Privacy policy

Customer Privacy Notice

Pursuant to Articles 12 and following of Regulation (EU) 2016/679 (hereinafter “GDPR”), Sea Marconi Technologies S.a.s., with its registered office at Via Ungheria, Collegno (Italy), registered in the Turin Companies Register with Tax Code and VAT number 00889150017 (hereinafter the “Company”), informs you that, in the course of its ordinary activities, it processes your Personal Data (including, for example, registration, use, storage, communication).

 

1. Identity and contact details of the Data Controller and the Data Protection Officer

When processing Personal Data, the Company acts as a controller (hereinafter the “Data Controller” or the “Controller”).

For any matters related to the processing of your Personal Data by the Company, and in particular to exercise your rights (briefly mentioned in paragraph 7 below), you can contact the Controller at its registered office indicated above, or send an email to: privacy@seamarconi.it.

 

2. Type of Personal Data, Lawfulness, Purpose of Processing, and Consequences of Refusal

The Company collects and processes your Personal Data (such as, for example, identification and contact information, related to your activities), whether provided by you or by third parties.

Specifically, processing is carried out for the following purposes:

(A) purposes related and functional to marketing activities and/or to the subsequent establishment, management, execution, and termination of the contract entered into with the Company;

(B) administrative purposes;

(C) purposes related to compliance with pre-contractual, contractual, and tax obligations arising from relations with you;

(D) purposes related to obligations imposed by law, regulations, community legislation, or provisions of the Authorities (e.g., compliance with anti-money laundering legislation);

(E) purposes related to the necessity to establish, exercise, or defend a right, including in court;

(F) other purposes strictly related and instrumental to the management of the relationships with you.

The provision of your Personal Data for the above purposes is necessary.

Your refusal to provide the Company with your Personal Data, as described above, will result in the inability to update you on new developments and other marketing and commercial information, as well as to continue with the contract entered into with you.

 

3. Processing Methods

In relation to the purposes indicated, the processing of Personal Data is carried out in full compliance with the principles of confidentiality, integrity, fairness, minimization, accuracy, necessity, relevance, lawfulness, and transparency, using manual, IT, and telematic tools, strictly related to the purposes themselves and, in any case, by applying technical and organizational measures to ensure the security and confidentiality of Personal Data.

The Company emphasizes that, despite the appropriate technical and organizational measures in place, the transmission of Personal Data via the Internet does not guarantee complete security. Additionally, the use of certain methods of transmitting Personal Data, such as instant messaging applications (e.g., WhatsApp) on mobile devices, delivery of unencrypted USB drives, or Cloud tools, significantly increases the risk to the security of Personal Data. The Company cannot guarantee the security of transmitted Personal Data, thereby assuming that the risk of any transmission and the methods used rest with you.

Adequate guarantees regarding the security and confidentiality of the processing of your Personal Data will also be provided by the subjects referred to in paragraph 4.

 

4. Recipients of Personal Data

For the Company’s operations, your Personal Data may be communicated to:

(A) individuals, legal entities, entities, for purposes related to the provision of goods and services to the Controller or those that may carry out activities related, instrumental, or supportive to the activity carried out by the Controller, or activities necessary for the establishment, execution, or termination of the contractual relationship;

(B) subjects who have the legal right to access Personal Data by law or secondary or community regulations;

(C) tax authorities.

The subjects belonging to the above categories will process Personal Data, as appropriate, as (i) independent data controllers, in full autonomy, if unrelated to the original processing carried out by the Company (pursuant to Article 4, paragraph 1, no. 7 GDPR), (ii) joint controllers, if they jointly determine the purposes with the Company (pursuant to Article 26 GDPR), or (iii) data processors, if they carry out the processing on behalf of the Company (pursuant to Article 28 GDPR and Article 29 of the Privacy Code).

You may request from the Controller the nominative list, quality, and contact details of the subjects belonging to the above categories to whom your Personal Data has been communicated.

 

5. Transfer of Personal Data Abroad

For the Company’s operations, Personal Data may be communicated within Italy, to countries within the European Union, or to countries outside the European Union. Some countries outside the European Union may not have provisions on the processing of Personal Data equivalent to those of the GDPR and have not been subject to adequacy decisions by the European Commission: processing in such destination countries, where there are no laws on data protection, may impact the security of the data transferred and the exercise of rights.

In any case, where possible, the Company obtains guarantees from recipients of Personal Data regarding the security of their processing.

 

6. Data Retention Period

The Company will retain your Personal Data in its databases for the time permitted by law for the protection of its legal interests. You may request further information on this by contacting the Controller via the email provided in paragraph 1.

 

7. Data Subject’s Rights

As a data subject, you can exercise all the rights specified in Articles 15-22 of the GDPR. Specifically, by contacting the Controller as indicated in paragraph 1, you have the right to:

  • (A) obtain confirmation as to whether or not your Personal Data is being processed, even if not yet recorded, and its communication in an intelligible form;
  • (B) obtain, among other things, the indication of (i) the origin of the Personal Data; (ii) the purposes and methods of processing; (iii) the identification details of the Controller; (iv) the recipients or categories of recipients to whom Personal Data may be communicated or who may become aware of it, also as data processors; (v) the categories of Personal Data in question; (vi) where possible, the envisaged retention period or the criteria used to determine it; (vii) the existence of the right to request the rectification, deletion of Personal Data, or restriction of the processing of Personal Data; (viii) the existence of the right to object to processing; (ix) the right to lodge a complaint with the supervisory authority; (x) the existence of automated decision-making, including profiling;
  • (C) obtain: (i) the rectification or integration of Personal Data; (ii) the restriction of processing, where possible; (iii) the portability of Personal Data, where applicable; (iv) confirmation that the operations referred to in (i) and (ii) under this letter have been brought to the attention of the recipients to whom the Personal Data was disclosed, except where this proves impossible or involves the use of means manifestly disproportionate to the right being protected;
  • (D) obtain the deletion of Personal Data in cases provided for by law; the Company preempts that there may be cases where it will be entitled to refuse the request for deletion of Personal Data from its databases, as it is legally obligated or entitled to retain a copy;
  • (E) object, in whole or in part: (i) for legitimate reasons to the processing of Personal Data, even if pertinent to the purpose of collection; and (ii) to the processing of Personal Data for the purpose of sending communications.