Information about data processing

OPTICOM GRAPHITE SRL based in Via dell’Artigianato, 8 36060 Romano d’Ezzelino (VI), as Data Controller of personal data pursuant to art. 24 of EU 2016/679 Regulation informs you that, pursuant to art. 13 of the Regulations, will process1 the personal data referred to the staff of your organization manually and / or with the support of computerized means for the purposes indicated below.

Purpose of the processing
The personal data you provide will be processed for purposes related to the execution of the underlying supply contract, including any pre-contractual phase and, specifically, entertaining communications of various kinds and with different means of communication (telephone, mobile phone, text message, email, fax, paper mail); make requests or fulfil requests received; exchange information aimed at the execution of the contractual relationship, including pre and post contractual activities.
Your data may be processed for internal statistical purposes and market research. Failure to provide personal data will make it impossible for us to process contracts and other related obligations, as well as to properly manage mutual business relations.

Legal basis
Your personal data will be processed for the execution of a contract concluded with you or for the execution of pre-contractual measures taken at your request.

Data recipients
Furthermore, your data may be transferred to third parties, for technical and operational requirements strictly related to the purposes set out above and in particular to the following categories of subjects:
a) bodies, professionals, companies or other structures appointed by us in charge of processing related to the fulfilment of administrative, accounting and management obligations related to the ordinary conduct of our economic activity, also for purposes of credit recovery;
b) public authorities and administrations for the purposes connected to the fulfilment of legal obligations or to the persons entitled to access it by virtue of provisions of law, regulations, community regulations;
c) banks, financial institutions or other subjects to whom the transfer of the aforesaid data is necessary for the performance of our company activity in relation to the performance of the contractual obligations assumed with you.
d) suppliers of installation, assistance and maintenance services for IT and telematic systems and systems and all the services that are functionally connected and necessary for the performance of the services covered by the Contract.

Data storage period
Your personal data will be kept for the time strictly necessary to carry out the purposes described above and to fulfil the obligations established by law.

Data transfer
Normally, the Data Controller does not transfer personal data to third countries or to international organizations. For administrative reasons and related to the same (e.g. insurance policies) by the undersigned, some data referring to your person / organization could be transferred within the territory of a Member State of the European Union, of a state belonging to the European Economic Area or to a territory that the European Commission has identified as being able to guarantee an adequate level of personal data protection under the GDPR, or even to non-EU countries.
In the latter case, the undersigned guarantees that the transfer of data takes place on the basis of an adequacy decision of the European Commission pursuant to art. 45 of the GDPR, or that the transfer of data will be subject to adequate guarantees pursuant to art. 46 of the GDPR, ensuring that those who receive the data are contractually bound at least to the same obligations of the Data Controller.
The undersigned also reserves the right to use services in the cloud; in which case, the service providers will be selected among those who provide adequate guarantees, as required by art. 46 GDPR 679/16.

Rights of the subject
Pursuant to articles 13, paragraph 2, and from 15 to 21 of the Regulations, we inform you that in relation to the processing of your personal data you can exercise the following rights:
a) Right of access to personal data and to following information:
– confirmation that the processing of personal data is currently underway;
– Processing purposes;
– Categories of personal data;
– the recipients or categories of recipients to whom the personal data have been or will be communicated;
– if the data are not collected from the data subject, all the information available on their origin;
– the existence of an automated decision-making process, including profiling;
– a copy of personal data subject of the processing.
b) Right to rectification and integration of personal data;
c) Right to erasure of data («right to be forgotten») if:
1. personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;
2. the subject revokes the consent to the processing of data and there is no other legal basis for the processing;
3. the subject opposes the processing and there is no legitimate overriding reason to proceed with the processing;
4. personal data have been processed unlawfully;
5. personal data must be deleted to fulfil a legal obligation under Union law or the law of the Member State to which the data controller is subject.
The data controller, if he has made public personal data and is obliged to delete it, must inform the other controllers who process the personal data of the request to delete any link, copy or reproduction of your data.
d) Right to limit the processing in case:
1. the subject contests the accuracy of personal data, for the period necessary for the data controller to verify the accuracy of such personal data;
2. the processing is illegal and the subject opposes the erasure of personal data and requests instead that its use is limited;
3. although the data controller no longer needs it for processing purposes, personal data are necessary for the data subject to ascertain, exercise or defend a right in court;
4. the subject opposed the processing, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the subject.
e) Right to lodge a complaint to the Guarantor for the protection of personal data, following the procedures and indications published on the official website of the Authority
f) Right to portability of subject data, that is the right to receive, in a structured, commonly used and automatically readable form, personal data concerning you provided to a data controller and transmit them to another data controller, if the processing is based on consent or a contract and is carried out by automated means. When technically possible, the data subject has the right to obtain direct data transmission from one data controller to another.
g) Right to opposition at any time to the processing of personal data, including profiling, in particular when:
1. processing is carried out on the basis of the legitimate interests of the controller, after having clarified the reasons for the opposition
2. personal data are processed for direct marketing purposes.
h) Right not to be subjected to a decision based solely on automated processing, including profiling, except in cases where the decision is necessary for the conclusion or execution of a contract between the data subject and a data controller, is authorized by the law of the Union or of the Member State to which the controller is subject or based on the explicit consent of the data subject.
i) Right to withdraw consent at any time; the data, if not based on another legal basis (including, fulfilment of a legal obligation or execution of a contract) must be deleted by the controller.
The exercise of the rights is not subject to any form constraint and is free, except in cases of groundlessness or excessive requests for which a fee may be charged not higher than the costs actually incurred for the research carried out.

How to exercise rights:
The subject may at any time exercise the rights by sending a request by fax or e-mail to the following addresses:

Via dell’Artigianato, 8
36060 Romano d’Ezzelino (VI) – Italy
P.IVA 02218750244
Tel. +39 0424 513210 / +39 0424 513221
Fax +39 0424 513211