PRIVACY POLICY

This page describes the methods of processing personal data (of site users, suppliers and customers of the company) carried out by DWire S.r.l., with registered office in Via Lottizzazione 10, 54100 – Massa (MS) – Italy, VAT number: 01266810454, as Data Controller. 

The DPO has been appointed who can be contacted at dpo@scuadra.it 

The information is not provided for other websites that may be consulted by the user via links. 

This document may be subject to updates. Specific information and any requests for consent will be made available in the event of additional and different processing than those regulated below. 

  1. PURPOSE OF THE PROCESSING, DATA SUBJECTS AND TYPES OF DATA COLLECTED, LEGAL BASIS, NATURE OF PROVISION AND RETENTION PERIOD 
PROCESSING PURPOSE  DATA SUBJECT AND DATA PROCESSED  LEGAL BASIS  NATURE OF THE PROVISION  RETENTION PERIOD 
  1. commercial management (pre-contractual and contractual) and service provision 
Customers natural persons, Associates/employees of customers: personal data, contact details  – execution of a contract to which the data subject is a party or execution of pre-contractual measures adopted at the request of the same – fulfilment of a legal obligation to which the data controller is subject 

– pursuit of the legitimate interest of the data controller 

mandatory: the provision is necessary to provide and manage the requested service 

 

 

Without prejudice to legal obligations, personal data will be processed for the period necessary to achieve the purposes for which they are collected and will be stored for the entire duration of the relationship with the data subject and no longer than 10 years from the termination of the same. However, DWire may continue to retain the data for a longer period in order to be able to handle any disputes relating to the relationship established. 
  1. management of purchases of goods and services and related practices 
Associates/employees of suppliers, suppliers natural persons: personal data, contact details 
  1. economic-financial management and related practices 
Customers natural persons, suppliers natural persons: personal data, bank details 
  1. management of the employment relationship and related practices (e.g. health surveillance, health and safety in the workplace, staff training 
Employees/Associates: common and particular personal data (e.g. health care, trade union membership, religious worship, judicial)  – performance of a contract to which the data subject is a party  

– comply with a legal obligation to which the data controller is subject 

– for special data: to fulfil the obligations and exercise the specific rights of the data controller or the data subject in the field of labour law and social security and protection 

Mandatory: as a necessary condition for the establishment and management of the employment relationship and the fulfilment of legal obligations 
  1. Evaluation of the candidate with a view to hiring/collaboration 
potential employees/ Associates: personal data, contact details, residence, data communicated  – execution of a contract to which the data subject is a party or execution of pre-contractual measures adopted at the request of the same 

– for any special data Article 9 GDPR: processing of personal data manifestly made public by the data subject 

Optional: failure to provide data may make it impossible to evaluate and manage the application received  Without prejudice to legal obligations, personal data will be processed for the period necessary to achieve the purposes for which they are collected and will be stored for the entire duration of the relationship with the data subject and no longer than 10 years from the termination of the same. CVs of candidates who are not hired are kept for 1 year from their receipt/acquisition. However, DWire may continue to retain the data for a longer period in order to be able to handle any disputes relating to the relationship established. 
  1. Response and management of requests received by e-mail 
potential customers, requests for information by email or other: personal data, contact details, data communicated  Optional: failure to provide data may make it impossible to provide the requested service to the data subject  Without prejudice to legal obligations, personal data will be processed for the period necessary to achieve the purposes for which they are collected. However, DWire may continue to retain the data for a longer period in order to be able to handle any disputes relating to the relationship established. 
  1. Response and management of requests received through contact forms 
Requesting information through the website form: personal data, contact details, data communicated  The provision of the data indicated in the form as “requested” is mandatory as it is necessary to manage the request received 
  1. management and optimization of the website and social networks 
Website Users: browsing data  – pursuit of the legitimate interest of the Data Controller  the provision is implicit in the use of Internet communication protocols 
  1. Management of reports through the Whistleblowing  portal (please refer to the specific information on the website) 
Whistleblowers: common and particular data, including those relating to third parties named in the report and to the persons reported  – Compliance with legal obligations  mandatory: the provision is necessary for the taking charge and management of the report  The reports are processed and stored by a duly appointed third party, and are kept by the same for 5 years from the closure of the report 

 

We inform you that in any case, according to the provisions of Article 130 paragraph 4 of Legislative Decree 196/2003, the e-mail addresses provided by customers in the context of the sale of a service/supply of a product may be used by the Data Controller for the purpose of selling products and services similar to those covered by the commercial relationship already established. The customer may at any time request the suspension of the sending of such material by using the email indicated or by using the appropriate link included in the communications received. 

  1. MINOR 

DWire S.r.l. does not knowingly use its website to request data from children under the age of 14. 

  1. METHODS OF PROCESSING 

The processing of data for each of the above purposes will be carried out with the support of paper, computer or telematic means, in any case suitable for guaranteeing the security and confidentiality of the related processing. 

The data collected (limited to personal data) may be communicated to non-EU countries, for the purposes indicated above: in this case it undertakes to guarantee appropriate levels of protection and safeguards according to the applicable regulations. 

The Data Controller undertakes to observe specific security measures to prevent the loss of data, illicit or incorrect use and unauthorized access, in full compliance with the laws and regulations. 

  1. SUBJECTS INVOLVED IN THE PROCESSING 

The data collected may be processed, exclusively for the purposes indicated, by DWires employees or by third parties such as: 

  • Customers and/or suppliers of the Data Controller where communication is necessary for the execution of the service provided and/or requested (e.g. couriers, carriers) 
  • companies that provide IT system maintenance services, website maintenance and management; 
  • professional firms, companies that provide assistance and advice to the Data Controller (accountant, labour consultant, internal control bodies, banks, …) 
  • Public Administration that may be authorized, within the limits of legislative, regulatory and contractual provisions. 

The updated list of all data processors may be requested from the Data Controller. 

  1. RIGHTS OF THE DATA SUBJECTS 

The subjects to whom the personal data refer may assert their rights as expressed in art. 15 to 21 of EU Regulation 2016/679, in the manner established by Article 12 of EU Regulation 2016/679, and, as a result: 

  • obtain access to personal data and the rectification or erasure of the same or the limitation of processing concerning you or to object to their processing, as well as the right to data portability; 
  • withdraw consent, where the processing is based on Article 6(1)(a), at any time without prejudice to the lawfulness of the processing based on the consent given before the withdrawal; 
  • lodge a complaint with a supervisory authority. 

Any request in this regard can be sent to the following e-mail address: info@dwire.it or to the following address: Via Lottizzazione 10, 54100 – Massa (MS) – Italy.