5.Personal Data Processing

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PERSONAL DATA PROCESSING

(Art. 13 of EU Regulation 679/2016 – General Data Protection Regulation – GDPR)

DATA CONTROLLER

picotecno of Silvio Simonetti, with its registered office in Italy, Tirolo, Via Ruprecht, 23, 39019;
Tax code: SMNSLV67A09A952G and VAT number: IT02962520215

DATA PROTECTION OFFICER (DPO)

The Company's Data Protection Officer can be contacted via email at: info@schroepfprofi.com

You have the right to:

Access your data;
Request the deletion of your data;
Rectify and integrate incorrect or incomplete data;
Restrict data processing under the conditions provided in Art. 18 of the GDPR;
Object to processing in cases where the company has a legitimate interest;
Receive your personal data in a structured, commonly used, and machine-readable format if processing is based on consent or contract and conducted via automated means. You may also request, where technically feasible, to transfer your data to another data controller without obstruction;
Under Art. 22 of the GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects or similarly significantly affects you.

1. PURPOSE OF PROCESSING

1.1 Contractual and Pre-Contractual Purposes

Personal data ("Data") provided by you will be processed to utilize the services offered by the company for contractual, managerial, accounting, and tax purposes.

1.2 Legal Obligations

Data will be processed to comply with regulations and applicable national and international laws, including accounting and tax obligations, as well as those concerning restrictive measures, embargoes, anti-terrorism, and anti-money laundering.

1.3 Company Rights

Data may be processed to establish, exercise, or defend the Company’s rights in legal proceedings.

1.4 Extrajudicial Debt Recovery

If necessary, data will be processed to enable the Company to recover its claims without judicial intervention.

1.5 Direct Marketing

Data may be processed for generic, non-profiled marketing activities, such as:

Sending promotional and commercial communications about services/products offered by the Company via automated (e.g., SMS and email) and traditional means (e.g., phone calls and postal mail);
Invitations to participate in surveys, market research, and customer satisfaction questionnaires, including statistical analyses for marketing purposes.

Consent for processing can be revoked without any negative consequences via email.

2. LEGAL BASIS FOR PROCESSING

2.1 Contractual and Pre-Contractual Purposes: Processing is necessary for the execution of a contract or pre-contractual measures involving you.

2.2 Legal Obligations: Processing is required to comply with legal obligations.

2.3 Company Rights and Debt Recovery: Processing is based on the Company’s legitimate interest.

2.4 Direct Marketing: Processing is based on your explicit consent.

3. DATA RETENTION PERIOD

3.1 Contractual and Legal Obligations: Data will be retained for the duration of the contract and for 10 years after its termination.

3.2 Company Rights and Debt Recovery: In the event of judicial or extrajudicial proceedings, data will be retained for the duration of the dispute and until the expiration of any appeal deadlines.

3.3 Direct Marketing: Data will be retained until consent is revoked for this purpose. After the specified retention periods, data will be destroyed, deleted, or anonymized in accordance with technical deletion and

backup procedures.

4. CATEGORIES OF PERSONAL DATA PROCESSED

Personal details, contact information, administrative and accounting data, and identification data.

5. MANDATORY DATA PROVISION

Providing the data specified in Section 4 for purposes outlined in Sections 1.1, 1.2, and 1.3 is mandatory. Failure to provide this data will prevent the Company from providing its services. Providing data for purposes outlined in Section 1.4 is optional.

6. DATA RECIPIENTS

Data may be processed by external parties operating as independent controllers, such as supervisory authorities, public and private entities authorized to request data.
Data may also be processed on behalf of the Company by external parties designated as processors, following appropriate operational instructions.

These parties primarily include:
a. Companies offering transportation services;
b. Companies and professionals providing banking, administrative, accounting, credit protection, and legal services;
c. Companies and professionals offering insurance services;
d. Companies providing IT system management, maintenance, and development;
e. Companies supporting market research initiatives.

7. AUTHORIZED DATA PROCESSORS

Data may be processed by employees of the Company or designated processors responsible for achieving the purposes stated above. These individuals are authorized to process data and have received appropriate operational instructions.

An updated list of data processors appointed by the Company can be obtained by emailing: info@schroepfprofi.com

8. YOUR RIGHTS AS A DATA SUBJECT – COMPLAINT TO THE SUPERVISORY AUTHORITY

You may exercise the following rights by contacting the Company:
For rights under Sections 1) and 3), contact your local branch. Branch details are available under “Find a Branch” on the Company’s website.
For rights under Sections 2), 4), 5), 6), and 7), email: info@schroepfprofi.com

You also have the right to file a complaint with the supervisory authority in the Member State where you reside, work, or where the alleged violation occurred.

9. PERSONAL DATA STORAGE AND TRANSFER TO NON-EU COUNTRIES

Personal data will be stored and processed within the European Union. A detailed list of EU countries, categorized by application, is available upon request by emailing: info@schroepfprofi.com

If personal data is transferred to non-EU countries to achieve processing purposes, the Company will ensure appropriate safeguards as required by law.