Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal dataBiolo Trattori di Luppi Alberto & C. s.a.s (hereinafter also “Owner” or the “Licensor”), with registered office in Via Verona, 50 – 37063 Isola della Scala VR and VAT P. IVA 04263500235, as data controller informs you, pursuant to Articles 13 and 14 of European Regulation 679/2016 on the protection of personal data (“GDPR”) of the following.

1 TYPE OF DATA PROCESSED
The Licensor is the controller of the personal data disclosed at the time of signing the Contract and subsequently provided during the execution of the Contract.
The personal data that the Licensor collects in connection with the management of the contractual relationship and in any pre-contractual stages may be provided directly by the Interested Party (as defined below) or by the Client, if they are internal contacts of the Client assigned to the management of the Contract.
Personal data processed by the Licensor may include, but are not limited to, the names, titles, telephone numbers, tax code, payment and banking data, and possibly the business name and e-mail addresses of individuals and legal representatives of companies as contracting parties to the Contract as well as internal contact persons for contract management (hereinafter, the “Interested Parties” and the “Data”).
Some information, relating for example to data on representatives and attorneys or financial statements or customer reliance, is also acquired from public sources (e.g. Chambers of Commerce, or business information services).

2 PURPOSE OF DATA PROCESSING
Data is processed by Licensor in the course of its economic and commercial activities for purposes related to the establishment, management and execution of business relationships, including pre-contractual relationship management. Specifically, the Data provided by the data subjects will be processed, mainly by computer tools, for the following purposes:
a) the performance of obligations strictly related to the management of the Contract, including administrative and accounting management of contracts, management of payments and invoices, issuance of services and management of customer support services. The provision of data for such activities is essential for the proper management of the Contract and does not require the consent of the Data Subject (Art. 6(1)(b) of the GDPR);
b) the performance of activities instrumental to the management of the Contract, including the scheduling of activities, protection management of any litigation and debt collection for which the provision of data, where necessary, is optional and whose processing is based on the legitimate interest of the Licensor;
c) the fulfillment of obligations arising from the law, regulations or EU legislation (e.g., tax and accounting obligations) for which the provision of data is mandatory and the processing does not require the consent of the Data Subject (Art. 6(1)(c) of the GDPR);

3 METHODS OF PROCESSING
The Data will be processed by the Company using electronic and manual systems in accordance with the principles of fairness, loyalty and transparency provided for in the applicable legislation on the protection of personal data and protecting the confidentiality of the Data Subject through technical and organizational security measures to ensure an adequate level of security.

4 DATA STORAGE
The Data necessary for the administration of the Contract and the fulfillment of the obligations set forth in the letter. (a) and (b) of Section 2 of this policy will be retained by the Owner in its files for 10 years after the registration of transactions in compliance with civil and tax obligations imposed by current regulations. Similarly, the Data referred to in par. (c) of Section 2 required for protection in case of dispute or litigation will be retained for 10 years after termination of the Contract.

5 COMMUNICATION, DIFFUSION AND TRANSFER OF DATA
The Data will be processed, to the extent necessary, by authorized, adequately instructed and trained personnel of the Data Controller, as well as by personnel of third parties who provide services to the Data Controller and perform Data processing on behalf of and at the instruction of the Data Controller as data processors.
These are those who provide IT services (e.g., hosting providers), call center services, debt collection activities, customer support services (e.g., ticketing management), support services for marketing activities (e.g., direct email marketing) and third party companies, including companies of Biolo Trattori di Luppi Alberto & C. s.a.s, that provide complementary activities. The complete and updated list of the entities that process Data as data processors is available upon request to the Data Protection Officer.
In cases where the contractual relationship involves our business partners, the Data Controller may share some Data with distributors, resellers and partners that are part of the distribution chain of Biolo Trattori di Luppi Alberto & C. s.a.s. products and services.
In the performance of its ordinary business activities, the Data may be disclosed to parties that carry out control, audit and certification activities of the activities carried out by the Data Controller, consultants and freelance professionals in the context of tax and judicial assistance services and in the case of corporate transactions for which it is necessary to evaluate the company’s assets, to other companies of Biolo Trattori di Luppi Alberto & C. s.a.s where this is necessary for the purposes of coordination and group control, entities and public administrations, including tax authorities where this is necessary, as well as to parties entitled by law to receive such information, Italian and foreign judicial authorities and other public authorities, for purposes related to the fulfillment of legal obligations, or for the fulfillment of obligations assumed and arising from the contractual relationship, including for the need to defend in court. Contact data may be disclosed for quite occasional needs to clients and/or suppliers of the Data Controller, for example, if they have to cooperate with such parties for the purpose of providing services.
The Data will under no circumstances be disseminated or generally transferred outside the European Union. However, for specific needs related to the location of the third party with whom the Data may be shared, as described above, some Data may be transferred outside the European Economic Area to countries that offer adequate protection. In cases where the third country does not offer adequate protection, the Data Controller undertakes to ensure adequate levels of protection and safeguards, including contractual ones, including the stipulation of standard contractual clauses (copies of the commitments made by third parties in the context of such clauses may be requested by means of a request to be sent to the Data Protection Officer).

6 MARKETING AND PROFILING
Subject to the consent of the Data Subject, the Data may also be processed by the Data Controller for the following purposes:
a) the sending via e-mail and with automatic messages or by telephone, of offers and commercial initiatives relating to products or services of the companies of Biolo Trattori di Luppi Alberto & C. s.a.s as well as the conduct of market research or other customer satisfaction initiatives promoted by the Data Controller. Should the provision of any data for this purpose be required, which is an entirely residual assumption, such provision will be optional. It is understood that data processing for this purpose will be possible only with the consent of the Data Subject (Art. 6(1)(a) of the GDPR). Consent may be revoked at any time, freely in the ways indicated in Section 7 below or through the unsubscribe link available in each electronic communication. Any failure to grant or withdrawal of consent shall in no way affect the performance of the Contract;
b) the analysis of the habits of use of the products and services of Biolo Trattori di Luppi Alberto & C. s.a.s by the Interested Party according to what may be considered of his/her interest both in order to improve its products and services with features that may be of greater interest to customers and to offer the Interested Party products that may respond more punctually to his/her needs. Should the provision of any data for this purpose be required, which is an entirely residual hypothesis, such provision will be optional. It is understood that the processing of data for this purpose will only be possible with the consent of the Data Subject (Art. 6(1)(a) of the GDPR). Any use of information relating to the use of products or services traceable to the legal person Customer may be carried out by the Data Controller even in the absence of specific consent, unless otherwise provided by law. Consent may be revoked at any time freely in the ways indicated in point 7 below; any failure to grant or revocation of consent shall in no way affect the performance of the Contract.
Subject to the consent of the Data Subject, in order to receive promotions and commercial initiatives, the Licensor may also disclose the Data to Biolo Trattori di Luppi Alberto & C. s.a.s companies involved in software development and training partners and suppliers of Biolo Trattori di Luppi Alberto & C. s.a.s for them to send promotions and commercial initiatives.
Without prejudice to the assumptions of the exercise of the rights of cancellation of the Data and the rights of opposition and limitation of the processing referred to in point 7 of this notice, the Data processed for the purposes referred to in this point will be stored and processed in compliance with the applicable legislation for the protection of personal data for as long as necessary to fulfill the purposes indicated above to the maximum extent of 24 months or the longer maximum period permitted by law for profiling referred to in (a) of this item; otherwise, for the purposes set forth in par. (b) of this point, the processing will be carried out until the consent is revoked by the Data Subject.

7 WHAT ARE THE RIGHTS OF THE DATA SUBJECT
The Data Subject may exercise, in connection with the data processing described herein, the rights provided by the GDPR (Articles 15-21), including:
– Receive confirmation of the existence of the Data and access to its content (access rights);
– Update, modify and/or correct the Data (right of rectification);
– to request the deletion or restriction of the processing of Data processed in violation of the law including Data whose retention is not necessary in relation to the purposes for which the Data were collected or otherwise processed (right to be forgotten and right to limitation);
– Object to the processing (right to object);
– revoke consent, where given, without prejudice to the lawfulness of the processing based on the consent given before revocation;
– Propose a complaint to the Supervisory Authority (Data Protection Authority www.garanteprivacy.it) in case of violation of personal data protection regulations;
– receive an electronic copy of the Data concerning him or her as a Data Subject, when such Data has been rendered in the context of the contract, and request that such Data be transmitted to another data controller (right to data portability).
To exercise these rights, the Data Subject may contact the Data Protection Officer by sending his/her request to biolotrattori@gmail.com or by addressing the communication by mail to:
Biolo Trattori di Luppi Alberto & C. s.a.s
Via Verona, 50 – 37063 Isola della Scala VR