WINSME S.r.l. single member limited partnership (hereafter “WINSME” or “Data Controller”), provides the following information in accordance with art. 13 of EU Regulation no. 2016/679 of 27 April 2016 (hereafter GDPR), to describe the features of the processing performed on your personal data with the measures adopted to safeguard your rights.
The Data Controller is WINSME S.r.l. single member limited partnership (VAT code 10545840968) with registered office in Via Michelangelo Buonarroti n. 39 – 20145 – Milan – e-mail: firstname.lastname@example.org
Data subject to processing
WINSME collects the following personal data:
- contact data
Purposes of processing
Personal data are processed for the following purposes:
- responding to a request for information
Why our processing is lawful
Our processing is lawful because it is:
- performed to implement pre-contractual obligations.
Data retention time
Data collected for “Purposes of processing”
- envisaged under letter (a) will be kept for a period not exceeding fifteen months.
Methods of personal data processing and place of conservation
Personal data are processed with both hard copy and electronic media (e.g., server, cloud database, application software).
Optional or mandatory nature of the provision of data
Provision of the data requested under letters (a) of “Purposes of processing” is mandatory and failure to provide these data will mean that the Data Controller cannot fulfilling the request of the Data Subject.
Categories of subjects to whom personal data may be communicated
Personal data provided to us may be processed, in compliance with the principle of the strict indispensability of the processing:
- By WINSME employees, acting and processing the data under the authority and instructions of the Data Controller, as of art. 29 of the GDPR, or by employees appointed by the Data Controller, as of art. 2 quaterdecies of Law Decree no. 101/2018.
- By other state or non-state academic institutions, for the transmission of documentation regarding students’ academic careers, within the limits of data indispensable for provision of the services.
- By public bodies implementing dispositions of law (e.g, Public Administrations).
- By natural or legal persons who the Data Controller makes use of for the performance of activities necessary to achieve the Purposes as of above (by way of example only: student teaching services, suppliers of IT and application services, supervisory services, paediatrician), or to whom the Data Controller is required to communicate the data, as a result of legal or contractual obligations. The providers of services appointed as external Data Processors will be subject to contractual and legal obligations to maintain the confidentiality of the data and they will have access solely to the information necessary to perform their functions.
A list of data Data Processors is available at the Data Controller’s premises.
Personal data will not be disseminated under any circumstances.
Rights of the interested party
In relation to the processing of personal data, pursuant to the GDPR, the interested party
has the right:
- Right of access: the interested party has the right to obtain a copy of their personal data that WINSME is in possession of and that are processed.
- Right to rectification: the interested party has the right to rectify the personal data stored by WINSME if they are not updated or correct.
- Right to revoke a given consent: at any time, the interested party can also revoke the consent given for a specific processing.
- Right to contact the Guarantor Authority for the protection of personal data, if the interested party has doubts about the processing of personal data carried out by WINSME.
The interested party can also exercise the following rights under specific circumstances:
- Right to erasure: the interested party can request that WINSME erases their personal data if the purposes of the processing have ceased and there are no legitimate interests or legal provisions that require its continuation.
- Right to object to processing: the interested party can request that WINSME ceases to carry out a specific processing of personal data. The right to object does not apply when the data processing takes place on a contractual basis.
- Right to data portability: the interested party has the right to obtain a copy of the personal data in a structured format of common use and that is readable through an automatic device and has the right to obtain the direct transmission of the personal data from one Data Controller to another without impediments.
- Right to limit the processing: the interested party has the right to request that WINS limits the processing operations on their personal data.
To exercise each of the rights, the interested party can send an e-mail or write to the following address, specifying the request and providing WINSME with the information necessary for the correct identification of the sender (also attaching a copy of the identity document):
- by e-mail email@example.com
- by mail, Via Michelangelo Buonarroti n. 39 – 20145 – Milan.
The Data Controller will reply within a month. If for some reasons WINSME is unable to reply, it will provide the interested party with a detailed explanation as to why it cannot satisfy their request.
This information notice may be amended or supplemented over time, so we invite you to periodically consult the website www.wins-me.com to remain constantly updated.