Information on the processing of personal data
(Legislative Decree 30.6.2003, n. 196 - Article 13)
The undersigned Athena S.p.A. communicates that it holds your information qualified as personal data under the Data Protection Code (Legislative Decree 30.6.2003, n. 196 – Privacy Code) and shall proceed to the processing for the purposes and in the manner indicated below.
Processing of personal data shall mean any operation or set of operations carried out without the aid of electronic instruments, concerning the collection, recording, organization, storage, consulting, development, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, erasure and destruction of data, even if not registered in a database.
Please be informed that such information will be handled through the aid of paper, computer or telecommunications for the following purposes:
A. Contractual purposes. Mandatory consent.
In relation to the needs of commercial performance of orders received and the consequent fulfillment of legal, obligations fiscal, accounting, administrative and contractual arrangements, in order to attain an effective management of business relationships, Athena S.p.A. will process the data of customers and users.
In addition, as part of the same purposes covered by the processing to allow customers and users the completion of required procedures prior to online registration. The purposes pursue the goal of allowing access to all the concerned areas of the website (or other websites related to Athena S.p.A. and/or related companies, subsidiaries and or linked) is to require that the user authenticate by using login/password. In this context the aims of processing are represented by the goal of allowing managers with the generation and subsequent technical and administrative management of the Client ID and activation codes created in the process of user registration, to handle any kind of request received through restricted areas of the site and provide answers to users.
Under Article. 24 of the Privacy Code, Athena S.p.A. is not required to gather the specific consent for processing for the purposes specified herein since it is designed for the fulfillment of legal obligations and/or a contract or pre-contractual requests relating to the person concerned. Hence the transfer of personal data is compulsory for all that has been required by legal and contractual obligations and therefore the refusal to supply may make it impossible to proceed with contractual relations or perform all obligations properly connected.
B. Communication and dissemination of personal data
The personal data processed for the purposes specified under Paragraph A above shall be communicated to professionals and consultants, lenders, parent companies and subsidiaries and/or affiliates, suppliers, dealers, distributors, business partners. Under Article 13, comma 1, letter d) We inform you that subjects or categories of subjects to whom your personal data may be communicated to or who may come to know them as Data Processors (where any) or as persons in charge of the processing: staff, computer technicians that manage the internal network and the Websites of Athena S.p.A. Personal data will not be disseminated.
C. Processing of personal data for promotional purposes, advertising and marketing. Optional consent.
Personal data collected will also be processed, either on paper as well as via automated/computer modalities, for purposes of commercial promotion, advertising, market research, surveys, statistical analysis, solicitation and marketing in the broadest sense (including prize contests) of the products and/or services. The data processing will be performed by any authorized means though the use of telephone, fax, e-mail, sms or other means of distance communication. The processing can also be performed manually through the use of channels such as postal mail or other brochures and/or catalogs.
By consenting to the processing of personal data for the above purposes, the interested subject specifically takes note of these promotional, sales and marketing purposes of the data processing and expressly and separately authorizes such processing in accordance with art. 130 of the Privacy Code, which for this type of processing provides that the use of electronic communication tools for marketing purposes in the data processing must be based on the gathering of a specific consent, which has to be separate and it is entirely optional.
For the same purposes Athena S.p.A. informs that the data – which shall not be disseminated - may be communicated to third party business partners whom Athena S.p.A. work with (for example in co-branding initiatives) or to third parties whom may be delegated for promotional and advertisement by Athena S.p.A. In the event that such third parties proceed to the processing of personal data on their own as object of commercial communication consented by the interested subject, they will rise autonomous Data Controllers of the data subject to the mandatory obligation to gather an informed and specific consent by the interested subject.
In the event that - for the purposes described above – a reference telephone number of the interested subject is gathered and the interested subject gives his/her optional and specific consent to the processing of such personal data for purposes of commercial promotion and marketing in a broad sense, Athena S.p.A. informs users that it can legally process the telephone reference even if enrolled in the Public Registry of Opt-Out.
We recall with particular attention the fact that the conferral of personal data to Athena S.p.A and consent to the communication to third parties for the purposes described above are entirely voluntary and optional (and in any case such consent may be revoked without any formality even after the lending). An eventual deny of consent by the interested subject shall only have as a consequence that the Data Controller shall be prevented from sending with the means above mentioned advertisements and promotional messages.
Consequently, whereby you decide to give specific consent you must first be informed and aware that the goals of processing are pursued for the specific nature of commercial, advertising, promotional and marketing in the broad sense. In order to act with absolute transparency, we inform you that the data collected shall be further processed:
1. to send by means of any medium of communication to persons who have given their informed consent informative and advertising material, promotional or otherwise having the character of commercial solicitation, including the activities and means provided under Article 130 of the Privacy Code;
2. to carry out direct sales or placement of goods or services of Athena S.p.A and / or third parties;
3. to send commercial information; make commercial interactive communications under article 58 of Legislative Decree 206/2005 through the use of telephone, email, automated calling systems without human intervention, or fax;
4. for the elaboration research studies, market ;
5. to send unsolicited commercial communications under Article 9 of Legislative Decree 9 April 2003 n.70 of transposition of the so-called Electronic Commerce Directive 2000/31/CEE, which requires that unsolicited commercial communications must be immediately and unequivocally identifiable as such and indicates that the recipient of the message may refuse receipt of such communications in the future;
6. to allow Athena S.p.A. (pursuant to art. 16 of the Privacy Code, for any reason - even onerous - and also to any third party in the transactions involving the sale or purchase of commercial databases for the same purposes as above specified), to transfer the databases containing personal data of users who have given their informed consent. Thus giving your optional consent, you acknowledge and consent to these additional, possible processing.
The processing that we intend to undergo has the purpose to enable Athena S.p.A for the operation of services of communication and trade promotion in the broadest sense (including consequential and administrative management activities), and through the use of personal data of persons who have knowingly given their informed consent for the processing of specific business purposes outlined above.
Even where you have given your consent to authorize Athena S.p.A. S.r.l. to pursue all the purposes mentioned in points 1 to 6 above, will remain free to withdraw at any time, without any formality by sending a clear communication to that effect to the email address Athena@athena-spa.com. Following the receipt of the opt-out request, it will be up to Athena S.p.A. S.r.l. to proceed promptly to remove or delete any data from databases and to inform for the same purposes of cancellation any third party to whom the data has been communicated. The mere receipt of a request for cancellation will apply automatically as confirmation by the Data Controller of occurred cancellation.
C.1 Communication and dissemination of personal data processed for promotional purposes, advertising and marketing.
For the purposes mentioned in points1 to 6 above your common personal data may also be communicated to:
1. business partners and/or third party purchasers and/or assigned database, agents or employees of the Data Controller;
2. delegated persons and/or appointed by the Data Controller to carry out activities strictly related to the performance of promotional services, and advertising and commercial solicitation;
3. delegated persons and/or appointed by the Data Controller to carry out technical maintenance (including maintenance of network equipment and electronic communication networks of websites);
4. persons, companies or professional activities that provide accounting, administrative, legal, tax and financial assistance and advice to the Data Controller;
5. persons, bodies or organs to which the disclosure of personal data is mandatory under the provisions of law obligatory by force of disposition of norms or of orders by authorities
In addition, individuals or classes of persons to whom your personal data may be communicated to or who may come to know them as Data Processors (if appointed) or persons in charge of the processing are: administrative management personnel and / or technical information platform managers.
D. Possible filling-in by the interested subject by using third parties’ personal data.
The user acknowledges that any indication (for example in the filling-in of forms and electronic modules on the site) of personal data and contact information of any third party represents a processing of personal data against which the user acts as Data Controller, thus assuming all the obligations and responsibilities of the law. In this sense, you guarantee Athena S.p.A. that any third party data will be so designated by the user (and that will consequently be processed as if the third party had provided their informed consent to the processing) has provided the user with their full consent full compliance with the Data Protection Code. The user confers indemnification with respect to any dispute, claims of damage from handling, etc. that could reach Athena S.p.A. from any third parties concerned as a result of the data provided by the user in breach of the applicable personal protection data laws.
Data Controller and data Processor.
The identifying details of the Data Controller are:
Athena S.p.A. – legal seat in Via delle Albere, 13 - 36045 Alonte (Vicenza) – Italy - R.E.A. VI-139951 – Tax Code and VAT number 00589040245 – Fully paid stock capital: € 10.000,00.
The contact details allowing the user to quickly contact Athena S.p.A. and communicate directly and effectively with the same, including e-mail address are:
Tel. +39 (0)444 727272
Fax +39 (0)444 727222
N. Verde 800491590
The updated list of Data Processors (if any), can be found at the above company.
Keeping of personal data and security measures.
The data will be kept for the time defined by the referenced standards. In any case, the period of conservation of your data will be represented by the necessary time it takes to pursue the above expressed purposes or until such time as Athena S.p.A. receives your cancellation request.
Please also be informed that the data will be collected, processed and stored in full compliance with the provisions of Articles 31 and following of the Privacy Code and the Technical Regulations – Annex attachment B of the Code - regarding security measures.
Exercise of privacy rights by the interested subject.
At any time you may - without any formality - exercise the rights under Art. 7 of the Privacy Code, which for your convenience we have reproduced in full below.
(Right to access personal data and other rights)
1. The interested party has the right to obtain confirmation of whether or not personal data concerning him, even if not yet recorded and their communication in intelligible form.
2. The interested party has the right to obtain information on:
a) origin of personal data;
b) purposes and methods of processing;
c) the logic applied in case of processing with the aid of electronic instruments
d) the identity of the owner, manager and the representatives appointed under article 5, comma 2;
e) on subjects or categories of persons to whom the data may be communicated to or who can learn about them as appointed representative in the State, territory as managers or agents.
3. The interested party has the right to obtain:
a) An updating, rectification or, when interested, an integration of data;
b) the cancellation, the transformation into an anonymous form or blocking of data unlawfully processed, including those that do not need to be kept for the purposes for which the data was collected or subsequently processed;
c) certification that the operations noted in letters a) and b), have been brought to knowledge in regards to their contents, to those whom the data has been communicated or disseminated, except where this requirement proves impossible or involves a manifestly disproportionate to the protected right.
4. the interested part has the right to oppose in whole or in part:
a) for legitimate reasons of the processing of personal data, pertinent to the purpose of the collection;
b) the processing of personal data for purposes of sending advertising materials or direct sales or for carrying out market surveys or commercial communications.