1. The purposes of the Processing of Data
The users ‘ personal data will be treated by PACSIS for the following purposes:
a) Fulfillment of contractual obligations (article 6, paragraph (a) of the Law of Personal Data Protection and article 6, n. º 1, paragraph (b) of Regulation (EU) no. 2016/679 of April 27, 2016): in particular, to carry out the General Terms and Conditions of the website, these being accepted by the User during the registration process. Subject to specific and optional consent given by the User to PACSIS to the processing of personal data for marketing purposes under the terms of paragraph 2, all personal data (name, surname, address, e-mail and telephone contacts) will only be used by PACSIS to determine the identity of the User (also by means of email validation), to avoid fraud or the practice of illicit acts and the contact with the User for issues related with the service provision;
b) Fulfillment of legal obligations (article 6, paragraph (b) of the Law of Personal Data Protection and article 6, n. º 1, paragraph (c) of Regulation (EU) no. 2016/679, of April 27, 2016), for the fulfillment of legal obligations established by the national law, and European laws or regulations.
PACSIS may also use your data for the following purposes:
Studies and Market Analyses;
Marketing of Products and Services;
Development and Testing of Products;
Support in the Relationship with Customers; and,
Work Planning and Support of Management Decisions and Market Strategies.
The provision of personal data for the processing purposes mentioned above is optional, but necessary, to the extent that the failure to provide them implies the impossibility of registration and use of the website. The asterisk in the registration form identifies the personal data necessary for the execution of the purposes of the processing described in paragraph 1.
2. Additional purposes of Data Processing: marketing (sending promotional material, direct sales and commercial communication)
With the express, free and informed consent of the user, some personal data of the user (first name, last name, email, address, and telephone number- landline and mobile) may also be processed by PACSIS for marketing purposes (direct sales, sending of promotional material and commercial communication), or for PACSIS to be able to contact the User through e-mail to suggest the purchase of products and/or services offered by the PACSIS and/or by third parties, to present offers, promotions, or business opportunities.
The consent for the processing of data for such purposes is free and optional. If the consent has been given, the User may revoke the same at any time through communication to PACSIS, and for all intents and purposes using the methods specified in paragraph 7 of this policy. The User can also exercise the right of opposition to the sending of commercial communications (by e-mail) by clicking on the specific link to revocation of consent, which is included in all marketing e-mails. If the consent has been revoked, the PACSIS may send an e-mail to the User to confirm the effective revocation of consent.
PACSIS hereby informs that, following the exercise of the right of opposition to the sending of commercial communications, the User may continue to receive marketing messages due to technical issues (for example, marketing messages prepared just prior to the exercise of the right of opposition). If you continue to receive marketing communications within 72 hours of the exercise of the right of opposition, PACSIS requests that the situation be immediately reported, using, to do so, the contacts specified in paragraph 7 of this policy.
3. Methods of Treatment
The treatment of the personal data of the users will run automated and manually by computer tools, applying logics strictly related to the purposes and, in any case, ensuring the security and confidentiality of personal data.
4. Disclosure and Transmission of Personal Data
The employees of PACSIS appointed to manage the personal data may access to the personal data of the Users. Those employees appointed by the PACSIS as ‘people responsible for the processing’ will treat the personal data of the Users exclusively for the purposes specified in the terms of this policy and in strict compliance with the Law of Protection of Personal Data and Regulation (EU) no. 2016/679, of April 27, 2016.
The third parties who may process personal data on behalf of PACSIS, may also access the personal data of the Users on the quality of subcontractors, such as, including, without limitation, providers of IT services necessary for the operation of the website, providers of outsourcing services or cloud computing services, professionals and consultants, or platform-responsible for sending marketing emails on behalf of PACSIS.
PACSIS may share your data with third parties for the accomplishment of marketing initiatives and advertising, ensuring that all third parties involved in the process of data treatment are committed to comply with and respect the provisions of the Law of Protection of Personal Data and Regulation (EU) no. 2016/679, of April 27, 2016.
Please be advised that, in fulfillment of legal and/or contractual obligations, personal data may also be transmitted to the judicial, administrative, supervisory or regulatory authorities and also to entities that perform, lawfully, actions of data collection, actions of prevention and fight against fraud, market or statistics studies.
Users have the right to obtain a complete and updated list of subcontractors (if any) appointed by PACSIS, and, to do so, must send a specific request to PACSIS under the terms specified in paragraph 7 of this policy.
5. Rights of the Holders of the Data
In accordance with article 10 of the Law 67/98, of October26, and article 12 of Regulation (EU) no. 2016/679, of April 27, 2016, PACSIS informs that users have the right to obtain information about (i) the identity of the person responsible for the processing and, if applicable, of his representative; (ii) the purposes of the processing, (iii) the recipients or categories of recipients of the data, (iv) the voluntary or mandatory nature of the response, as well as the possible consequences of not responding, and (v) the existence and the conditions of the right of access and rectification, provided that they are necessary, taking into account the specific circumstances of the collection of the data, to ensure to its holder a fair processing in respect of the same. In addition, PACSIS informs the data subjects that they have the right to: a) update, rectify or, when interested, to require the integration of data; b) deletion, anonymisation or blocking of personal data that have been processed unlawfully, including personal data whose retention is not necessary for the purposes for which it has been collected and therefore to be treated; (c) the certification that the operations performed in accordance with the letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated to or disseminated, unless this requirement proves itself to be impossible or involves an effort manifestly disproportionate compared with the right that must be protected. Users have the right to object, in whole or in part: a) for legitimate reasons, to the processing of their personal data, even if they are relevant to the purposes of collection; (b) to the processing of personal data for purposes of sending promotional material, direct sales or for carrying out Market surveys or commercial communication.
6. Security and Confidentiality
7. How to Contact PACSIS in Matters of Privacy and Data Protection
Users may exercise their rights upon the contact with PACSIS through the following methods: (i) sending a registered letter with acknowledgment of receipt to the indicated address of PACSIS, (ii) sending of electronic mail to the mailbox [email protected]