Privacy Policy

PRIVACY POLICY – PERSONAL DATA PROTECTION NOTICE

In accordance with applicable national legislation on personal data protection (Italian Personal Data Protection Code, as amended and updated, most recently by Law No. 160 of 27 December 2019, Decree Law No. 53 of 14 June 2019, Ministerial Decree of 15 March 2019 and Legislative Decree No. 101 of 10 August 2018) and European legislation (General Data Protection Regulation – GDPR 2016/679), we inform you that any personal data you have already provided, as well as any personal data you may provide in the future as a “data subject”, will be processed in full compliance with the above-mentioned regulations and with the confidentiality obligations to which Torino Transfer Srl is subject.

Data Controller and Data Protection Officer

The Data Controller and Data Protection Officer is:

Torino Transfer Srl
VAT Number: 13175770018
Email: info@torinotransfer.it
Phone: +39 349 1610251

Purpose of data processing
The personal data you provide may be processed for the following purposes:

  1. Providing information about the services offered by the Data Controller
  2. Sending commercial offers related to the services provided
  3. Managing contractual or pre-contractual administrative data

Personal data are collected and processed electronically and/or manually in order to:

  1. Enable and manage the services requested by the client;
  2. Create and maintain a private customer database;
  3. Create and maintain a public portfolio of completed projects (which may include images of completed work, the client’s company name and website address);
  4. Carry out profiling activities in order to send personalized communications or propose services consistent with the user’s preferences.

Failure to provide the requested data may make it impossible to fulfill the requested services.

Data are processed directly by the service provider or by authorized personnel solely for the purpose of delivering the agreed services.

Personal data may be shared with third parties when necessary for the execution of contractual obligations but will never be sold or exchanged.

Legal basis for processing
Torino Transfer Srl processes personal data lawfully where processing:

  • is necessary for the performance of a contract or pre-contractual measures requested by the user;
  • is necessary to comply with legal obligations applicable to the Data Controller;
  • is based on the user’s explicit consent for newsletter communications, personalized communications or marketing activities based on user preferences.

Processing methods and data retention
Data processing is carried out using automated and/or manual systems in compliance with Article 32 of GDPR 2016/679 regarding security measures. Processing is performed by specifically authorized personnel in accordance with Article 29 of GDPR 2016/679.

No fully automated decision-making process, including profiling as defined in Article 22 paragraphs 1 and 4 of EU Regulation 2016/679, is implemented.

In accordance with the principles of lawfulness, purpose limitation and data minimization set out in Article 5 of GDPR 2016/679, and subject to your explicit consent where required, personal data will be retained only for the period necessary to achieve the purposes for which they were collected and processed, and in any case not longer than the limits established by applicable tax, labor and civil legislation, and for a maximum additional period of ten years.

Scope of data communication
The collected data will never be publicly disclosed and will not be shared without your explicit consent, except where communication is required to fulfill legal obligations or contractual commitments.

Personal data may be shared with third-party service providers including, but not limited to:

  • Facebook and Instagram (Meta Platforms, Inc.)
  • WhatsApp Web and WhatsApp Business (WhatsApp LLC)
  • Telegram (Telegram LLC)
  • Google Inc. (including Google Analytics, Google Drive, Google Maps, YouTube, Google Ads, Google My Business, Google Calendar, Gmail, Google Chrome, Google Search and related services)
  • LinkedIn (LinkedIn Corporation)
  • 123FormBuilder (123 Formbuilder S.r.l.)
  • NCC Gest
  • Tieni il Conto (Zucchetti)
  • Aruba Business s.r.l.
  • Hosting per te (Armada di Mascio Fabio)

Where applicable, such third parties process personal data in compliance with applicable data protection laws. Images (photos or video recordings) may also appear in services such as Google Image Search or other search engines.

Failure or incorrect provision of data
Failure to provide mandatory information may prevent the Data Controller from ensuring proper processing in accordance with contractual obligations. Where personal data are required for the execution of a contract or for compliance with legal obligations (such as accounting and tax requirements), failure to provide such data may prevent the establishment of the contractual relationship.

International data transfers
Personal data are generally processed within the European Union.

However, Torino Transfer Srl may transfer personal data to third parties located outside the European Union or the European Economic Area where necessary for service delivery.

In such cases, these parties will be appointed as Data Processors in accordance with Article 28 of GDPR and transfers will be regulated in compliance with Chapter V of GDPR. Appropriate safeguards will be adopted including adequacy decisions issued by the European Commission, standard contractual clauses or binding corporate rules. For further information about such safeguards you may contact info@torinotransfer.it.

Special categories of personal data
Under Articles 9 and 10 of EU Regulation 2016/679 you may voluntarily provide data belonging to special categories of personal data, such as data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health data or data concerning a person’s sexual life or sexual orientation. Such data will only be processed with your explicit written consent.

Automated decision-making
The Data Controller does not carry out automated decision-making processes, including profiling, as defined under Article 22 of GDPR.

Links and social media plugins
This website may use social media plugins allowing interaction with social platforms such as Facebook, Google, Twitter, LinkedIn, Instagram or WhatsApp.

When interacting with these plugins (for example clicking the “Like” button), the information is transmitted directly to the respective social network platform and stored by it.

For further information regarding how these platforms process personal data, please consult the respective privacy policies of each social network.

Cookie Policy
This website uses technical cookies to ensure the proper functioning of its services and to improve the browsing experience. Technical cookies do not require user consent.

Profiling cookies may require your consent, which can be modified or withdrawn at any time. For complete information regarding the use of cookies and how to manage them, please click here.

Rights of the data subject (Articles 15–22 GDPR)
As a data subject you have the right to access, rectify, erase or restrict the processing of your personal data, as well as the right to data portability and the right to object to processing.

You may exercise these rights by submitting a written request to the Data Controller at the registered office or by email at info@torinotransfer.it.

Right to lodge a complaint
You also have the right to lodge a complaint with a supervisory authority, in particular the Italian Data Protection Authority (www.garanteprivacy.it).

Changes to this Privacy Policy
Changes in applicable legislation or updates to our services may require modifications to this Privacy Policy. We therefore encourage users to review this page periodically. Any relevant updates will be published on this page and, where appropriate, notified to users more visibly.

The undersigned confirms that they have been informed:
– of the identity of the Data Controller
– of the identity of the Data Protection Officer
– of the processing methods used
– of the purposes for which the personal data are processed

◻ I GIVE CONSENT     ◻ I DO NOT GIVE CONSENT

pursuant to Article 7 of Regulation (EU) 2016/679 to the processing of personal data according to the methods and limits described in the above notice, including where applicable those considered special categories of personal data.