Personal data processing and protection information statement (Art. 13 GDPR)
WEGUM provides information on how he processes and protects personal data he may acquire from and process through the website.
Art. 1. Data Controller: collects data and decides processing purposes/ methods
WEGUM SRL
Address: Via Ascanio Sforza 3 20136 Milano
VAT number: 10233780963
Tax Identification number: 10233780963
Telephone: 0284211175
Email: info@wegum.it
Certified email: wegum@legalmail.it
Art. 2. Purposes and legal basis for processing: why data are processed and what justifies processing
Data are processed for the following purposes.
Purpose a) – Contacts
- fulfilment of precontractual obligations (respond to requests submitted through the contact form on the website in the “contact us” section” or WhatsApp);
Legal basis: execution of the contract.
Refusal to provide compulsory data (indicated with a *) prevents the controller from responding to requests.
Purpose b) – Anonymous statistics
- Anonymous statistical data are collected to monitor the proper functioning of the website and user navigation. Such data are processed in aggregated form and cannot be used to identify individual users.
Legal basis: legitimate interest
Art. 3. Processed data and processing methods
The following data are processed in order to fulfil the purposes of Art. 2:
Purpose a) – Online contacts
- The data requested are those provided in the contact form: email, telephone number and message
Purpose b) – Statistics
- Anonymous statistical data are collected on visited website pages. We do not collect the user’s IP address and therefore we are unable to identify which pages you are visiting.
All disclosed data are processed within the limits strictly necessary for the achievement of purposes set forth in Art. 2 here above, in hard copy or by computerised means.
Art. 4. Data conservation
Data are processed and stored at the Data Controller’s office and in company devices (e.g. computer, server, smartphone, etc.).
Data processing (hard copy or digital) is executed with appropriate measures for ensuring the security and confidentiality of personal data and specifically in compliance with adequate security measures and in accordance with the principles of propriety, necessity and proportionality.
Some of the software used by the Data Controller is managed by cloud systems (e.g. email inboxes). Providers have been selected to ensure the safeguarding and confidentiality of data.
Some data may also be present in backup systems. If this is the case, removal will not be possible. As of now we guarantee that in the event of a total system reboot, such data will be anonymised once more/ deleted.
Collected and processed data are stored for the following periods
Purpose a): 5 years from contract request.
Purpose b): 14 months.
Art. 5. Communication and transmission of data
In the execution of normal contractual duties, employees and/or non-employed professionals working for the Data Controller have access to data in their capacity as authorised processing persons.
Art. 6. Data transmission beyond the EU
WEGUM does not directly transfer data outside the EU. However, the use of technological tools (such as email and messaging services) implies that data transmitted through these channels may pass through the servers of the respective service providers. These servers are located in various parts of the world, including outside the European Union.
The Data Controller agrees to send/receive documents and/or communicate with the data subject also via WhatsApp.
The optional use of WhatsApp implies that such conversations may also be stored on the service provider’s servers. This provider has servers located outside the European Union; therefore, any communications may also be stored on those servers, in accordance with the provider’s contractual terms and privacy policy.
Statistics
Anonymous statistical data are stored on the servers of a service provider located outside the EU (Google).
Art. 7. Rights of the data subject
Art. 7 no. 3 The data subject has the right to withdraw their consent at any time; Art. 15 Right to access, including the right to obtain information on the personal data conservation period. Right to obtain indication on the origin of collected data as well as on the processing purposes and methods. Right to lodge a complaint with the Personal Data Protection Authority; Art. 16 Data Subject’s right to obtain the updating, rectification, integration of personal data; Art. 17 Right to cancellation /the right to be forgotten (when provided for); Art. 18 Right to the limitation of processing (when provided for); Art. 20 Right to data portability (when enabled by current technology); Art. 21 Right to object to processing; Art. 22 Right to not be subjected to a decision solely based on automated processing, including profiling.
Art. 19 requires the Data Controller to notify of rectification, erasure and/or limitation of processing requested by data subjects.
Art. 8. Requests from data subjects: how rights can be exercised
Requests pertaining to the exercise of rights set forth in Art. 7 here above can be submitted by data subjects to the Data Controller by registered letter or email, to the addresses provided in Art. 1 here above.
In all submitted requests, data subjects must enclose a valid identification document.
Art. 9. Updating of this information statement
This Information Statement may be modified and integrated, including as a consequence of legislative modifications/ integrations. Data subjects will be informed of any modifications.
You are reminded that the data subject can obtain the latest updated text of the information statement by sending a request to:
info@wegum.it
