INFORMATION PURSUANT TO THE REGULATION (E) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

Due Torri S.p.A. (“Due Torri”) operates in the business of the integrated logistics and it’s highly specialized, in particular in the management of all warehouse activities and processes, in the control of distribution flows and in the design of custom and customized logistics services (“the Activities”), for the execution of which it could process personal data, either manually or through computer systems.

What personal data does Due Torri use?

The personal data that Due Torri usually uses includes, for example, all those data that are essential to the Activities, such as, always as an example, the correspondence between Due Torri and its customers.

Why does Due Torri process personal data? And for how long?

Personal data processing is based on purposes that include, for example, the performance of a contract, Compliance fulfilments, etc. The processing is carried out on the basis of the data subject’s personal data.

The same reasons are used to determine the period of treatment.

Due Torri, in any case, will store personal data for a period not exceeding the duration of the Activities concerned, having the right to retain them for a longer period only if the Activities require it, and always against a new specific information sent to the interested parties.

To whom are the personal data processed by Due Torri transferred?

Due Torri, in the execution of the Activities, shares personal data, for example with authorities and organizations, according to regulatory provisions, with professionals in charge of the execution of Activities within their competence, etc.

Where, in particular, the processing of personal data is necessary for the protection of the legitimate interests of Due Torri, Due Torri undertakes to ensure that the processing is carried out in such a way that its legitimate interests are given priority over the interests of the individual.

Due Torri, in any case, has the right to use personal data for reasons other than those explained above but only against a new information specifically addressed to the interested parties.

What are the rights of data subjects to have their personal data processed by Due Torri?

Data subjects have the right to obtain from Due Torri confirmation as to whether or not personal data concerning them exist, even if they have not yet been recorded, and communication of such data in an understandable form. Interested parties also have the right to obtain the indication from Due Torri:

(a) the origin of the personal data

  1. b) the purposes and their methods of processing
  2. c) the logic applied in case of treatment with the aid of electronic instruments
  3. d) the identification data of the owner, the managers and the treatment
  4. e) the subjects and categories of subjects to whom the personal data may be communicated or who may come to know as appointed representative in the territory of the State, managers or agents

In the event that the interested parties prove the incorrectness of the personal data kept by Due Torri, they have the possibility to request the updating of such data or their correction, in particular:

  1. a) the updating, rectification or, where interested therein, integration of data
  2. b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary for the purposes for which the data were collected
  3. c) certification to the effect that the operations as per letters a) and b) above have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement has been proved impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

The interested parties have the right to object, in whole or in part:

  1. a) for legitimate reasons, to the processing of personal data concerning them, even though they are relevant to the purpose of collection
  2. b) to the processing of personal data concerning them for the purpose of sending direct sales advertising material or for carrying out market surveys or commercial communications.

Data subjects have the right to lodge a complaint with the Privacy Authority.

What level of data security is there for data in Two Towers systems?

Interested parties are required to keep their login details on the website/portal secure, in particular the password provided by Due Torri or personally chosen by them. The login credentials are for personal use only and cannot be shared with others.

How to Contact Due Torri?

In case of any questions or concerns about this policy, or if more information are needed about how the protection of the personal information works and/or the interested party would like to contact Due Torri, the email to be contacted is privacy@duetorrispa.com.

How does Due Torri handle the changes made to this policy?

The terms in this Policy may be changed from time to time. If this is the case, Due Torri will publish any significant change to this information by means of a specific communication on its website or by contacting the interested parties directly through other available communication channels.