PURPOSES AND METHODS OF PROCESSING PERSONAL DATA
The personal data provided by the data subject (the “data”) will be processed for the following purposes:
to provide access to content and news from the world of Brekka (the “service”), in accordance with the methods provided for by BREKKA SRL (“the company”);
to enable the company to carry out surveys designed to improve the quality of the service provided in the legitimate interests of BREKKA SRL, its subsidiaries and affiliated companies and its sales network (“customer satisfaction”);
to send commercial and/or promotional communications regarding the products and services offered by the company, including invitations to Brekka events, and to perform market research activities (“marketing”), subject to the consent of the data subject;
to analyse the behaviour, habits and propensity to consume of the data subject (with his/her consent), with a view to improving the products and services provided by the company and to meeting the specific needs of customers (“profiling”);
to use images of the customer and/or the data subject as part of the customer profiling activity, in order to improve customer management and the customer experience as a whole (once again, this is subject to the consent of the data subject).
subject to the consent of the interested party, to communicate the data to subsidiaries directly and indirectly controlled by BREKKA SRL and/or to companies connected to BREKKA SRL, which may process the data of the data subject in order to send sales and/or promotional communications on the products and services of the aforementioned companies, as well as to perform market research activities.
The processing of data for each of the aforementioned purposes may be carried out using paper-based, automated or electronic means, in particular via ordinary mail or by email, via telephone (e.g. automated calls, SMS messages), via fax and via any other IT channel (e.g. websites, mobile apps etc.).
CONSEQUENCES OF FAILURE TO PROVIDE CONSENT
The provision of consent as referred to in letters c), d), e) and f) above is optional. However, failure to provide this consent will render it impossible for BREKKA SRL to carry out the activities referred to in letters c), d), e), and f).
OTHER PARTIES WHO MAY PROCESS THE DATA
The data may be processed by parties operating on behalf of the company in line with specific contractual obligations, in EU member states or in countries outside of the EU. The data may be disclosed to third parties in order to comply with legal obligations or orders from public authority bodies, or to allow the company to exercise its rights in court.
TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
Within the context of the company’s contractual relations, the data may be transferred outside the European Economic Area (EEA). This may occur via the insertion of the data into databases managed by third-party companies operating on behalf of the company. The management of the databases and the processing of the data therein must comply with the purposes for which this information was collected, and such activities shall be carried out in strict compliance with the applicable laws on the protection of personal data. In cases where the data is transferred outside the EEA, the company will take all appropriate contractual measures necessary and appropriate in order to ensure adequate levels of data protection. These measures may include agreements based on standard contractual clauses for the transfer of data outside the EEA, as approved by the European Commission, among other methods.
THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER
The data controller is BREKKA SRL, with registered office in via L.Pogliaghi, 1 – 20146 Milan . The data subject may contact the Data Protection Officer and the company regarding these issues at the email address [email protected]
STORAGE OF PERSONAL DATA
The data processed in order to provide the service and to deliver customer satisfaction will be kept by the company for the period considered strictly necessary to achieve these ends. Furthermore, the data processed in order to provide the service may be stored for a longer period, to enable any disputes relating to the provision of the service to be handled. Data processed for marketing and profiling purposes will be kept by the company from the point at which the data subject provides his/her consent until this consent is revoked. In the event that consent is revoked, the data may no longer be processed for the aforementioned marketing and profiling purposes, but may still be stored in order to handle any disputes and/or disagreements and/or to ensure the safety of the customer. The time for which data for marketing and profiling purposes is kept by BREKKA SRL is in compliance with local regulations and with the provisions set out by the Data Protection Authority.
THE RIGHTS OF THE DATA SUBJECT
The data subject shall have the following rights:
the right of access, i.e. the right to obtain confirmation from the company as to whether or not personal data concerning him or her are being processed, and where this is the case, to obtain access thereto;
the right to rectification and erasure, i.e. the right to have inaccurate data rectified and/or to have incomplete data completed, and the right to have personal data erased for legitimate reasons;
the right to impose restrictions on the processing of personal data, i.e. the right to request the suspension of data processing for legitimate reasons;
the right to data portability, i.e. the right to receive the data in a structured, commonly-used and easily readable format, as well as the right to transmit the data to another data controller;
the right to object, i.e. the right to oppose the processing of data where legitimate reasons for this exist, including data processed for marketing and profiling purposes, if this is envisaged;
the right to contact the competent data protection authority in case of unlawful data processing.
The data subject may exercise the rights listed above by writing to BREKKA SRL – Customer Service Dept. , via L.Pogliaghi,1 – 20146 Milan , or to the email address [email protected]