Service privacy policy

INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 

Information notice to data subjects – Processing of data for commercial information 

Pursuant to and for the purposes of Article 14 of the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, hereinafter “Regulation”), we inform you that Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l., on the basis of a specific prefectural authorization (pursuant to Art. 134 of Royal Decree no. 773/1931 and subsequent amendments, containing the Consolidated Public Security Act, hereinafter “T.U.L.P.S.”), processes the personal data of the data subject obtained from public registers, lists, deeds or documents accessible to anyone or otherwise publicly available (public sources), or provided directly by the data subjects. Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l. guarantees that the processing of personal data is carried out in compliance with fundamental rights and freedoms, as well as the dignity of the data subject, with particular regard to confidentiality, personal identity, and the right to the protection of personal data.

  1. Purpose of processing personal data

Although the activity mainly concerns data relating to legal entities, some categories of personal data may also be involved (name, surname, email/telephone contact details), mainly relating to individuals holding particular roles within such legal entities (e.g., directors, shareholders, managers, etc.). It should be considered that there exists a legal and/or economic link between a natural person and a legal entity (e.g., company) when one or more of the following situations occur: participation of the data subject in a company through the direct or indirect ownership or control of shares or quotas; exercise, by virtue of a position or role held by the data subject, of effective powers of administration, management, direction, and control over a company.

If such information comes into play, it should be noted that it will in any case originate from public registers, lists, deeds or documents accessible to anyone or otherwise publicly available (public sources), or provided directly by the data subjects. Such data will be processed within the limits and in the manner provided by applicable laws regarding accessibility, usability, and publicity of such data. They will not fall within the category of special data (Art. 9 of the Regulation) nor within that of data relating to criminal convictions and offences (Art. 10 of the Regulation). The data will not be subject to evaluative processing (neither automated nor manual) aimed at forming a judgment on the solidity, solvency, or reliability of the data subject, but will be processed solely for commercial information purposes, in order to facilitate the retrieval of all public information available on companies falling within predetermined targets and to identify suitable subjects for initiating new business relationships as well as for the establishment or management of contractual or pre-contractual relationships. The legal basis legitimizing such processing is legitimate interest (Art. 6, para. 1, letter f of the Regulation).

This notice does not include activities of direct marketing or profiling.

  1. Methods of processing personal data

The processing of personal data takes place at the offices of Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l., or, if necessary, at the subjects indicated in paragraph 4, using both paper and electronic media, also through automated tools designed to store, manage, and transmit the data, in compliance with all precautionary measures ensuring their security and confidentiality. Processing is carried out so as to minimize the risk of destruction or loss, unauthorized access, or processing not in line with the purposes of collection. Personal data are processed in compliance with the principle of minimization, pursuant to Articles 5(1)(c) and 25(2) of the Regulation. Therefore, they are processed lawfully and fairly, collected for specified, explicit, and legitimate purposes, accurate and, where necessary, kept up to date, relevant, complete, and not excessive in relation to the purposes of processing.

  1. Nature of collection and consequences of failure to provide personal data

The data will not be provided by the data subject but will in any case originate from public registers, lists, deeds or documents accessible to anyone or otherwise publicly available (public sources). Such data will be processed within the limits and in the manner provided by applicable laws regarding accessibility, usability, and publicity of such data and will not fall within the category of special data (Art. 9 of the Regulation) nor within that of data relating to criminal convictions and offences (Art. 10 of the Regulation). The data subject may in any case exercise the rights set out in paragraph 7 below.

  1. Communication and dissemination of personal data

Personal data may, where necessary, be communicated (meaning disclosed to one or more specific subjects):

  • to entities whose right of access to the data is recognized by national law, EU law, or collective bargaining agreements;
  • to collaborators and employees of Matchplat within the scope of their duties and/or contractual obligations, including data processors and persons in charge of processing, appointed pursuant to the Regulation.

I dati personali non vengono in alcun caso diffusi, con tale termine intendendosi il darne conoscenza in qualunque modo ad una pluralità di soggetti indeterminati. I dati personali dell’interessato, ferma restando la loro libera circolazione fra gli Stati membri dell’Unione Europea, potranno essere trasferiti anche verso un Paese non appartenente all’Unione Europea nei limiti di cui agli Artt. 44, 45, 46, 47, 48, 49, 50 del Regolamento. 

  1. Titolare del trattamento dei dati personali

The data controller is Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l. As of today, all information regarding the Controller, together with the updated list of processors and appointed system administrators, is available at the headquarters of Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l., Via Gerolamo Zanchi, 22, Bergamo.

  1. Criteria used to determine the retention period of personal data

The personal data of data subjects are processed for the period of time during which they remain accessible and/or published in the public sources from which they originate, in accordance with the relevant regulations.

Information from public sources concerning adverse events (such as bankruptcies or insolvency proceedings, encumbrances, mortgages or seizures, protests) is retained according to the following time limits:

  1. a) information concerning bankruptcies or insolvency proceedings, for no longer than 10 years from the date of the opening of the procedure; after this period, such information may be further used only if other information relating to a subsequent bankruptcy is available or if a new bankruptcy or insolvency procedure is initiated regarding the subject or a connected subject. In such a case, processing may continue for a maximum of 10 years from their respective openings;
  2. b) information relating to encumbrances and mortgage registrations (mortgages and seizures) for no longer than 10 years from the date of registration, unless deleted earlier, in which case a record of the deletion will be retained for a period of 2 years.

7. Rights of the data subject

The data subject may, at any time, exercise the following rights:

  • the right to obtain access to their personal data;
  • the right to obtain the rectification of their personal data, where not contrary to applicable laws on data retention;
  • the right to obtain the erasure of their personal data, where not contrary to applicable laws on data retention;
  • the right to obtain the restriction of processing of their personal data;
  • the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data;
  • the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
  1. Right to lodge a complaint

The data subject is informed of their right to lodge a complaint with a supervisory authority (in particular with the Italian Data Protection Authority).

  1. Source from which personal data were obtained 

Matchplat collects and processes personal data from public registers, lists, deeds or documents accessible to anyone or otherwise publicly available (including, by way of example, from Chambers of Commerce, Revenue Agency, press articles, and publicly accessible websites). Matchplat also collects personal data from such public or generally accessible sources through private providers, based on specific agreements with them.

  1. Data Protection Officer (DPO)

The Data Protection Officer appointed by Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l. is as follows:

DPO  P.IVA  Via/Piazza  CAP  Comune  Nominativo del DPO 
LTA SRL  14243311009  VIA DELLA CONCILIAZIONE,10  00193  Roma  Luigi Recupero 

The Data Protection Officer can be contacted at the registered office of Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l., Via Gerolamo Zanchi, 22, Bergamo. For written requests/communications in digital form, the Data Protection Officer may be contacted through the contact details of Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l. (info@www.matchplat.com) as indicated on the website https://www.matchplat.com/.

PRIVACY POLICY
Regulation (EU) 2016/679
Information notice to data subjects – Data management of the Parties 

Pursuant to and for the purposes of Article 13 of the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, hereinafter “Regulation”), we inform you that Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l. processes the personal data provided and freely communicated by the data subject. Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l. guarantees that the processing of personal data is carried out in compliance with fundamental rights and freedoms, as well as the dignity of the data subject, with particular regard to confidentiality, personal identity, and the right to the protection of personal data.

  1. Purpose of processing personal data (Art. 13.1.c Regulation 679/2016/EU)

All personal data of the Data Subject are processed by the Controller on the basis of one or more of the following lawful grounds:

  • the processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract (Article 6.1.b Regulation 679/2016/EU);
  • the processing is necessary for compliance with a legal obligation to which the Controller is subject (Article 6.1.c Regulation 679/2016/EU).

The purposes for which the personal data of the Data Subject will be processed include:

  • entry into company records and IT databases;
  • management of pre-contractual and contractual stages;
  • management of collections and payments;
  • preparation of internal statistics;
  • compliance with specific requirements.
  1. Methods of processing personal data

The processing of the Data Subject’s personal data takes place at the offices of the Controller or, if necessary, at the subjects indicated in paragraph 4, using both paper and electronic means, by telephone or online, also through automated tools designed to store, manage, and transmit the data, in compliance with all precautionary measures ensuring their security and confidentiality.

Processing is carried out so as to minimize the risk of destruction or loss, unauthorized access, or processing not in line with the purposes of collection. The Data Subject’s personal data are processed:

  • in compliance with the principle of minimization, pursuant to Articles 5.1.c and 25.2 of Regulation 679/2016/EU;
  • lawfully and fairly.

The Data Subject’s personal data are collected:

  • for specified, explicit, and legitimate purposes;
  • accurate and, where necessary, kept up to date;
  • relevant, complete, and not excessive in relation to the purposes of processing.
  1. Nature of collection and consequences of failure to provide personal data (Art. 13.2.e Regulation 679/2016/EU)

The provision of personal data is mandatory for the purposes specified in paragraph 1. Failure to provide such data will result in the inability to deliver the requested service, its proper performance, and compliance with legal obligations. Personal data are stored at company offices and, where necessary, at the subjects indicated in paragraph 4.

  1. Possible recipients or categories of recipients of personal data (Art. 13.1.e Regulation 679/2016/EU)

The personal data of the Data Subject, where necessary, may be communicated (meaning disclosed to one or more specific subjects) to:

  • subjects whose right of access to the data is recognized by national, secondary, or EU legislation;
  • collaborators, employees, and consultants of Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l., within the scope of their duties and/or contractual obligations, including persons authorized to process data, appointed pursuant to Regulation 679/2016/EU;
  • suppliers, including data processors appointed pursuant to Art. 28 of Regulation 679/2016/EU, acting on behalf of Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l.;
  • postal offices, couriers, and shippers for sending documentation and/or materials.

The personal data of the Data Subject will not in any case be disseminated (meaning disclosed in any way to an indefinite number of subjects), except as required by law.

  1. Data Controller (Art. 13.1.a Regulation 679/2016/EU)

The data controller is Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l. As of today, all information regarding the Controller, together with the updated list of processors and appointed system administrators, is available at the headquarters of Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l., Via Gerolamo Zanchi, 22, Bergamo.

  1. Criteria used to determine the retention period (Art. 13.2.a Regulation 679/2016/EU)

I dati personali dell’interessato oggetto del trattamento saranno conservati per il periodo necessario a rispettare i termini di conservazione stabiliti dalla legge e comunque non superiori a quelli necessari per la gestione delle obbligazioni contrattuali e per la gestione dei possibili ricorsi e contenziosi. 

  1. Rights of the Data Subject (Art. 13.2.b Regulation 679/2016/EU)

The Data Subject may, at any time, exercise the following rights:

  • the right to obtain access to their personal data;
  • the right to obtain the rectification of their personal data, where not contrary to applicable laws on data retention;
  • the right to obtain the erasure of their personal data, where not contrary to applicable laws on data retention;
  • the right to obtain the restriction of processing of their personal data;
  • the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data.
  1. Right to lodge a complaint (Art. 13.2.d Regulation 679/2016/EU)

The Data Subject is informed of their right to lodge a complaint with a supervisory authority (in particular with the Italian Data Protection Authority).

  1. Data Protection Officer (DPO)

The Data Protection Officer appointed by Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l. is as follows:

DPO  P.IVA  Via/Piazza  CAP  Comune  Nominativo del DPO 
LTA SRL  14243311009  VIA DELLA CONCILIAZIONE,10  00193  Roma  Luigi Recupero 

The Data Protection Officer can be contacted at the registered office of Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l., Via Gerolamo Zanchi, 22, Bergamo. For written requests/communications in digital form, the Data Protection Officer may be contacted through the contact details of Matchplat S.r.l. – Company subject to management and coordination by Mobo Holding S.r.l. (info@www.matchplat.com) as indicated on the website https://www.matchplat.com/.

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