Information for clients of the Delphina Selection website pursuant to art. 13 of the EU Regulation 679/2016

Preamble

In compliance with EU Regulation 679/2016, containing provisions concerning the protection of personal data, Delphina S.p.A. with administrative headquarters in Palau – 07020, Loc. Cala di Lepre (hereinafter referred to as “Delphina”) as Data Controller is required to provide certain information regarding the use of personal data. In consideration of the foregoing, Delphina’s compliance with the current rules on transparency and mandatory publication of data and documents remains valid.

Data sources and type

Personal data acquired by Delphina may be collected:

• directly from the interested party
• by third parties under those conditions in which Delphina acquires data from external organizations in order to send information or propose offers regarding products and/or services.

In cases of data not being collected directly from the interested party, this information will be made available at the time of registration and in any case not later than the first eventual communication.
Where the existing relationship requires it, the data processed are personal data relating to individuals and, where appropriate, particular data such as sensitive/judicial data. It is possible that in order to comply with specific obligations relating to the management of the relationship (such as accounting and tax requirements, as well as in the case of the management of any legal disputes, out-of-court and /or consultancy), Delphina will be in possession of data identified in terms of law as “sensitive” (such as those from which racial and ethnic origins may possibly be inferred, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, trade union and/or political nature as well as the state of health and judicial data). All these data are however processed in any case for the carrying out of institutional purposes in compliance with the aforementioned law and the confidentiality obligations that have always been respected by Delphina’s activities.
The data will be kept only for the period necessary for the purposes for which they are processed or in accordance with the laws, rules and national and Community regulations to which Delphina must comply (e.g. accounting and tax regulations, etc.).

Purpose of the processing

The data are processed as part of Delphina’s normal activities and according to the following institutional purposes. If the controller intends to further process the personal data for a different purpose than that for which they were collected, he will provide all necessary information to the interested party beforehand.
1) Provision of the services requested by the interested party in the context of the existing relationship / contract (for example: management of the registration account, order management, sales and after-sales customer assistance, payment management, etc.), purposes related to Delphina in terms of services, including external, requested and correlated (shipments, returns, etc.), including the purposes of legitimate related interest, or administrative obligations (e.g. invoicing), accounting and tax performed for purposes of public institutional character, transposition and management of obligations provided for by laws, regulations and national and community legislation, as well as by instructions given by authorities legitimized by law, management of a possible judicial dispute, out-of-court and consultancy activity.
2) the sending of communications and promotional offers, relating to the products or services provided by Delphina by telephone, paper mail, email or other means, including the analysis of consumer behaviour aimed at personalizing commercial offers for analysis and improvement of services provided.

Consent is mandatory for data relating to the processing that Delphina has to carry out in order to fulfil its obligations towards the interested party on the basis of the existing relationship/contract, as well as legal obligations, rules and regulations. Failure to provide such data may make it impossible for Delphina to proceed with the current relationship (purpose 1).
Consent is not mandatory for all other purposes and, even if conferred, may be revoked at any time by the interested party (purpose 2).

Legal basis

The data are processed for the carrying out of the purposes as defined above, within the terms provided for by laws, rules and national and community regulations with which Delphina has to comply. Pursuant to EU Regulation 679/2016, the updated explicit regulatory references that provide for the obligations or tasks on the basis of which the processing of sensitive and judicial data may be processed are available from the Data Controller. These data may be communicated, within the context of the carrying out of the intended purposes only where required by law or regulation. It is without prejudice to the communication or distribution of data required in accordance with the law by police forces, judicial authorities, information and security bodies or other public entities for purposes of defence or security of the state or prevention , ascertainment or repression of crimes.

Method of processing

The data are processed using manual, computerized and telematic tools according to logic protocols strictly related to the purposes themselves and in any case in order to guarantee the security and confidentiality of the data. Archiving is carried out both electronically and on paper. The following essential information relates to these methods:

• The collection of personal data is limited to the minimum necessary for each specific purpose of the processing
• The processing of personal data is limited to the purposes for which they were collected
• The storage of personal data is limited to the minimum necessary for each specific purpose of the processing
• Personal data may be disclosed to third parties, both in Italy and abroad, exclusively for the management of services offered to Delphina customers
• Data will not be communicated outside the European Union. If this eventuality is necessary for the provision of the service, all the procedures and measures required by the law will be adopted
• Personal data will not be sold or rented out

Scope of distribution and interested parties

Within the strictly defined limits relating to the aforementioned purposes, personal data collected by Delphina may also be disclosed to the following subjects or categories of subjects. In addition, data may also be transferred to foreign countries, following evaluation of adequacy, in the case of a foreign customer.

• Subjects with whom communication is required by law, by regulation or by national and EU legislation as well as for the execution of contractual or pre-contractual obligations
• Credit Institutions, Insurance Companies and similar bodies for the execution of contractual or pre-contractual obligations
• Companies monitoring the quality of services provided, companies that carry out the transmission, enveloping, transport and sorting of communications to interested parties
• Legal and accounting consultants for the purpose of studying and resolving any legal problems related to the existing contractual position and external studies specialized in the management of accounting and tax aspects
• Consultants and professionals (technicians, designers, etc.) or companies that collaborate with Delphina in order to provide the requested service or sell the purchased product (e.g. transport companies, cooperatives, associated companies, parent companies, etc.)
• Associated companies for purposes related to relationships with Delphina
• Companies that collaborate with Delphina for marketing and communication activities (only for purpose n.2)

Rights of the interested party

At any time the interested party may exercise his/her rights with regard to the Data Controller, pursuant to EU Regulation 679/2016 through the following addresses: privacy@delphina.it – Delphina S.p.A. with administrative headquarters in Palau – 07020, Loc. Cala di Lepre (for written communications). To guarantee the correct exercise of the rights, the interested party must identify him/herself unequivocally. Delphina undertakes to provide feedback within 30 days and if it is impossible to comply with these deadlines, to justify any extension of the deadlines. The response will be free of charge except in cases of groundlessness (e.g. there are no data concerning the applicant making the request) or excessive requests (e.g. repetitive over time) for which a fee may be charged that will not be higher than the costs actually incurred for the completion of the specific request. The interested party can also send a complaint to the Supervisory Authority. If a personal data breach suffered by Delphina is ascertained, within 72 hours of knowledge of the fact the Data Controller will proceed with notification of the violation to the competent Supervisory Authority and will also communicate the event to the interested party, except in cases of exclusion provided for by the legislation.

Right to know

• origins of personal data
• categories of data processed
• purposes and methods of processing
• storage period
• logic applied in case of processing carried out with the aid of electronic instruments
• identification details of the Data Controller and the Data Processor
• subjects and categories of subjects to whom personal data may be communicated or who can learn about them as managers or persons in third party countries
• existence of the profiling process

Right to request

• confirmation of the existence or otherwise of their personal data and that such data be made available in an intelligible form
• updating, rectification, data integration and limitation
• cancellation, transformation into anonymous form or blocking of data processed in violation of the law (including those for which storage is not necessary in relation to the purposes for which they were collected or subsequently processed)
• certification that the operations referred to in the points above have been brought to the attention of those to whom the data have been communicated or distributed except in the case where this fulfilment proves impossible or involves the use of means manifestly disproportionate to the right protected by Delphina
• copy of the data being processed

Right to oppose

• to the processing of personal data concerning the interested party including profiling for legitimate reasons, even if pertinent to the purpose of the collection
• to the processing of personal data concerning the interested party for the purposes of: sending advertising material, commercial communications, carrying out market research and direct sales
• to the processing of data processed for statistical and/or scientific or historical research, except in the case of public interest in the processing