Data controller

WTS SpA

Via XX Settembre, 120

25020 Flero (BS)

Data controller: Legal representative

Data controller contacts: privacy@wtsgroup.eu; Telephone n. +39 030 3539060

Categories of processed data

Among the personal data gathered by the website www.ottonemeloda.com, in a direct or indirect way, there are; name, surname, telephone number, address, postal code, city, e-mail address, possible cookie and user’s data.

Here below you can find the complete details of every category of processed data, while the specific policy regarding cookies is available to the following link: http://www.ottonemeloda.com/cookie-policy/

The collected data are intentionally and freely stated by the user by filling out the contact form presented in a relevant section of the website:

http://www.ottonemeloda.com/contacts/

The mandatory data that stated in the a.m. contact form are:

• Name and Surname
• E-mail address
• City
• Messagge

If the user refuses to communicate the mandatory data, it could be impossible www.ottonemeloda.com to answer to the inquiries or requests received.

In case of doubt on the mandatory and/or optional data, the user can contact the data controller.

The possible use of cookies – and other track tools – by www.ottonomeloda.com or by the owner of extra services used by www.ottonomeloda.com, except where otherwise stated, has the purpose to provide to the user the services and information required, in addition to the objective stated in the related document of the cookie policy.

The user is responsible for the communication and the sharing of the personal data of other people’s through www.ottonomeloda.com, and he guarantees that he has the right to communicate and share them. In this way the data controller is not responsible towards third-parties.

Methods and place of data processing

Methods of data processing

The data controller has adopted safety measures which prevent the access, modification, disclosure and unauthorized cancellation of the personal data.

The personal data processing will be carried out by electronic and/or automated instruments in an organized and logical way which follows the principles of honesty and accuracy.

The gathered data may be shared with companies or peoples contractually involved with www.ottonomeloda.com (account, sales and marketing department, legal and network administrators)and also with external parties (entities that provide services for the management of the information, telecommunications networks, e-mail, newsletter and website service management) who can be named – if necessary – data controller.

The list of potential data processors is constantly updated and it is available at WTS SpA.

Legal basis of the data processing

The data controller handles the user’s personal data only when the below condition subsisted:

• The data processing is necessary to perform a contract with the user, to answer an inquiry and/or to process with pre-contractual measures.

Anyway, the concreate legal basis of each process and the purposes of the data processing (if it is foreseen by a contract or if it is necessary to perform a contract) can be required to the data controller.

Place

The data are processed in the operative offices of the data controller or in any other place where the involved parties are located. If you need further information, please contact the data controller.

The user’s personal data collected by the website will not be transferred outside the Italian borders.

Data retention

The personal data are handled and kept for a period not exceeding the purposes for which the data were collected and subsequently processed.

Therefore:

• The personal data gathered to allow the performance of a contract between the data controller and the user will be kept until the performance will be completed.
• The personal data gathered due to an inquiry sent by the user will be kept until the user will receive all the information requested.

If the data processing is based on an user’s approval, the data controller can keep the personal data until the approval is removed. Furthermore, the data controller can be obliged to keep the personal data for a longer period in compliance with a law or with an authority order.

At the end of the data retention, the personal data will be cancelled. Therefore, at the end of the retention, the right to access, cancel and modify the data can not be exercise anymore.

Right of the person concerned

Art. 15 (Right to withdraw), 16 (right to reply) of Reg. UE 2016/679

The user has the right to obtain from the data controller the confirmation that a process of his personal data is ongoing or not; if yes he has the right to access to the personal data and to the below information:

1. The purposes of the data processing;
2. The categories of the personal data involved;
3. To whom the personal data have been communicated, especially if there are third countries or international organization involved;
4. The expected data retention or the parameters used to determine this period;
5. The existence of the right to ask the data controller the amendment, the cancellation and/or the restriction of the process; and the right to oppose to the processing of his personal data;
6. The right to complain to an authority;
7. The existence of an automated decision process. In this case, you can ask information on the logic used together with the importance and the expected consequences of this process for the user.

Art. 17 of Reg. UE 2016/679 – right to erasure («right to be forgotten»)
The person concerned has the right to obtain the cancellation of the personal data by the data controller without unjustified delay and the data controller is obliged to cancel without unjustified delay the personal data, if one of the following causes subsists:

1. The personal data are no more necessary for the purposes for which the data were collected and subsequently processed.
2. The user removed the approval on which the data processing is based on as per art. 6, paragraph 1, letter or as per article 9, paragraph 2, letter a, and if no other legal basis exists.
3. The person concerned objects the data processing as per article 21, paragraph 1, and there is no other legal reason to proceed with the data processing or the person concerned objects the data processing as per article 21, paragraph 2;
4. The personal data are illegally handle;
5. The personal data must be cancelled to fulfill a legal obligation existing in the Union or in the Member State in which the data controller is subjected;
6. The personal data have been collected as per the services offered by the information society as per article 8, paragraph 1 of Reg. UE 2016/679

At. 18 Right to restriction of processing
The person concerned has the right to obtain a restriction of processing when one of the below condition subsists:

1. The user contests the correctness of the personal data. The restriction lasts for the necessary time to verify the exactitude of the personal data;
2. The data processing is illegal and the person concerned objects the cancellation of the data and asked for a restriction;
3. Even if the personal data are no longer necessary for the data controller, they are indispensable for the person concerned for the check, the practice or the defense of a right in a legal branch;
4. The used has objected the data processing as per article 21, paragraph 1, reg UE 2016/679 waiting for a control on the legal reasons why the data controller gathered the information related to the reason of the person concerned.

Art.20 Right to data portability
The person concerned has the right to receive from the data controller his personal data in an organized format which is easily legible by an automatized device. He has also the right to transfer the personal data to another data controller without obstacles from the first one.

Withdrawal of consent of data processing

The person concerned can withdraw the consent of his personal data processing by sending a registered post to the following address: WTS SpA – Via XX Settembre 120 – 25020 Flero (BS) together with a copy of his identity card and with the following sentence: <<withdrawal of consent of processing of my personal data>>.

At the end of this operation, the personal data of the person concerned will be removed from the archives as soon as possible.

If you need further information on the data processing of your personal data, together with the rights stated above, you can send a registered post to the following address: WTS SpA – Via XX Settembre 120 – 25020 Flero (BS).

It could be possible that, before giving you any information, we might have to verify your identity by asking you some questions. Our answer will be sent to you as per the times and ways defined by the reg. EU 2016/679.