Elisabetta Cipriani Ltd as data controller of personal data (hereafter, “Data controller”) informs you that the aforementioned subject in the controller of your personal data and that it will proceed with the related processing for the purposes and with the methods indicated below.
A. Purposes of processing.
A.1 Pre-contractual and contractual purposes
a) Provide a pre-contractual proposals;
b) Obligations arising from the stipulation of the service contracts for the services referred to above, signed with the Customers;
c) Communications on service updates, dissemination of notifications, satisfaction questionnaires, newsletters, information notes or documents related to the signed service contracts.
A.2 Purposes of fulfillment of obligations under the law, regulations or EU regulations.
Personal data will be processed to fulfill the obligations provided for by law, regulation or EU law, as well as for civil, accounting and tax purposes in the field of work, social security and welfare.
The data that will be processed for the purposes set out above may be: personal contact details of the Customers’ and Suppliers’ staff, such as telephone numbers, addresses, and emails.
B. Scope of communication and disclosure of personal data for processing purposes.
In all cases described above, the Data Controller may communicate personal data to third parties to whom communication is necessary for the fulfillment of the obligations deriving from the contracts signed, the requests for estimates sent and the provisions of the law (by way of an example and not exhaustively: persons, companies or professionals/firms that provide assistance, advice or collaboration in technical matters, data processing, accounting, administrative, legal, tax and financial services. We hereby specify the subjects or categories of subjects who may become aware of the personal data of the data subjects as managers or agents, and provide a specific list by categories:
- Personnel of the Data Controller, appointed and authorized to process;
- Third parties involved by the Data Controller for the organization, execution and administrative management of services requested by you (service or material suppliers, technical consultants, IT consultants, legal, tax specialists);
- Public administrative bodies and entities, to fulfill the obligations established by law.
B1. Legal basis, obligation or optional consent for the pursuit of the purposes of the processing of personal data.
The legal basis establishing the lawfulness of the processing described above is specified in the GDPR, art. 6 par. 1 lett. b): “the processing is necessary for the execution of a contract of which the party concerned is a party or for the execution of pre-contractual measures adopted at the request of the same”, lett. c): “the processing is necessary to fulfill a legal obligation to which the data controller is subject”, and lett. f): “the processing is necessary for the pursuit of the legitimate interests of the data controller or third parties”.
Where the interested party did not intend to provide the personal data requested and necessary on the basis of the foregoing, the consequence could be that of the impossibility of using the services provided by Elisabetta Cipriani Ltd.
C. Data retention periods and other information.
The personal data collected will be kept for the time during which they will be considered useful for the purposes for which they were collected.
The five-year or ten-year terms for the conservation of documents and related data of a civil, accounting and fiscal nature are still as required by the law.
D. Data Controller.
The identification details of the Data Controller are as follows:
Elisabetta Cipriani Ltd – 23 Heddon St, London W1B 4BQ – United Kingdom
Email: info@elisabettacipriani.com
E. Exercise of rights by the data subject.
The data subject is informed that:
a) ask the Data Controller for access to and rectification or deletion of personal data or restrictions on processing the data concerning the data subject, or to object to its processing, as well as the right to data portability. To exercise the aforementioned rights it will be sufficient to send an email to info@elisabettacipriani.com making the request explicit;
b) lodge a complaint with the ICO (Information Commissioner’s Office), following the procedures and indications published on the official website https://ico.org.uk/;
c) any corrections or cancellations, or limitations on processing carried out at the request of the data subject – unless this proves impossible or involves a disproportionate effort – will be communicated by Elisabetta Cipriani Ltd to each of the recipients to whom the personal data have been transmitted. The Data Controller shall inform the data subject about those recipients if the data subject requests it. The exercise of rights is not subject to any form of constraint and is free of charge.
F. Updates to this Privacy Policy.
This information is subject to updates due to legislative changes, as well as organizational changes within Elisabetta Cipriani Ltd. The latest updated version is the one published at the Elisabetta Cipriani Ltd website https://www.elisabettacipriani.com/.
The interested parties are therefore invited to periodically check the content.