Information for data subjects pursuant to art. 13 of General Data Protection Regulation (GDPR) no. 679/2016 and annexed provisions issued by National and European Authorities

• Privacy protection - Last updated 10/03/2018
  • 1. Personal data controller - identification and contact details
  • 2. Contact details of Data Protection Officer
  • 3. Personal data processors and place of processing
  • 4. Legal basis of processing/Why we process your data
  • 5. Which data do we process and how?
  • 6. Processing methods
  • 7. When is the user obliged to provide their data?
  • 8. Protection of minors
  • 9. Categories of recipients to whom personal data may be disclosed
  • 10. Data retention period
  • 11. Transfer to non-EU countries
  • 12. Claim to Data Protection Authority
  • 13. Your rights
  • 14. Which contact details should be used to exercise rights?
  • 15. Terms and methods of response by Controller to those who wish to exercise a right inherent to their personal data
  • 16. Modifications to this information sheet

IC Intracom Italia S.p.A. (hereinafter also IC Intracom and/or company e/o controller) undertakes to continuously offer visitors a web experience characterised by full respect and protection of their Privacy, and gives its Welcome to the www.techly.com website.

We invite you to consult our Privacy Policy and read the following information provided pursuant to art. 13 of the GDPR (General Data Protection Regulation) no. 679/2016 – Privacy Regulation EU; these are intended for those who interact with the web services directly provided by IC Intracom and electronically accessible from the address www.icintracom.biz and aim to describe the methods used to manage said website and not other external websites accessible to the user by means of links. Additional information may be provided within the various access channels.

1.Personal data controller - identification and contact details
IC Intracom Italia S.p.A.
Viale Europa, 33
z.i. Cornadella Sud
33077 Sacile (PN)
Tel. (+39) 0434.735573
Fax (+39) 0434.735535
E-mail: info@techly.com - privacy@techly.com

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2.Contact details of Data Protection Officer
Summary:
No optional nomination had been made on the date this information was published.
Detailed explanation:
As at this day, after making the necessary evaluations, the company has not identified a Data Protection Officer (DPO); the company reserves the right to supplement this information sheet should it decide to proceed differently.

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3.Personal data processors and place of processing
Summary:
Third parties to the Controller, who can manage your personal data on our behalf and in our name. List available at our offices by submitting a request using the contact details reported herein.
Detailed explanation:
The list of identified data processors bound by contract or other legal document, and of the system administrator/s is available at the company premises. Processes connected to the web services offered by this site take place at the IC Intracom premises and possibly at the premises of any external Data Processors and other specifically delegated and authorised subjects (as better described below) and are carried out by parties in charge of managing the requested services, data processing and storage, as well as all necessary maintenance operations. In the case of necessary/useful/guaranteed web services, we specify that data connected to web services may be processed by the personnel of the company/ies responsible for maintaining the technological part of the website and the platform for the newsletter service. With the consent of the data subject, if required by law and in any case further to the publication of an information sheet indicating the various purposes, personal data may be communicated to public and private third parties external to IC Intracom, which shall process the data in the capacity of independent controllers (or processors if applicable) of the data. In this regard, the writer is in no way responsible and furthermore assumes no responsibility for: rules and methods of handling the personal data of other Websites that can be accessed from the pages of the site www.icintracom.biz through links and/or references; the contents of any email services, web spaces, forum chats provided to users.

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4. Legal basis of processing/Why we process your data Underlying purpose (provision of data and mandatory consent)
Summary:

• Response to requests received from the user
• Provision of goods and services
• User contact details for issues connected to requests made by users themselves
• Legal and/or regulatory provisions
• Specific industry provisions

Detailed explanation:
We process your personal data for the following purposes:

• To respond to explicit requests by the data subject/user.
• To comply with obligations resulting from relationships for the supply of goods and services, both during the pre-contractual and contractual stages, with particular regard to the fulfilment of said obligations and the collection of any amounts agreed upon.
• Compliance with obligations set out by national and European legislation, where applicable.
• To invoke the legal, arbitration and administrative rights also of third parties, in respect of regulatory limitations.

Promotional activities (data provision and optional consent)
Summary:
Sending of marketing communications, direct marketing activities, market analyses etc. ...by means of:

• automated instruments (e.g. sms and chat, email, pre-recorded telephone calls)
• traditional (e.g. paper mail, live telephone calls)

Detailed explanation:

• Marketing details: subject to your express consent, we may use computerised and non-computerised tools (i.e. traditional methods such as paper mail and/or live telephone calls) to send communications for the purpose of monitoring the progress of client relations and to plan and execute analytical, strategic and operational marketing activities, and to inform about commercial and promotional activities inherent to goods/services linked to those for which the relationship was established and for which the request for contact was sent. The purpose in question may therefore be pursued for other reasons in addition to those strictly linked to the underlying purpose in the event you decide to provide your consent (after having viewed the information contained herein); should you decide not to provide your consent (optional) for the aforementioned purpose, the basis and consequent obligations of the relationship between our company and yourself shall nonetheless be neither compromised nor altered; formulated applications and requests shall nonetheless be processed. Therefore, should you choose to provide your consent, it shall be intended as valid for contact using both traditional means and computerised means (e.g. email, sms, mms, telefax, automated telephone calls...); should you decide, at any time, to exercise the right to oppose and/or revoke your consent, you may do so in a diversified and autonomous manner for either of the contact methods.
• Mailing list or newsletter: con la registrazione alla mailing list o alla newsletter, l’indirizzo e-mail dell’Utente viene automaticamente inserito in una lista di contatti a cui potranno essere trasmessi messaggi e-mail contenenti informazioni, anche di natura commerciale e promozionale, relative ai nostri servizi. L’indirizzo e-mail dell’Utente potrebbe anche essere aggiunto a questa lista come risultato della registrazione a questa Applicazione o dopo aver effettuato una richiesta.
• Contact/Registration form: by filling in the contact form with their Data, the User provides their consent for its use to respond to requests for information, quotes, or any other type of request indicated in the header of the form.
• Interaction with social networks and external platforms: this type of service allows interactions with social networks, or with external platforms, directly from the pages of this Website. Interactions made and information acquired from this Application are nonetheless subject to the User’s privacy settings for each social network. If a social network interaction service is installed, the latter may collect traffic data relative to the pages in which it is installed, even if the service is not used.

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5. Which data do we process and how?
Summary:

• Browsing and use data
• Email, address, first name, last name /or company name, names of contacts, use data
• System and maintenance log
• Cookies (vd. cookie policy)

Detailed explanation: Personal Data (e.g. email, address, first name, last name /or company name, names of contacts, cookies, use data...) may be voluntarily inserted by the User or automatically collected during use of this Application. To this end we inform you of the fact that, in addition to the data you expressly provide to IC Intracom, other data derived from your browsing of the Website may also be recorded. For all accesses to the Website, we record the type of browser (e.g. Internet Explorer, Chrome, Mozilla), the operating system (e.g. Windows, Macintosh) and the host and URL of origin of the visitor, in addition to data on the requested page. This data may be used in an aggregated and anonymous form for statistical analyses of Website use. Other Personal Data collected may - also in the future - be indicated in other sections of this page or using informative text displayed at the same time as the collection of the Data itself in any dedicated sections. Personal Data may be voluntarily inserted by the User or collected automatically during use of this Application. The use of any Cookies - or other tracking tools - by this Application or by the controllers of third-party services, where not otherwise specified, is for the purpose of identifying the User and recording their preferences for purposes strictly linked to the provision of the service/s and/or information requested by the User themselves. Failure by the User to provide certain Personal Data may prevent this application and the company itself from providing its services. For details, see the cookie policy. The User assumes responsibility for the Personal Data of third parties published or shared using this Website and guarantees to have the right to communicate or diffuse said data, freeing the Controller from any liability toward third parties.

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6. Processing methods
Summary:
Paper and computerised means
Detailed explanation:
Data in relation to you shall be processed using manual and automated tools, using methods strictly correlated to the purposes indicated herein, and nonetheless in such a way as to guarantee the security and confidentiality of your data. Should you wish to receive further information, we remind you of your guaranteed rights as specified herein.

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7. When is the user obliged to provide their data?
Summary:
Underlying purpose: obligatory
Other purposes (marketing/promotional/insertion of stores in map): optional
Detailed explanation:
The types of personal data collected and processed in the website www.icintracom.biz are those necessary to fulfil the requested services and in the remaining cases, are derived from user browsing. It is therefore evident that, in the event said data is not provided, it will not be possible to provide the services requiring use of these tools. Should you choose not to provide your consent to receive marketing or direct sales information, or interactive commercial communications, your email and telephone number will not be used for this purpose.

Attention:
The voluntary sending of emails to the addresses indicated in the website entails the acquisition of the sender's email address, as well as any other information contained in the message; said personal data shall be used for the sole purpose of fulfilling the requested service.
The optional insertion of data in the forms present on the Website (newsletter, contact form, subscription etc.), similarly to the optional, explicit and voluntary sending of data in online forms or emails to the addresses indicated in this Website to receive specific services and/or communications and information, entails the subsequent acquisition of the sender’s address/contact details necessary to respond to requests or provide the requested services, communications and information, as well as any other personal data inserted.

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8. Protection of minors
Summary:
Data pertaining to minors may be processed provided consent is granted or authorised by the holder of parental responsibility.
Detailed explanation:
IC Intracom does not intentionally collect information of a personal nature (such as name, address and telephone number etc.) pertaining to minors. We do not allow minors to subscribe to websites or participate in online competitions or promotions. In any case, should the parent or guardian of a minor suspect that a minor may have nonetheless provided information of a personal nature, he/she must contact us in the event they wish to have the aforementioned information deleted from our archives. Should IC Intracom become aware that it is in possession of information of a personal nature pertaining to a minor, it shall nonetheless immediately delete the aforementioned information from its databases. Should false data be provided, IC Intracom shall be deemed to be released and held harmless from all liability and/or claims, without prejudice to the checks it undertakes to carry out itself. Moreover, it should be noted that all minors must in any case receive due authorisation from their parents or guardians before using or making any kind of information public on the internet.

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9. Categories of recipients to whom personal data may be disclosed
Summary:
- employees and similar of IC Intracom, qualified as subjects “authorised for processing” (administrative, commercial, marketing personnel, system administrators etc. ...), duly trained and monitored by the controller;
- external subjects (e.g. agents, legal consultants, administrative consultants, experts on industry regulations, suppliers of technical services, hosting providers, IT services companies, communication agencies, commercial partners where necessary to comply with specific obligations, etc. ...).
Detailed explanation:
Your data will not be diffused by us, whereby such term implies making indeterminate subjects aware of the data in any way, also by way of consultation or by making it available. In general, your data may be disclosed by us, whereby such term implies making determinate subjects aware of the data in the following terms:

• subjects that may access the data by virtue of legal, regulatory or European provisions, within the limits set out by such standards;
• subjects that may need to access the data for purposes strictly tied to fulfilling requests and purposes ancillary thereto, within the limits strictly necessary for the associated tasks (public security subjects and other public or private subjects to ensure compliance with legal obligations, also of an administrative nature, and similar);
• to employees of the company qualified as subjects authorised to process personal data and to staff responsible for correctly responding to your requests, within the limits of the connected communication needs (therefore your name and email address and any other contact details/tools provided by yourself);
• to managers of the institutional website, who perform technical or organisational tasks on our behalf instrumental to the supply of the requested services, as well as any third parties involved in any way in the activities;
• to subjects that assist us in the transmission of communications having a commercial/promotional purpose;
• to system administrators specifically appointed by the company itself in compliance with regulatory provisions.
  NB: data shall not be disclosed to third parties for their own marketing purposes.

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10. Data retention period
Summary:
10 years for underlying purposes
24 months for marketing purposes (unless authorisation is revoked)
12 months for profiling purposes (unless authorisation is revoked)
Detailed explanation:
Your personal data will be stored in our archives for the underlying purposes and based on your authorisations for the period necessary in order to comply with civil law regulations, or for a maximum of 10 years.
For other purposes, the following retention periods have been defined:
10 years for underlying purposes
24 months for marketing purposes (unless authorisation is revoked)
12 months for profiling purposes (unless authorisation is revoked)
Said retention periods may be reduced and/or increased (with notification to the data subjects) in the event, for example, of instructions received from supervisory Institutions and/or Authorities. Consent can nonetheless be revoked at any time without prejudice to the lawfulness of the processing based on the consent (effectively) granted before the revocation itself.

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11. Transfer to non-EU countries
Summary:
The data controller may transfer your data to non-EU countries in order to use certain services, for example archiving or the creation of mailing lists; naturally, in this case, IC Intracom undertakes to verify security in the transfer of personal data according to the criteria established by the law (for example, the presence of a “legally binding and enforceable instrument” between public authorities or bodies; binding corporate rules; the standard data protection clauses adopted by the Commission; codes of conduct; certification mechanisms).
Detailed explanation:
The transfer of personal data to countries outside the European Union:
may entail greater risks and therefore must be properly monitored;
is a complex activity that requires specific skills.
To this end, the starting point for an organisation must be based on the adoption of countermeasures designed to maintain the same level of protection that would have been afforded to personal data had it remained in the EU. Should IC Intracom make use of such possibilities, it undertakes to collect all supporting documentation beforehand and make it available to the data subjects (for example, the presence of a “legally binding and enforceable instrument” between public authorities or bodies; binding corporate rules; the standard data protection clauses adopted by the Commission; codes of conduct; certification mechanisms), using the same methods as those by which rights can be exercised.

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12. Claim to Data Protection Authority
The procedures available to you and for your protection (in addition to the exercising of rights toward us) are:
Access from the website www.garante privacy.it in the dedicated claims section, if the competent body is an Italian Authority.
or
In accordance with the methods laid down by the supervisory Authority of the member State (if not Italy) in which the data subject normally resides or works, or the place in which the presumed violation occurred.

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13. Your rights
Summary:
Access – Limitation – Correction – Opposition -– Revocation of consent – Deletion (Right to be forgotten) - Portability
Detailed explanation:

• Right of access: you can receive a copy of the personal data which is the object of processing at any time.
• Right of limitation: can be exercised not only if the conditions of lawfulness are violated, but also if a request is made to correct the data or if the data subject opposes its processing; the Controller undertakes to mark the data in question during the period of evaluation of what needs to be done, using organisational methods suited to said scope.
• Right to correction: incorrect personal data relative to you can be corrected without delay and incomplete personal data can be supplemented, also by providing a supplementary declaration.
• Right to opposition: you can oppose at any time, for reasons connected to the particular situation, the processing of your personal data, even if used for direct marketing and/or profiling.
• Right to revoke your consent if provided, for example for marketing and similar purposes.
• Right of deletion (to be forgotten): it is possible to request the deletion of data in a strengthened form, also following the revocation of consent for the processing of personal data by the data subject.
• Right to portability: this does not apply to non-automated processing and therefore to paper archives and/or registers; moreover, the only portable data is that provided by the data subject to the Controller and processed with the consent of the data subject or based on a contract stipulated with the Controller.

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14. Which contact details should be used to exercise rights?
Paper mail (Registered Post with Return Receipt):
IC Intracom Italia S.p.A. Viale Europa, 33 z.i. Cornadella Sud 33077 Sacile (PN)
Tel. (+39) 0434.735573
Fax (+39) 0434.735535
PEC icintracom@legalmail.it
E-mail: info@techly.com - privacy@techly.com

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15. Terms and methods of response by Controller to those who wish to exercise a right inherent to their personal data
Summary:
no. 1 (one) month, extendable up to no. 3 (three) months for more complex cases in writing
Detailed explanation:
We inform you that when you exercise your rights, the Controller must provide a written response, also using electronic tools that facilitate accessibility (orally only further to the express request of the data subject) within no. 1 (one) month, which in complex cases can be extended to no. 3 (three) months, without prejudice to the obligation to provide feedback within one month of the request, also in the case of refusal. The Controller, after evaluating the complexity of the request formulated by the data subject, may determine the value of a contribution to be requested of the data subject, only in the case of manifestly unfounded or excessive requests.

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16. Modifications to this information sheet
The Data Controller reserves the right to make changes to this information sheet at any time, publicising the changes to Users here. We therefore kindly ask that you consult this page often, using the date of the last revision as a reference, indicated at the bottom of the page. Should the User decide not to accept the changes made to this privacy policy, said User shall be obliged to cease using this Application and may request the Data Controller to remove its Personal Data. Unless otherwise specified, the previous information sheet shall continue to apply to the Personal Data collected up until that moment.

Last updated 10/03/2018