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INFORMATION FOR THE PROCESSING OF PERSONAL DATA

Pursuant to article 13 of the Regulation (EU) 2016/679 general on data protection ("Regulations"), Robo'n Roll Srl referred below the Company, provides the following information with reference to the personal data provided by the contractual counterparty whoundertakes to transfer this information to the persons concerned, as well as to the personal data collected for the marketing purposes indicated in this Notice.

1. Data Controller

Robo’n Roll Srl, VAT No. 03699230367 with registered office in Stradello della Noce n.41 cap.41123 Modena - Italy.

2. Categories of Data Processed

2.1 Data processed during the contractual relationship

Object of processing is the personal data provided by the contractual counterpart from now on called INTERESTED PERSON, at the time of collecting the information, from now on called PERSONAL DATA or simply DATA, from www.robonroll.com such as, for example:

  • personal data
  • place of birth
  • place of residence
  • fiscal Code
  • VAT number
  • telephone number
  • email address
  • Bank account details

and their following changes, as well as the additional data that will be provided by the INTERESTED PARTY or acquired by the Company during the contractual relationship ("PERSONAL DATA" or "DATA").
All such information is to be considered Personal Data in accordance with the applicable regulations to the extent that they relate directly or indirectly to identified or identifiable natural persons (for example, directors, employees, managers, collaborators, consultants of the contractual counterparty).
For example, the VAT number of a legal entity does not fall within the definition of Personal Data.

2.2 Data processed in the course of marketing activities.

Object of processing is personal data ("Personal Data" or "Data") provided by the user ("INTERESTED PERSON") or collected by the Company during its navigation on the Website.

  • Data provided by the INTERESTED SUBJECT: this is mainly the Data collected during the interactions with the Company through the forms or forms on the Website or by subscribing to the Newsletter. This data includes the name, surname, e-mail address and telephone number;
  • Other data processed: this is mainly the Data collected during the navigation of the INTERESTED SUBJECT on the Site, such as the IP address, the operating system of the browser used, the clicked content and the web pages visited.

3. Purpose of the Processing, legal basis and consequences of failure to provide the Data

3.1 Data treated during the contractual relationship :

Personal Data are processed by the Company for the following purposes:

  • fulfill the legal and administrative obligations to which the Company is subject. Any refusal to provide Personal Data for the pursuit of the aforementioned purposes will result in the inability to establish and continue the contractual relationship with the Company;
  • stipulate and manage the contractual relationship with the Company. For this purpose, the Personal Data will also be processed in the context of the activities of: administration, accounting, contract management, services, billing / payments, auditing and certification of mandatory / voluntary financial statements, assignment or advance credits, as well as to fulfill specific requests and comply with the other obligations arising from the Contract with the Company. The provision of Personal Data is necessary for the establishment and execution of the Contract. Any refusal to provide Personal Data for the pursuit of the aforementioned purposes will result in the inability to establish and continue the contractual relationship.

3.2 Data processed in the course of marketing activities

The Data are processed by the Company for the following purposes:

  • allow interested parties to be updated on the Company's products, through the direct marketing of goods and services, the receipt of the newsletter,the distribution of information material, the organization and promotion of events and the sending of questionnaires related to the degree of customer satisfaction;
  • send personalized information based on the specific profile and interests of the INTERESTED SUBJECT;

The processing of data for the purposes referred to in points a), b) and c) is optional, and is subject to the provision of consent by theINTERESTED SUBJECT. Any refusal to provide such Data will make it impossible to communicate to the INTERESTED PARTY any commercial initiative and offer of Robo'n Roll Srl, as well as to receive commercial information deemed relevant for its profile.

The processing of Personal Data could also take place as part of the management of any dispute. Any such processing could be carried out on the basis of a legitimate interest of the Company, which intends to protect its interests and rights as recognized by the regulations in force.

4. Processing methods and data retention period

4.1 Data processed during the contractual relationship

Personal Data are processed mainly at the Company with the aid of electronic and manual means suitable for guaranteeing security and confidentiality. In particular, they can be treated in the following ways:

  • collection of data from the data subject;
  • collection of data from registers, public records or documents;
  • recording and processing on paper;
  • registration and processing on computer support;
  • organization of archives in both automated and non-automated form

Personal Data will be stored in accordance with the provisions of current legislation on the subject, for a period of time not exceeding that necessary to achieve the purposes for which they are processed.
The criteria for determining the retention period of the Data take into account the permitted processing period and the applicable laws on taxation, the prescription of rights and the nature of legitimate interests where they form the legal basis of the processing.
In accordance with the provisions of current legislation, Personal Data may be stored for a period subsequent to the one originally envisaged, in the event of any disputes or requests by the competent Authorities.

4.2 Data processed in the course of marketing activities

Communications for the purposes indicated in paragraph 3.2 may be made by e-mail, sms, whatsapp, Telegram paper mail as well as any other means of communication present and future, provided that the person concerned can object to the processing carried out by one or all of these media.
The Data are mainly processed at the Company with the aid of electronic and manual means suitable for guaranteeing security and confidentiality.
In particular, they can be treated in the following ways:

  • collection of data from the data subject;
  • recording and processing on paper;
  • registration and processing on computer support;
  • organization of archives in both automated and non-automated form.

Data will be kept in compliance with the provisions of current legislation on the subject, for a period of time not exceeding that necessary to achieve the purposes for which they are processed. In the absence of specific rules that provide retention times for the purposes indicated in this Notice, the Company will take care to use the Personal Data for the aforementioned marketing purposes for a time congruous with respect to the interest shown by the INTERESTED PARTY towards the promotional initiatives, evaluated over 5 years. In any case, the Company will take all measures to avoid the use of the same data indefinitely, proceeding periodically to verify in an appropriate manner the effective permanence of the interest of the INTERESTED SUBJECT to carry out the processing for marketing purposes, as above clarified.

5. Scope of communication and transfer of data

Personal Data will be made available to subjects authorized for their processing within the Company only where necessary and for the purposes for which treatment is permitted.

5.1 Data processed during the contractual relationship

Personal Data may be communicated by the Company, solely and exclusively for the purposes indicated, as well as to the competent Judicial

Authorities where necessary, to the following categories of subjects:
- banking and credit institutions;
- insurance companies;
- legal advisors;
- tax advisors, auditors and accountants;
- credit recovery companies;
- companies that detect financial risks and that perform fraud prevention activities;
- public administrations and supervisory and control authorities;
- car rental company;
- travel agencies;
- companies that provide IT services;
- companies that provide security and surveillance services;
- companies that control and / or are associated with the Company.

reference to the Personal Data communicated to them, the subjects belonging to the above categories may operate, as appropriate, as data controllers (and in this case receive appropriate instructions from the Company) or as separate data controllers. In the latter case, the Personal Data will be communicated only with the express consent of the interested parties, except in cases where the communication is mandatory or necessary by law or for the pursuit of purposes for which the consent of the law is not required by the law interested.

If this is instrumental to the pursuit of the purposes indicated in paragraph 3.1, the Data may also be transferred abroad to companies located both within and outside the European Union. Some of these jurisdictions may not guarantee the same level of protection as the Data secured by the country in which the individual resides. In this case, the Company agrees that the Data will be treated with the utmost confidentiality, stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided by the European Commission.

5.2 Data processed in the course of marketing activities

Data may be communicated by the Company, solely and exclusively for the purposes indicated, as well as to the competent Judicial Authorities where necessary, to the following categories of subjects:

  • companies that provide IT services;
  • consultants of the Company;
  • marketing service providers;
  • companies that control and / or are associated with the Company.

If this is instrumental to the pursuit of the purposes indicated in paragraph 3.2, the Data may also be transferred abroad to companies located both within and outside the European Union. Some of these jurisdictions may not guarantee the same level of protection as the Data secured by the country in which the individual resides. In this case, the Company agrees that the Data will be treated with the utmost confidentiality, stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided by the European Commission.

6. Existence of an automated decision-making process

There is no automated decision-making process in relation to the data.

7. Rights of the interested party

At any time, the interested party will have the right to:

  • obtain from the Company confirms that it is or is not undergoing the processing of its Personal Data and, in this case, obtaining access to the information pursuant to art. 15 of the Regulations;
  • obtain the correction of inaccurate data concerning it, or, taking into account the purpose of the processing, the integration of incomplete Personal Data;
  • obtain the cancellation of your Personal Data, in the presence of one of the reasons set forth in art. 17 of the Regulations, where applicable;
  • revoke consent at any time in cases where it was previously provided. The withdrawal of consent does not affect the lawfulness of the treatment based on the consent previously given;
  • obtain the limitation of the processing of your Data if one of the hypotheses referred to in art. 18 of the Regulations;
  • oppose the processing of your Personal Data, for reasons related to your particular position, where applicable;
  • receive the Personal Data supplied to you in a structured, commonly used and automatically readable form, as well as transmit such Data to another data controller, in the cases and within the limits set forth in art. 20 of the Rules.

The Company may request additional information before processing requests if it needs to verify the identity of the individual submitting them.
Pursuant to the GDPR, the Company is not authorized to charge costs for fulfilling one of the requests listed in this paragraph, unless they are manifestly unfounded or excessive, and in particular they are repetitive. In cases where an INTERESTED SUBJECT requires more than one copy of his personal data or in cases of excessive or unreasonable requests, the Company may (i) charge a reasonable fee, taking into account the administrative costs incurred to process the request or (ii) ) refuse to meet the request. In these cases the Company will inform the interested parts of costs before processing the request.

These rights may be exercised by sending:
- a communication by e-mail to the address info@robonroll.com

Without prejudice to any other administrative or judicial appeal, the person concerned also has the right to lodge a complaint with a Supervisory Authority (for Italy: the Guarantor for the protection of Personal Data), if he considers that the treatment that concerns him is carried out in violation of the General Data Protection Regulation. Further information is available on the website http://www.garanteprivacy.it.

The Company undertakes to comply with all the obligations set out in this statement. Interested parties who may decide to propose the appeals or complaints referred to above, are invited to contact us.

Robo'n Roll s.r.l.

Aggiornato Ago/2018