CLIENT PRIVACY POLICY PURSUANT TO ART. 13 OF THE REGULATION (EU) 2016/679
Dear Client,
to provide you with the requested services we need to collect some personal data. Pursuant to art. 13 of the Regulation (EU) 2016/679, we wish to inform you that you are a Data Subject and why and how your data will be processed.
CATEGORIES OF PERSONAL DATA PROCESSED
- data provided by the Client: name, surname, including information and/or copy of the identity document, contacts (address, phone number, email address…);
- data from public registers, lists, deeds or documents available to anyone;
- other data from legitimately accessible sources in relation to the nature of the activities and the purposes indicated below;
- data collected during the activities carried out on the specific mandate of the interested party.
The aforementioned data may include, only if relevant and necessary in relation to the purposes indicated below: data relating to criminal convictions and offences of the data subject, data revealing his/her ethnic or racial origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or sexual life and sexual orientation of the person.
SOURCE OF PERSONAL DATA
Collection and updating of personal data may take place:
- through the person concerned or, if a minor, through those who exercise parental responsibility (parents, guardians, persons delegated by them);
- through intermediaries authorized by the interested party (lawyer, guardian, other);
- from sources freely accessible to anyone;
- from the investigative activity.
PURPOSE OF THE PROCESSING AND LEGAL BASIS
Personal data collected will be processed for the following purposes:
- correct and complete execution of the assignment received – to fulfill obligations arising from the performance of the contract to which the data subject is party for the establishment, exercise or defense of legal claims;
- administrative obligations;
- civil obligations;
- tax obligations;
- social security obligations;
- organizational, management obligations;
- legal obligations.
Processing is lawful because of the following conditions:
- art. 6, par. 1, let. b) GDPR:
“processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”; - art. 6, par. 1, let. c) GDPR:
“processing is necessary for compliance with a legal obligation to which the controller is subject”.
OBLIGATION TO PROVIDE PERSONAL DATA
The Data Subject is obliged to provide the Data Controller with his/her personal data, as requested by art. 135, last par. TULPS. Processing of tax and administrative obligations arising from the performance of the service is mandatory. In case of refusal, the requested activity cannot be carried out.
DISCLOSURE TO SUBJECTS OTHER THAN THE CONTROLLER
Personal data provided may be disclosed to:
- suppliers based on contractual and/or legal obligations;
- subjects allowed to access data pursuant to national or EU law, within the scope and limits of this legislation;
- banks, credit institutions, credit card issuers, data processing companies and professionals for activities strictly related to the performance of the contract;
- institutions, consortia, professionals and companies for credit recovery and protection, credit insurance companies, commercial information companies;
- other subjects, such as collaborators or private investigators within the limits strictly necessary for the fulfillment of the mandate and support in carrying out the investigations;
- other subjects for tax, accounting, insurance, management/maintenance of information systems, financial services. They will assume the role of Processor or Joint Controller for the processing carried out by them, always for the purposes specified above, and will be bound to full compliance with confidentiality and security obligations.
TRANSFER OF PERSONAL DATA OUTSIDE THE NATIONAL TERRITORY
Personal data may be transferred to foreign countries of the European Union or non-EU countries, whenever necessary and limited to data strictly relevant to the purpose of the mandate.
PROCESSING MODALITIES AND DATA STORAGE PERIODS
In relation to the aforementioned purposes, the processing of personal data may take place by paper, IT and telematic tools. Always guaranteeing the most absolute confidentiality, relevance and not excess with respect to the purposes described above.
The data relating to the investigation commissioned by the mandate will be stored for the strictly necessary period. If not indicated, the deadline is 30 days.
The data relating to the fulfillment of tax and administrative obligations, or for the purpose of compliance with contractual obligations, will be stored for the period required by law for accounting documentation (10 years).
RIGHT OF ACCESS BY THE DATA SUBJECT
The Data Subject has the right to obtain from the Controller the access to his/her personal data.
The Data Subject has also the right to request from the Controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing.
RIGHT TO WITHDRAW THE CONSENT
The Data Subject has the right to withdraw his/her consent at any time, without prejudice to the lawfulness of processing based on consent before its withdrawal. This is without prejudice to the data which are kept as proving the execution of the contract and the related payment obligation and those relating to compliance with laws and regulations, to which the Controller is subjected.
RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
The Data Subject has the right to lodge a complaint with the supervisory authority (Garante per la protezione dei dati personali, Piazza Montecitorio n. 121, Rome, phone number: 06.696771, email address: garante@gpdp.it, pec: protocollo@pec.gpdp.it).
AUTOMATED DECISION-MAKING PROCESS
The use of an automated decision-making process or of a profiling process pursuant to art. 22, par. 1-4 does not exist and is not expected.
DATA CONTROLLER
AGENZIA INVESTIGATIVA PRATESE
Via Fratelli Giachetti nr. 28/3
59100 – Prato (PO)
Italy
P.I. e CF 01754990974
Phone number: +39 0574 401179
Email address: info@agenziainvestigativapratese.it
Requests must be addressed to the Data Controller using the contact details indicated, always bearing in mind that it will not be possible to respond to requests by phone if there is no certainty about the identity of the incoming call.
Latest update: September 14, 2019