT no. 04251800282, in the person of its legal representative pro tempore, hereinafter also only “BILLO”, or “Data Controller”, insofar as Data Controller pursuant to EU Regulation No. 679/2016 – General Data Protection Regulation (hereinafter “GDPR”), and applicable national legislation pro tempore on personal data protection (Italian Legislative Decree no. 196/2003 and subsequent amendments), recognises the importance of personal data protection and considers it to be one of the main objectives of its business activities.
Consultation of the Website by the user involves the release of information having the nature of personal data.
“Processing” of personal data means any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, erasure or destruction.
BILLO informs you that the processing of your personal data will take place through manual, computer and/or telematic tools and will be based on the principles of lawfulness, fairness, transparency, limitation of purposes and storage, minimisation of data, accuracy, integrity and confidentiality. Your personal data will therefore be processed with logics strictly related to the purposes indicated below concerning consultation and use of the Website, in accordance with the provisions of the GDPR and applicable national legislation on personal data protection and, in any case, in order to guarantee the security and confidentiality of the data itself.
- DATA CONTROLLER
In light of the applicable legislation, the Data Controller is BILLO S.R.L., with registered office in Merlara (PD), Viale dell ‘Industria n. 155, Tax Code and VAT no. 04251800282.
The updated list of Data Processors and persons authorised to process data is kept at the aforementioned headquarters of the Data Controller.
2. PERSONAL DATA SUBJECT TO PROCESSING
“Personal Data” means any information concerning an identified or identifiable natural person with particular reference to an identifier such as a name, identification number, location data, online identifier or one or more elements characteristic of his or her physical, physiological, psychological, economic, cultural or social identity.
The following type of Personal Data is collected from the Website:
A) Navigation data
The computer systems of the Website collect certain Personal Data, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected to be associated with you, but by its very nature may, through processing and association with data held by third parties, allow users to be identified. Said data includes the IP addresses or domain names of the devices used by users who connect to the Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to your operating system and computer environment.
This data is used in order to obtain anonymous statistical information on use of the Website and to check its correct functionality; to allow – given the architecture of the systems used – the correct provision of the various services requested by you, for security reasons and to ascertain responsibility in the event of hypothetical computer crimes against the Website or third parties.
B) Data provided voluntarily
Apart from that specified above in regards to navigation data necessary to implement computer and telematic protocols, the provision of Personal Data by users of the Website is free and optional, albeit functional to the provision of certain services: in these cases, therefore, failure to provide data may compromise or make it impossible to provide the service.
In particular, through the Website you have the possibility to voluntarily provide Personal Data, such as, for example, name, surname, date and place of birth, address of residence, tax code and VAT number, company name, registered company address, fixed and/or mobile telephone number, email address, certified email address, bank and payment references, through the optional and voluntary sending of email messages containing contact requests, requests for quotations, spontaneous job applications by sending CVs or any type of communication to the addresses or contact details indicated on the Website or by filling in the “Request for Information” form on the Website. The sending of such communications will entail the acquisition of your email address, necessary to respond to your requests and any other Personal Data transmitted by you. Such data provided by users who voluntarily interact with the Website, is used solely for the purpose of carrying out the requested service and is communicated to third parties only if this is strictly necessary for the execution of the service itself or if required by law.
BILLO will process the aforementioned data in compliance with the provisions of the GDPR and applicable national legislation on personal data protection, assuming that it refers to you or to third parties who have expressly authorised you to provide it on the basis of a valid legal basis that legitimises the processing of the data in question. With respect to these hypotheses, you stand as an independent data controller, assuming all legal obligations and responsibilities. In this sense, you grant the widest indemnity on this point with respect to any dispute, claim, request for compensation for processing damage, etc. that may be received by BILLO from third parties whose Personal Data has been processed through the Website in breach of the applicable legislation.
C) Cookies and related technologies
3. METHOD, PURPOSE, LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING, CONSEQUENCES OF REFUSAL
The collection and processing of Personal Data by BILLO is carried out in compliance with the principles of lawfulness, fairness and transparency and in such a way as to ensure adequate security, including protection, through appropriate technical and organisational measures, against unauthorised or unlawful processing and against accidental loss, destruction or damage.
Processing connected to the web services of the Website is carried out using mainly automated and electronic tools and handled by BILLO staff, authorised to this end to process Personal Data, as well as by third parties insofar as Data Processors specifically appointed and instructed by BILLO insofar as the Data Controller and in relation to the specific services provided, or by independent “Data Controllers”, authorised to access said data by virtue of legal provisions, regulations and legislation.
No data deriving from BILLO’s web services, except in anonymous and aggregate form, is disclosed.
The Personal Data you provide through the Website will be processed by BILLO for the following purposes:
- purposes related to the execution of a contract to which you are a party or the execution of pre-contractual measures adopted at your request (e.g. contact request, registration in the reserved area, etc.);
- statistical research/analysis on aggregated or anonymous data, without the possibility of identifying the user, aimed at measuring the functionality of the Site, measuring traffic and evaluating usability and interest;
- the fulfilment of obligations set out by the law, a regulation, European legislation or an order of the authority, including accounting, administrative and tax obligations, to which BILLO is subject;
- purposes necessary to ascertain, exercise or defend a right in judicial proceedings or whenever the judicial authorities exercise their judicial capacity.
The legal basis for the processing of personal data for the purposes referred to in point A) above is the execution of a contract to which you are a party or the execution of pre-contractual measures adopted at your request.
The purpose referred to in point B) does not involve the processing of personal data, whereas the legal basis for the processing of personal data for the purposes referred to in point C) is the fulfilment of a legal obligation to which the Data Controller is subject, while for the purposes referred to in point D) it is the pursuit of the legitimate interest of the Data Controller.
Please note that, taking into account the purposes of the processing as illustrated above, the provision of your personal data for the purposes referred to in points A), B), C) and D) above is mandatory. Failure, partial or incorrect provision and/or express refusal to process on your part will make it impossible for the Data Controller to fulfil your requests, process any purchase orders or fulfil the contractual obligations assumed or a legal obligation to which the Data Controller is subject or the requests of the competent Authorities.
We inform you that if you are already a customer, we may send you commercial communications relating to BILLO products and services similar to those already used, unless you disagree.
4. CATEGORIES OF RECIPIENTS
Your Personal Data may be shared, for the purposes specified in Article 3 above, with:
a) subjects necessary for the provision of the services offered by the Website, including, by way of example, the sending of emails and the maintenance and analysis of the operation of the Website and other external subjects, each in their specific field of competence, with whom the Data Controller maintains relationships necessary to carry out its activities or due to a legal obligation, to whom a specific mandate has been entrusted and for the time necessary to achieve the purposes for which the data was collected, who act, where necessary, as Data Processors of BILLO;
b) persons authorised by BILLO to process Personal Data who have committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. BILLO employees and collaborators);
c) judicial or supervisory authorities, administrations, bodies and public bodies, in exercising their capacity, when required by law.
In any case, your data will not be disclosed.
Your Personal Data will not be transferred to third countries outside the European Union.
6. DATA RETENTION
Processing connected to the web services of the Website takes place at the ____________________________ data centre, as well as at the aforementioned headquarters of the Data Controller and on the devices of the same.
The management and storage of Personal Data takes place on servers located within the European Union owned and/or made available to the Data Controller and/or third parties authorised to process.
BILLO will process your Personal Data for the time strictly necessary to achieve the purposes indicated in Article 3 above. Without prejudice to the foregoing, BILLO will process your Personal Data for as long as allowed by Italian law to protect its interests.
More information about the Personal Data retention period and the criteria used to determine this period can be requested by writing to the addresses indicated above.
7. YOUR RIGHTS
In accordance with the provisions of the GDPR, you may exercise the following rights:
- right of access – obtain confirmation of whether or not personal data concerning you is being processed, and, in this case, receive information relating, in particular, to: purposes of the processing, categories of personal data processed and retention period, recipients to whom said data may be communicated (Article 15, GDPR);
- right to rectification – obtain, without undue delay, the rectification of inaccurate personal data concerning you and the integration of incomplete personal data (Article 16, GDPR);
- right to erasure – obtain, without undue delay, the erasure of personal data concerning you, in the cases provided for by the GDPR (Article 17, GDPR);
- right of limitation – obtain from the Data Controller the restriction of processing, in the cases provided for by the GDPR (Article 18, GDPR);
- right to portability – receive in a structured format, commonly used and readable by an automatic device, the personal data concerning you provided to the Data Controller, as well as obtain the transmission of said data to another data controller without hindrance, in the cases provided for by the GDPR (Article 20, GDPR);
- right to object – object to the processing of personal data concerning you, unless there are legitimate reasons for the Data Controller to continue processing (Article 21, GDPR);
- right to withdraw any consent given at any time, without prejudice to the lawfulness of processing based on consent given prior to withdrawal;
- right to lodge a complaint with the Data Protection Authority or other supervisory authority (Art. 77, GDPR).
You may at any time exercise your rights as indicated above by sending:
– a registered letter to the Data Controller at its registered office: BILLO S.R.L., Viale dell ‘Industria, 155 – 35040 Merlara (PD)
– an email to the Data Controller at: firstname.lastname@example.org