Privacy Policy

in compliance with art. 13 of EU regulation 679/2016

PTMatic srl (hereinafter called “the Owner”) Owner of the data handling, in compliance with art. 13 of the EU regulation 679/2016 (hereinafter called the “Privacy Regulation”), and with its subsequent modifications and amendments, collects and handles personal data of its own Clients and Suppliers (hereinafter called “the data subject”).

Data handling: purposes and methods.

The personal data of the data subject are handled for the normal activity of the Data Owner to pursue the following purposes:

1. correct and full execution of the obligation provided by the contract (hereinafter called “The contract”)
2. administrative and accounting compliance strictly connected to the Contract;
3. fulfilment of specific obligations prescribed by the communitarian rules in force (e.g. those prescribed for the prevention of money laundering);

The personal data handling is performed by specifically appointed, trained and authorised subjects, under the supervision of the data Owner, in compliance with art. 29 of the Privacy Regulation, using manual or IT tool to guarantee the secrecy and  security of personal data. The personal data handling may also occur on behalf of the data owner, performed by the data handling controller appointed in compliance with art. 28 of the Privacy Regulation.

The personal data will be stored for a period established according to criteria based on the nature and duration of the Agreement and on the protection needs of the data subject’s rights.

Juridical base of the data handling, nature of the conferment and consequences of a possible refusal, and consent of the data subject.

2.1) Purposes for the previous paragraph 1, points 1, 2, and 3.

With reference to the purposes mentioned at paragraph 1, point 1, 2 and 3, the communication of personal data is compulsory and is a necessary requirement to fulfil the Agreement; the failure to communicate personal data may imply the impossibility to obtain the performance, subject of the Agreement, and therefore the juridical base of the related handling is the correct execution and management of the Agreement.

2.2) Purposes mentioned at the previous paragraph 1, point 4.

Subjects or subject categories which data may be communicated and communication range.

In relazione alle finalità del trattamento sopra indicate, e nei limiti strettamente pertinenti alle medesime, i dati personali dell’Interessato saranno o potranno essere comunicati alle seguenti categorie di soggetti:

With regard to the purposes of the processing indicated above, and to the extent strictly pertinent to them, the personal data of the Data Subject will or may be communicated to the following categories of subjects:

1. the tax authorities and other public authorities, where required by law or at their request; 
2. to credit institutions for payment arrangements or other financial activities instrumental to the performance of the Contract
3. to external structures and/or companies used by the Controller to carry out activities related, instrumental or consequent to the performance of the Contract
4. to external consultants (e.g. for the management of tax compliance), if not designated in writing as Data Processors
5. to external parties carrying out control activities, such as auditing companies, board of statutory auditors, supervisory body
6. factoring companies and/or specialised companies or law firms for debt collection and/or for the protection of their interests/rights;

The above-mentioned subjects, to whom the personal data of the Data Subject will or may be communicated (insofar as they are not designated in writing as Data Processors), will process the personal data in their role of Data Controllers within the framework of the Privacy Regulation, in full autonomy, being unrelated to the original processing carried out by the Data Controller.

An up-to-date list of the subjects designated and the Processors can be provided upon request by the Data Subject.I dati dell’Interessato non saranno oggetto di diffusione.

Should this be necessary for the performance of the Contract, the personal data of the Data Subject may be transferred to EU and/or non-EU countries, in full compliance with the provisions of the Privacy Regulation, the relevant measures and decisions of the Privacy Guarantor, as well as EU regulations. In particular, the Data Controller undertakes to comply with the provisions of Decisions 2001/497/EC, 2004/915/EC and 2010/87/EU (depending on the case in question), which require the signing of so-called 'standard contractual clauses' between the legal entities involved in the processing of non-EU data.

Rights of the data subject

Articles 15 et seq. of the Privacy Regulation give the data subject the right to obtain:

• confirmation of the existence or otherwise of personal data concerning him/her, even if not yet recorded, and their communication in intelligible form;
• - indication of the origin of the personal data, the purposes and methods of processing, the logic applied in the event of processing carried out with the aid of electronic instruments, the identification details of the data controller;
• - the updating, amendment, integration, deletion, transformation into anonymous form or blocking of data processed in breach of the law (including data whose storage is not necessary in relation to the purposes for which the data were collected or subsequently processed). The declaration that such procedures have been brought to the attention of those to whom the data have been communicated or disseminated (also as regards their content), except where this proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

The data subject has furthermore the right:

• to revoke at any time the consent given to the processing of personal data, where applicable (without prejudice to the lawfulness of the processing based on the consent given before revocation)
• to object, in whole or in part, on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of collection
• to object, in whole or in part, to the processing of personal data concerning him/her for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication;
• to lodge a complaint with the Garante for the protection of personal data in the cases provided for by the Privacy Regulation;
• to data portability within the limits of Article 20 of the Privacy Regulation
• In order to know the detailed and constantly updated list of the subjects to whom the personal data of the data subject may be communicated and to exercise the rights under Articles 15 et seq. of the Privacy Regulation, the data subject may contact the Data Controller:

PT MATIC S.R.L.

Via Matteotti 146/148 – 20010 BAREGGIO MI

Tel: +39 0290390002 – E.mail: ptmatic@legalmail.it

Bareggio, 25th September 2018

[1] Under Article 4 of the Privacy Regulation, 'personal data' means: 'any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, by reference in particular to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity'.