PRIVACY

PRIVACY POLICY TEMPLATE DATA COLLECTED FROM DATA SUBJECT
Information pursuant to and in accordance with Art. 13-14, EU Reg 2016/679
(European Regulation on the Protection of Personal Data)

Dear Sir/Madam

We would like to inform you that EU Reg. 679/16 (“European Regulation on the Protection of Personal Data”) provides for the protection of persons and other subjects and respect for the processing of personal data.

Pursuant to Articles 13 and 14, therefore, we provide you with the following information:

1. Purpose, legal basis of the processing for which the data are intended

Purposes, legal basis of the processing for which the data are intended The processing of the personal data you provide is aimed solely at performing contractual obligations and fulfilling your specific requests, as well as fulfilling regulatory obligations, particularly accounting and tax obligations. Specifically, the data are processed for purposes as best identified by the following activities. Aries, a limited liability consortium company of the Venezia Giulia Chamber of Commerce, in collaboration with the Trade Associations, supports Trieste businesses with a view to the harmonious development of the territory. Aries provides a range of services from initial information for the creation of new businesses, to the dissemination of entrepreneurial culture among young people, from support for female entrepreneurship, to the orientation of immigrants to business activity, as well as the management of regional, national, and EU contributions. The Company specializes in a wide range of services offered in favor of internationalization and, in line with the strategies of the Chamber of Commerce, accompanies companies in foreign markets by providing assistance and specialized advice as well as implementing a wide range of projects in markets of interest to the companies involved.

Finally, in order to foster the development of the territory, Aries also promotes a series of initiatives, financed by European as well as national Funds, in the most strategic sectors for the economy of the territory. l data will also be processed for the entire duration of the contractual relationship and also subsequently for the fulfillment of legal obligations as well as for our purposes of forming an internal and confidential database. For the purposes of the indicated processing, the data controller may become aware of data defined as special in accordance with EU Reg 2016/679, such as those disclosing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership in parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature, state of health and sex life.

The legal basis is contractual, dependent on consent or ex lege obligations provided for or

2. Method of processing

In relation to the indicated purposes, your data are subject to computer and paper processing. Processing operations are implemented in such a way as to ensure the logical, physical security and confidentiality of your personal data.

3. Legitimate interests pursued by the data controller or third parties

The following requirements are met for the use of legitimate interests as a legal basis for processing:
1) the data controller needs to process the data for its own or a third party’s purposes (e.g., if a finance company is looking for one of its customers who is behind in payments, the company has a legitimate interest in obtaining the customer’s new address even in the absence of specific consent);
2) the interests of the data controller must be balanced against those of the data subject, and thus the processing appears unjustified if it has detrimental effects on the rights and freedoms, or legitimate interests, of the individual (going back to the example above, it is clear that the customer’s interest in not paying taxes cannot be considered legitimate or justified);
3) the processing of information must be fair and comply with data protection principles (so the finance company must ensure that the data is accurate, up-to-date, not excessive-the company obtains only the data necessary for the purpose, tracking the customer-.

4. Nature of personal data

Your personal, sensitive and judicial data inherent to the performance of the service you have requested constitute the object of processing.

During the provision of the service it may be necessary to acquire and carry out processing operations of your sensitive and judicial personal data. You are requested to express the relevant consent in writing.

5. Compulsory or optional nature of conferment

The provision of your personal and sensitive data, is not compulsory in nature, but refusal to do so may make it impossible or extremely difficult to provide the services you have requested.

6. Scope of communication and dissemination of data

Your data may be communicated to:

all subjects to whom the right of access to such data is recognized by virtue of regulatory provisions;

to our collaborators, employees, within the scope of their duties;

to all those natural and/or legal, public and/or private persons when the communication is necessary or functional to the performance of our activities and in the manner and for the purposes described above;

6. Transfer of personal data to a third country the transfer of data outside the EU or to international organizations takes place in compliance with the regulation with specific attention to the means and authorizations and with specified written authorization of the user and issued for the purposes as better described in point one.
7. Mode and duration of storage of personal data The storage of personal data is put in place in compliance with Regulation 2016/679 and the provisions of the law in force at the headquarters of Aries, Società consortile a r.l. of the Chamber of Commerce Venezia Giulia Piazza della Borsa 14, 34121 Trieste The Data is held at II Owner of the processing of your personal data is Aries, Società consortile a r.l. of the Chamber of Commerce Venezia Giulia Piazza della Borsa 14, 34121 Trieste.
9. Identification details of the Data Controller, Data Processor and Privacy Officer The Data Controller of your personal data is Aries, Società consortile a r.l. of the Camera di Commercio Venezia Giulia Piazza della Borsa 14, 34121 Trieste in the person of the legal representative pro tempore.
   The appointed Dpo is Dr. VISINTIN Paolo who can be reached at the email dpo@ariestrieste.it
11. Rights of the interested party

9.1 Art. 15 (right of access) , 16 (right of rectification) of EU Reg. 2016/679
The data subject has the right to obtain from the data controller confirmation as to whether or not personal data concerning him or her are being processed and, if so, to obtain access to the personal data and the following information:
(a) the purposes of the processing;

(b) the categories of personal data concerned;

(c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly if recipients in third countries or international organizations;

(d) the intended retention period of the personal data or, if this is not possible, the criteria used to determine this period;
(e) the existence of the data subject’s right to request from the controller the rectification or erasure of personal data or the restriction of the processing of personal data concerning him or her or to object to their processing
(f) the right to lodge a complaint with a supervisory authority;

(h) the existence of an automated decision-making process, including profiling, and, at least in such cases, meaningful information about the logic used, as well as the importance and expected consequences of such processing for the data subject.
9.2 Right under Article 17 of EU Reg. 2016/679 – right to erasure (“right to be forgotten”)

The data subject has the right to obtain from the data controller the erasure of personal data concerning him or her without undue delay, and the data controller is obliged to erase the personal data without undue delay, if any of the following grounds exist:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) the data subject withdraws the consent on which the processing is based in accordance with Article 6(1)(a) or Article 9(2)(a) and if there is no other legal basis for the processing;

(c) the data subject objects to the processing pursuant to Article 21(1) and there is no overriding legitimate ground for processing, or objects to the processing pursuant to Article 21(2);

(d) personal data have been processed unlawfully;

(e) the personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the controller is subject;
(f) personal data have been collected in relation to the provision of information society services as referred to in Article 8(1) of EU Reg. 2016/679
9.3 Right referred to in Art. 18 Right to restriction of processing.

9.3 Right referred to in Article 18 Right to limitation of processing.

The data subject has the right to obtain from the data controller the restriction of processing when one of the following cases occurs:
(a) the data subject disputes the accuracy of personal data, for the period necessary for the data controller to verify the accuracy of such personal data;

b) the processing is unlawful and the data subject objects to the erasure of the personal data and instead requests that their use be restricted;

(c) although the data controller no longer needs the personal data for the purposes of the processing, the personal data are necessary for the data subject to establish, exercise or defend a legal claim; and

(d) the data subject has objected to the processing pursuant to Article 21(1) EU Reg 2016/679 pending verification as to whether the legitimate grounds of the data controller override those of the data subject.
9.4 Right under Article 20 Right to data portability
The data subject has the right to receive in a structured, commonly used and machine-readable format personal data concerning him or her that has been provided to a data controller and has the right to transmit such data to another data controller without hindrance by the data controller

10) Scope of data communication and access.

The user’s personal data may be communicated to:

all parties to whom the right of access to such data is recognized by virtue of regulatory provisions;

to our collaborators, employees, within the scope of their duties;

to all those natural and/or legal, public and/or private persons when the communication is necessary or functional to the performance of our activity and in the manner and for the purposes described above;

11) Nature of provision of personal data

The provision of certain personal data by the user is mandatory in order to allow the Company to handle communications, requests received from the user or to re-contact the user to follow up on his/her request. This type of data is marked by the asterisk symbol [*] and in this case the provision is mandatory to allow the Company to follow up on the request, which, in default, cannot be processed. On the contrary, the collection of the other data not marked by the asterisk is optional: failure to provide it will have no consequences for the user. The provision of personal data by the user for marketing purposes, as specified in the section “Purposes and methods of processing” is optional and refusal to provide it will have no consequences. The consent given for marketing purposes is understood to extend to the sending of communications carried out through both automated and traditional modes and/or means of contact, as exemplified above.

12) Rights of the interested party

12.1 Art. 15 (right of access) , 16 (right of rectification) of the EU Reg. 2016/679

The data subject has the right to obtain from the data controller confirmation as to whether or not personal data relating to him or her are being processed and, if so, to obtain access to the personal data and the following information:

(a) the purposes of the processing;

(b) the categories of personal data concerned;

(c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly if recipients in third countries or international organizations;

(d) the intended retention period of the personal data or, if this is not possible, the criteria used to determine this period;

(e) the existence of the data subject’s right to request from the controller the rectification or erasure of personal data or the restriction of the processing of personal data concerning him or her or to object to their processing

(f) the right to lodge a complaint with a supervisory authority;

(h) the existence of an automated decision-making process, including profiling, and, at least in such cases, meaningful information about the logic used, as well as the importance and expected consequences of such processing for the data subject.

12.2 Right under Article 17 of EU Reg. 2016/679 – right to erasure

(“right to be forgotten”) The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall be obliged to erase the personal data without undue delay, if any of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(b) the data subject withdraws the consent on which the processing is based in accordance with Article 6(1)(a) or Article 9(2)(a) and if there is no other legal basis for the processing;

(c) the data subject objects to the processing pursuant to Article 21(1) and there is no overriding legitimate ground for processing, or objects to the processing pursuant to Article 21(2);

(d) personal data have been processed unlawfully;

(e) the personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the controller is subject;

(f) personal data have been collected in connection with the provision of information society services as referred to in Article 8(1) of EU Reg. 2016/679

12.3 Right referred to in Article 18 Right to limitation of processing.

The data subject has the right to obtain from the data controller the restriction of processing when one of the following cases occurs:

(a) the data subject disputes the accuracy of personal data, for the period necessary for the data controller to verify the accuracy of such personal data;

b) the processing is unlawful and the data subject objects to the erasure of the personal data and instead requests that their use be restricted;

(c) although the data controller no longer needs the personal data for the purposes of the processing, the personal data are necessary for the data subject to establish, exercise or defend a legal claim; and

(d) the data subject has objected to the processing pursuant to Article 21(1) EU Reg 2016/679 pending verification as to whether the legitimate grounds of the data controller override those of the data subject.

12.4 Right under Article 20 Right to data portability

The data subject has the right to receive in a structured, commonly used and machine-readable format personal data concerning him or her provided to a data controller and has the right to transmit such data to another data controller without hindrance from the data controller

13. Revocation of consent to processing

The data subject may withdraw consent to the processing of his or her personal data by sending a registered letter with return receipt to the following address: Aries – Società consortile a r.l. della Camera di Commercio Venezia Giulia Piazza della Borsa 14, 34121 Trieste accompanied by a photocopy of your identity document, with the following text: <>. At the end of this operation, your personal data will be removed from the archives, unless otherwise provided by law, as soon as possible.

If you wish to have more information on the processing of your personal data, or to exercise your rights under point 7 above, you may send a registered letter with return receipt to the following address: Aries – Società consortile a r.l. della Camera di Commercio Venezia Giulia Piazza della Borsa 14, 34121 Trieste. Before we can provide you, or change any information, we may need to verify your identity and answer some questions. An answer will be provided as soon as possible.