We wish to inform you that SECO S.p.A. (hereinafter “SECO”) and/or PSM Tech S.r.l. (hereinafter “PSM Tech”) process your personal data in order to perform their obligations arising under the contract and/or the existing relationship with you, as well as for the purposes closely related to them. The processing activities are carried out in compliance with the Regulation (EU) 2016/679 (hereinafter “GDPR”) and any further applicable data protection provisions.
For any further information regarding your personal data processed by SECO or PSM Tech, please write an e-mail to firstname.lastname@example.org.
- Who is responsible for processing your personal data?
The Data Controller is SECO S.p.A., in the person of its legal representative, with head office in Arezzo (AR), 52100, Achille Grandi no. 20, Tel. 0575 26979, fax 0575 350210, for the process of Your personal data referred to the existing relationship with the company.
The Data Controller is PSM Tech S.r.l., in the person of its legal representative, with head office in Arezzo (AR), Via Achille Grandi no. 18, tel 0575 1824517, for the process of Your personal data referred to the existing relationship with the company.
- For what purpose do we process your personal data?
We inform you that your data (including personal data of your employees and collaborators), collected directly from you, or from third parties on your behalf, or acquired from private or public archives in carrying out of economic and commercial activities of SECO or PSM Tech or obtained during the performance of their respective relationship with you, will be processed, directly and/or through third parties, for the following purposes:
- supply products and related services offered by SECO or PSM Tech;
- management of relationship with Suppliers;
- fulfillment of specific pre-contractual and contractual obligations or legal obligations imposed by law or regulations;
- management of the assistance service in case of technical-commercial requests related to products purchased by SECO or PSM Tech and sending service or support messages;
- sending promotional and commercial communications relating to products and services similar to those purchased, without prejudice to your right to object to the sending of such communications in a way that will be indicated from time to time in the same communications;
- economic and administrative management and performance of the order or the contract.
- On what legal basis do we process your personal data?
Your data are processed for the execution or performance of a contract or for the performance of pre-contractual measures taken on your request, as well as to comply with a legal obligation (art. 6, par. 1, b-c, GDPR). The processing of your data may be necessary for the purposes of our legitimate interests to ensure management, protection and improvement of our services and transfer your data among the SECO Group for internal administrative purposes (art. 6, par. 1, f, GDPR).
- What types of data are processed?
For the performance of your relationship with them, SECO and PSM Tech may collect identification data such as name, surname, address, VAT number, and contact details. We will process personal data provided by you, also related to your employees and collaborators, for the implementation and/or performance of our obligation under the existing contractual relationship with you. For these purposes, SECO or PSM Tech may also use your company data, data acquired from private and/or public database (for example, from the Chamber of Commerce) and sometimes the data related to your bank account details.
- Is the provision of your personal data mandatory?
The provision of your personal data is a necessary requirement for the execution and the performance of a contract with SECO or PSM Tech. In case of lack of, partial or incorrect provision of the data SECO and PSM Tech will not be able to performance their legal and contractual obligations.
- How long do we keep your personal data?
Your personal data will be stored for a period of time no longer than that necessary for the purposes for which they were collected, or subsequently processed, pursuant to legal obligations. In particular, your personal data will be retained for the entire duration of the pre-contractual and contractual relationships and, after their extinction, only for the time necessary to ensure fulfillment of all legal obligations.
- To whom can your personal data be disclosed?
Your personal data may be communicated to the following categories of subjects:
- companies of SECO Group for the performance of the contract or your existing relationship with SECO and/or PSM Tech and/or for the related administrative purposes;
- subjects and/or public and private bodies to whom the data will be communicated to demand or to fulfill specific obligations provided by laws, regulations or European legislation;
- freelance professionals or professional firms enrolled for SECO and/or PSM Tech and/or SECO Group defense in litigation and/or administrative proceedings due to the contractual and/or the existing relationship;
- professional firms or consulting companies for administration and accounting, auditing and certification of financial statements services;
- external suppliers of IT services that provide IT maintenance and assistance, IT solutions (such as cloud services) and software solutions on behalf of SECO and/or PSM Tech and/or the SECO Group;
- business partners, operating in the electronics sector, with whom SECO and/or PSM Tech and/or the SECO Group collaborates for the development of projects related to the existing relationship with you;
- banks or other credit institutions for making payments and debt collection companies;
- public security authority and judicial authority, subjects, institutions or authorities to whom the communication of your personal data is required by law or by authorities’ orders;
- national and/or community organizations that fund or grant any kind of contributions;
- agents, subcontractors and any other subject involved in and/or which is part of the SECO Group sales network.
- To whom do we transfer your data abroad?
Your personal data may be transferred abroad both in the European Union and in Third Countries, for the execution and performance of the contract or the pre-contractual measures taken on your request, as well as the fulfillment of obligations imposed by the applicable legislation.
In particular, your personal data may be transferred to:
- the companies of the SECO Group and their agents in order to process purchase orders for products and respond to any information and assistance requests;
- third parties that are part of the worldwide distribution chain that SECO Group uses to process purchase orders, to distribute products, as well as for related services.
Please note that the transfer of your data abroad will take place in accordance with the provisions of art. 44 and following of the GDPR. In particular, we inform you that these transfers may take place on the basis of an adequacy decision adopted by the European Commission which established that the recipient Country ensures an adequate level of protection for personal data.
For transfers to Third Countries in absence of an adequacy decision of the European Commission, SECO and PSM Tech ensure an adequate level of protection of personal data, providing “adequate guarantees” based on the provision of art. 46, GDPR.
You may request SECO or PSM Tech further information regarding such transfers by writing an email at the abovementioned address.
- What are your rights concerning the processing of your personal data?
At any time, you can request further clarification and exercise your rights with reference to the specific processing of your personal data carried out by SECO and PSM Tech pursuant to art. 15 and following of the GDPR. In the manner and to the extent permitted by the law, you may exercise the following rights:
- Right of access: you have the right to obtain access to your personal data. This enables you to receive a copy of the personal data in possession of SECO or PSM Tech and to check that we are lawfully processing it;
- Right to rectification: you have the right to request that your personal data be rectified if they are incorrect, including the right to obtain their integration if they are not complete;
- Right to erasure: you have the right to request your personal data be deleted or removed (for example in case the personal data are no longer necessary for the performance of the contract or you object to the processing and there are no overriding legitimate grounds for the processing);
- Right to restriction: you have the right to obtain the restriction of processing of your personal data where one of the circumstances under article 18 of GDPR occurs;
- Right to data portability: you have the right to get a copy of your data provided to SECO or PSM Tech in a structured, commonly used and machine-readable format transferred to you or to another Data Controller.
- Right to object: without prejudice to any other administrative or judicial remedy, you have also the right to lodge a complaint with the competent supervisory Authority when you consider that the processing of your personal data by SECO or PSM Tech infringes data protection provisions.
Any requests related to the exercise of your rights in respect of SECO or PSM Tech must be addressed to the E-mail above mentioned.