Privacy Policy

Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (the “Regulations”), Adg Srl, below provides its customers, including potential customers, as well as third parties in general (e.g. proxies, legal representatives, etc.) who come into contact with it on behalf of or on behalf of customers, including potential customers (the “Data Subjects”), with the information required by the regulations regarding the processing of their personal data (“Personal Data”).

1.- Data Controller and Data Protection Officer

Adg Srl (P.IVA 08471381007), headquartered in Via dell’Omo, 121 – 00155 Rome, in the person of its legal representative pro tempore is the entity that processes the data of the Data Subjects and, for the purposes of the Law, is considered the Data Controller of the Personal Data. In this capacity, it is responsible for ensuring the application of appropriate organizational and technical measures for the protection of data in compliance with the provisions of current legislation.

Adg Srl has appointed a Data Protection Officer (DPO), in charge of ensuring compliance with the regulations for the protection of Privacy who can be contacted, for matters related to the processing of Personal Data, at the following address: adgsrl@adgsrl.com

2.- Method of collecting Personal Data

Personal Data subject to processing activities by the Data Controller may be acquired from the Data Subject, including through remote communication techniques that the Data Controller uses (e.g., websites, smartphone and tablet apps, call centers, etc.);

3.- Categories of Personal Data processed

The Personal Data processed by the Owner includes, but is not limited to:

i. browsing data (e.g. IP addresses or domain names of computers used by users connecting to the site, the time of the request, the method used in submitting the request to the server, the numerical code indicating the status of the response given by the server and other parameters related to the operating system and browser used by the user, log);

ii. biographical data (e.g., first name, last name, social security number, address, date and place of birth, nationality);

iii. contact information (e.g., telephone numbers, landline and/or mobile, email address);

iv. profiling and marketing data (e.g., interests and passions);

v. Other data attributable to the above categories.

4.- Purpose and legal basis of processing

Personal Data, when the specified conditions are met, will be processed for the following purposes:

Website registration and handling of requests for contact and/or informational materials

The processing of the Data Subject’s personal data is carried out in order to give effect to the activities preliminary and consequent to the request for registration to the website, if any, as well as for the management of requests for information and contact and/or sending of informative material, as well as for the fulfillment of any other obligations arising.

Legal basis for such processing is the fulfillment of services inherent in the request for registration, information and contact and/or sending of information material and compliance with legal obligations.

The provision of data is optional, however, any refusal by the Data Subject to provide the data will result in the impossibility for the Data Controller to follow up on the requested service.

contract performance

The Personal Data will be processed for the management of the contractual relationship (by way of example, for invoicing fees, handling payments or claims you may submit to us) and for the provision of requested services usable through the website.

Legal basis for such processing is the performance of services inherent in the contractual relationship and compliance with legal obligations.

The provision of data is optional, however, any refusal by the Data Subject to provide the data will result in the impossibility for the Data Controller to follow up on the requested service.

fulfilling legal obligations, defending a right in or out of court, and fraud prevention

Personal Data will be processed for the fulfillment of legal obligations, as well as to ascertain, exercise or defend a right of the Data Controller and/or defend against the claims of others, in or out of court. In particular, the Data Controller may process Personal Data for the fulfillment of accounting and tax obligations and for the fulfillment of measures of the judicial authorities directed at the prevention and suppression of crimes.

Legal basis for such processing is the pursuit of the legitimate interest of the Data Controller taking into account the balancing of the rights of the Data Controller and the Data Subject.

Promotional activities on Services/Products similar to those purchased

The processing of the Interested Party’s personal data is carried out for the purpose of sending communications regarding promotions and offers of the Owner’s Services/Products that are identical and/or similar to those covered by the current contract with the Interested Party, unless the Interested Party has objected to such processing initially or in subsequent communications.

Legal basis for such processing is the legitimate interest of the Controller to promote products or services to which the customer may reasonably be Interested, taking into account the balancing of the rights of the customer and the Controller.

The Data Subject has the right to object at any time, on grounds relating to his or her personal situation, to the processing of personal data concerning him or her for the purpose in question.

Promotional activities on Services/Products offered by Adg Srl

The processing of the Data Subject’s personal data is done for the purpose of sending, upon specific consent, communications of promotions and offers of the Owner’s Services/Products through traditional methods (e.g., regular mail, operator phone calls) and/or automated methods (e.g., e-mail, SMS, MMS, fax, pre-recorded phone calls).

The legal basis for such processing is the consent given by the Data Subject prior to the processing itself, which is revocable freely and at any time, without affecting the lawfulness of the processing previously carried out.

Any refusal of the Interested Party to give consent will result in the impossibility of using the relevant services, without any detrimental consequences for the contractual relationship with the owner.

Marketing purposes related to products or services of Adg Srl’s partners

The processing of the Data Subject’s personal data is carried out for the purpose of sending, subject to specific consent, communications of promotions and offers of Services/Products of Adg Srl ‘s business partners through traditional methods (e.g., regular mail, operator phone calls) and/or automated methods (e.g., e-mail, SMS, MMS, pre-recorded phone calls).

profiling

The processing of Personal Data, including location data, socio-demographic data acquired during the provision of electronic communication services and from public sources, of the Data Subject is carried out, subject to specific consent, for profiling purposes such as analysis of transmitted data and purchased Services/Products in order to propose advertising messages and/or commercial proposals in line with the choices expressed by the users themselves. This activity will be carried out in aggregated and anonymized form through the implementation of models for the analysis of customer data using statistical algorithms, predictive models and aggregations only for the time strictly necessary for the purposes pursued, the type of goods marketed or services rendered.

In any case, Personal Data will not be subjected to decisions based solely on automated processing, including profiling, that produce legal effects or similarly significantly affect the data subject.

5.- Recipients of personal data

The personal data collected may be disclosed to parties who will act as autonomous Data Controllers or Data Processors, as the case may be, for the purposes mentioned above, in fulfillment of legal, regulatory and/or arising from EU legislation or because they have a legitimate interest.

In particular, Personal Data may be made available to:

– Subjects in charge of carrying out activities related and instrumental to the processing (storage service companies, IT service companies, social media management service companies, marketing companies, insurance companies, banking institutions);

– Adg Srl‘s business partners;

– Public Administrations, to Authorities and other parties in fulfillment of legal obligations;

Personal Data will not be disseminated (made available to unspecified parties).

6.- Transfer of data to third countries

The Data Subject’s Personal Data is stored in archives located in countries of the European Union. Where necessary for the pursuit of the stated purposes, the Data Subject’s Data may be transferred abroad, to countries/organizations outside the European Union that guarantee a level of protection of Personal Data deemed adequate by the European Commission in its own decision, or otherwise on the basis of other appropriate safeguards, such as Standard Contractual Clauses adopted by the European Commission or the consent of the Data Subject. The Data Subject has the right to obtain a copy of any Data transferred abroad, as well as a list of the countries/organizations to which the data has been transferred by writing to the email address adgsrl@adgsrl.com

7.- Storage period of personal data

The Data will be kept in a form that allows the identification of the Data Subject for a period of time not exceeding that necessary to achieve the purposes for which it was collected taking into consideration the laws applicable to the activities and sectors in which the Data Controller operates. Once the terms thus established have expired, the Data will be deleted or transformed into anonymous form, unless their further storage is necessary to fulfill obligations (e.g., tax and accounting) that remain even after the termination of the contract (art. 2220 Civil Code) or to comply with orders issued by Public Authorities and/or Supervisory Bodies.

The duration of cookies used on the site can be found in the appropriate Cookie Policy: [Link]

In case of litigation, the above retention time may be extended up to 10 years after the settlement of the litigation.

8.- Methods of treatment

The processing will be carried out by authorized personnel who need to have knowledge of it in the performance of their activities, with the help of electronic instruments, according to principles of lawfulness and fairness, so as to protect at all times the confidentiality and rights of the person concerned in compliance with the provisions of current legislation.

Marketing-related profiling (analysis of consumer habits and choices) is done by an automated process for the purpose of studying and analyzing behavioral profiles and aspects characterizing the customer base to optimize promotional activities for products and services.

9.- Rights of the data subject

The Data Subject has the right to ask the Data Controller:

i. confirmation whether or not any processing of your Personal Data is taking place and, if so, to obtain access to it (right of access);

ii. the rectification of inaccurate Personal Data or the supplementation of incomplete Personal Data (right of rectification);

iii. the deletion of the Personal Data itself if one of the grounds provided by the Privacy Regulations (right to be forgotten) exists;

iv. the limitation of the processing of Personal Data when one of the cases provided for in the Privacy Regulation (right of limitation) occurs;

v. to receive in a structured, commonly used and machine-readable format the Personal Data to be provided to the Data Controller and to transmit such data to another Data Controller (right to portability);

vi. to object at any time in whole or in part to processing carried out in pursuit of a legitimate interest of the Controller and for marketing and profiling purposes (right to object);

vii. to revoke consent, if any, to the processing of Personal Data, at any time, without affecting the lawfulness of the processing based on the consent given prior to revocation.

Consent given for the conduct of marketing activities with automated contact modalities (e.g., sms, mms, fax, phonics, e-mail, web applications) also extends to traditional contact modalities (paper mail or telephone call with operator). Similarly, your objection to the conduct of marketing activities using automated contact methods also extends to traditional contact methods. This is without prejudice to your right to provide consent or to exercise your right to object in relation to only one of the two ways of carrying out marketing activities.

To exercise his or her rights, the Data Subject may send a message to the email inbox or a written communication to the Data Controller at the registered office of Adg Srl.

The Interested Party has, in addition, the right to lodge a complaint with the competent supervisory authority on the territory of Italy (Guarantor Authority for the Protection of Personal Data) or with the one that performs its duties and exercises its powers in the Member State where the violation occurred, as provided for in Article 77 of the Regulation, as well as to take appropriate legal action pursuant to Articles 78 and 79 of the Regulation.

10.- Cookies

Regarding the use of Cookies, see the appropriate Cookie Policy