Privacy policy

Information for customers pursuant to art. 13 of European Regulation no. 2016/679 on the protection of personal data The processing of data relating to legal persons does not fall within the scope of the personal data protection regulations established by European Regulation no. 2016/679. For the purposes of clarity and transparency towards its Customers, Bitubo Srl also provides this information to legal persons, describing the methods and purposes of all processing that the Company carries out or has the right to carry out on personal data. Therefore, the information specifically concerns the data of natural persons who work for the Company's Customers.
1. Introduction Pursuant to art. 13 of European Regulation no. 2016/679 (hereinafter, the “Privacy Regulation”) Bitubo Srl, with registered office in Teolo (PD), via A. Volta, 24, VAT number IT02007650282, e-mail privacy@bitubo.com (hereinafter also the “Company”), as Data Controller of the personal data already communicated or that will be communicated in the future and from which the personal data are or will be collected, wishes to inform the Customer that the data concerning him/her may be processed, in compliance with the legislation referred to above, in relation to pre-contractual and/or contractual relationships with the Customer or those that may be entertained in the future.
2. Source of personal data Personal data, acquired or that will be acquired in relation to contractual relationships or in the pre-contractual phase, are collected directly from the Customer. All personal data collected are processed in compliance with current legislation and, in any case, with due confidentiality.
3. Purpose of processing and legal basis of processing The collection or processing of personal data is carried out for the following purposes: (i) to adequately provide for the obligations connected to the performance of the economic activity of the Company and in particular for:
• the execution of pre-contractual activities and the acquisition of preliminary information for the purposes of stipulating the contract;
• management of the contractual relationship and all administrative, operational, management and accounting activities relating to the contract (order management, invoicing, checks on the reliability of suppliers, post-sales assistance and support, etc.);
• management of litigation, breaches of contract, formal notices, transactions, arbitrations, legal disputes, etc.;
• compliance with obligations set forth by laws, regulations, community legislation and provisions issued by public authorities.
With reference to the purposes referred to in the previous paragraph (i), the provision of personal data is mandatory and constitutes a necessary requirement for the establishment, management and execution of the contractual relationship; in fact, failure to provide such data determines the impossibility of receiving the contractually requested service and, therefore, the legal basis of the processing is the fulfillment of pre-contractual and/or contractual and legal obligations connected to the relationship established by the Customer with the Company, pursuant to art. 6, paragraph 1, letter b) and letter c) of the Privacy Regulation;
(ii) updating the Customer on promotional and commercial initiatives, through the sending of advertising and/or promotional material, via email (the “Marketing”).
With reference to the purpose referred to in the previous paragraph (ii), the provision is optional and failure to provide the relevant consent only determines the impossibility of receiving the Marketing. The legal basis of the processing is the consent expressed by the Customer pursuant to art. 6, paragraph 1, letter a).
4. Processing methods The processing of personal data will be carried out lawfully and correctly and in any case in compliance with the above-mentioned legislation, using tools suitable for guaranteeing security and confidentiality and may also be carried out using IT tools to store, manage and transmit the data. The processing will be carried out, primarily, by the internal organization of Bitubo Srl, under the direction and control of the designated corporate functions and for the purposes indicated above.
5. Duration of processing The personal data subject to processing will be stored: a) with reference to art. 3 paragraph (i) for the time strictly necessary with regard to the contractual relationship and therefore for the entire duration of the same. After the termination of the contractual relationship:
- the data necessary for the fulfillment of legal and fiscal obligations will be retained for a further 10 years;
- the data necessary for any legal defense will be retained for the entire duration of the trial, until the sentence becomes final;
- the data necessary for the fulfillment of communications to independent and judicial control authorities, will be retained for a period of 5 years, at the end of which the possible need for further retention will be assessed where this is requested by the aforementioned authorities.
After termination of the relationship, data other than those necessary for the purposes set out in the preceding points will be immediately deleted.
For pre-contractual purposes only, the data will be retained for the duration of the negotiations and in the event of failure to conclude the contract for the following 6 months, except for any legal defense in the event of disputes and/or pre-litigation activities. In this last case, in fact, the necessary data will be retained for the entire duration of the trial, until the sentence becomes final.
b) with reference to art. 3 paragraph (ii) the data necessary for sending Marketing will be processed until the Customer exercises the right to unsubscribe from the service.
6. Recipients of personal data Without prejudice to communications made in compliance with a legal obligation, regulation or community legislation, communication, even through simple consultation or making available of personal data concerning the Customer, may be made to the following parties:
a. public bodies, supervisory bodies, authorities or institutions;
b. natural or legal persons who provide specific services, such as – by way of example and not limited to – data processing, logistics and postal services, customer satisfaction surveys, legal, administrative, tax and/or accounting consultancy, organisation of trade fairs and communication events, etc.;
c. commercial intermediaries, banks and credit institutions, financial intermediation companies, natural or legal persons responsible for debt collection, auditing and/or certification of balance sheets and quality systems, independent collaborators of the Company, agents and reporters, insurers and brokers, freight forwarders, etc.
The subjects referred to in the preceding points operate as independent Data Controllers. We reassure the Customer that, in any case, the subjects cited are transferred exclusively, if not aggregated personal data and in anonymous form, the personal data necessary and pertinent to the purposes of the processing for which they are responsible.
The list of such third parties will be constantly updated and accessible to the Customer upon request to the Company. By virtue of the existence of connections with the same by telematic, computer or correspondence means, personal data may be made available abroad, possibly also outside the countries belonging to the EU in consideration of the existence of the relevant authorization, or on the basis of standard contractual clauses. In any case, personal data will not be disclosed.
7. Rights of the Interested Party The Customer's right to exercise the rights of access to the references indicated in the introduction to the personal data provided for by art. 15 of the Privacy Regulation and the rights provided for by art. 16, 17, 18, 21 of the Privacy Regulation regarding rectification, cancellation, limitation of processing and the right to object, within the limits of art. 2-undecies of the Privacy Code and in the manner established by art. 12 of the Privacy Regulation, remains unchanged. For this purpose, a communication may be sent to the e-mail address privacy@bitubo.com.
8. Right to lodge a complaint pursuant to art. 77 of the GDPR If Bitubo Srl does not provide the Customer with feedback within the timeframes set by the legislation or the response to the exercise of the Customer's rights is not suitable, the Customer may lodge a complaint with the Guarantor for the protection of personal data, at the following coordinates: website www.gpdp.it or www.garanteprivacy.it, e-mail protocollo@gpdp.it, telephone switchboard: (+39) 06.69677.1.
9. Further information Further information regarding the processing and communication of personal data may be requested from the Company. The updated list of Data Processors, where appointed, is available from the Company.