PRIVACY POLICY – MARKETING AND PROFILING INFORMATION TECNOPOOL S.P.A.
Pursuant to Article 12 of European Regulation No. 679/2016
Transparent Information, Communications, and Modalities for the Exercise of Data Subject Rights.
The data controller Tecnopool S.p.A., located at via Buonarroti 81, 35010 San Giorgio In Bosco (PD) Italy – Tax Code/VAT No. 01822250286, in its capacity as data controller (hereinafter also the “Controller” or “Tecnopool or Company”), adopts appropriate measures to provide the data subject with all the information referred to in Articles 13 and 14 and the communications referred to in Articles 15 to 22 and Article 34 in a concise, transparent, intelligible, and easily accessible manner, using simple and clear language, particularly for information specifically intended for minors. The information is provided in writing through this policy or through other means, including, where appropriate, electronic means.
Tecnopool S.p.A. informs you, pursuant to Articles 12 and 13 of European Regulation No. 679/2016 (hereinafter, “GDPR”), that your data will be processed in the manner and for the purposes indicated below.
In this regard, the Controller invites you to carefully read this policy as it contains important information about the protection of personal data and the security measures adopted to ensure its confidentiality in full compliance with the GDPR.
This Policy:
is intended for data subjects who consent to and/or request to receive communications about promotional, commercial, and advertising activities regarding events, initiatives, or partnerships of Tecnopool S.p.A. Upon receipt of this policy, unless the data subject explicitly refuses to accept it by responding to the indicated email address or through the website’s “unsubscribe” button or by registered letter or simply by calling the number: +39 0499453111 and requesting the revocation of consent, the consent is deemed to be granted.
- DATA CONTROLLER
The Data Controller is Tecnopool S.p.A., located at via M. Buonarroti 81, 35010 San Giorgio in Bosco (PD) Italy
- PERSONAL DATA BEING PROCESSED
The Controller wishes to inform you about products, services, promotions, and commercial events offered.
For the purpose of commercial communications intended for you, the Controller collects and processes the following personal data:
– Name, surname, address, city, ZIP code, telephone number, email address
– Profession/company name and areas of interest
- PROCESSING PURPOSES AND LEGAL BASIS
The personal data you provide when completing the collection form will be processed for the following purposes:
a) Direct Marketing:
– Conduct marketing activities such as statistical analysis and market research
– Send newsletters or other informative and promotional materials about Tecnopool’s activities, products, and services
– Send customer satisfaction surveys
These communications may be sent via automated messages, email, SMS/MMS, fax, postal mail, and/or telephone with an operator. The Controller collects a single consent for the marketing purposes described herein, in accordance with the General Provision of the Personal Data Protection Authority “Guidelines on Promotional Activities and Spam Prevention” of July 4, 2013. In any case, if you wish to object to the processing of your data for marketing purposes using the means indicated here, you may do so at any time, according to the methods described in section 6 of this policy.
b) Analysis and Reporting:
– Conduct analysis and reporting activities related to promotional communication systems
– For example, tracking the number of emails opened, clicks on links within communications, the type of device used to read the communication, and its operating system.
c) Profiling
Only with your prior consent will we be able to process your personal data also for profiling purposes, that is, to analyze or predict, including through automated systems, your personal preferences, and behaviors, in order to create group and individual profiles. These analyses allow us to:
- divide customers into homogeneous groups based on interests.
- develop market analyses and statistics.
- personalize commercial offers based on your profile.
- identify products and services that might interest you.
- improve our services based on the preferences detected.
The profiling activity may include the analysis of:
- purchase history.
- browsing behaviors on our website.
- interactions with our digital communications.
- preferences expressed in surveys or questionnaires.
- demographic data and geographic location.
The provision of data for profiling purposes is optional and withholding consent will not in any way affect your ability to use our services, but it will result in the impossibility of receiving personalized offers based on your interests.
Consent to profiling can be withdrawn at any time without prejudicing the lawfulness of processing based on consent given before its withdrawal. To withdraw consent, you may:
send an email to marketing@tecnopool.it.
The legal basis for processing your data for the purposes referred to in point 1) is Art. 6(1)(a) of the GDPR, that is, your consent. The legal basis for processing your data for the purpose referred to in point 2) is Art. 6(1)(f) of the GDPR, that is, the legitimate interest of the Controller in managing and monitoring its direct marketing activity.
The provision of your personal data for the purpose referred to in points 2) and 3) is optional, but any failure to provide it would make it impossible for Tecnopool to send you commercial communications.
- RECIPIENTS OF PROCESSING AND DATA TRANSFER
For marketing and profiling purposes, your personal data may be communicated to:
- entities that perform functions strictly connected and instrumental to the operation of the service (e.g., email marketing service providers, companies that manage our CRM).
- group companies.
- subjects acting as data processors and/or sub-processors duly appointed (the list is available at the Controller’s headquarters).
- people authorized by Tecnopool to process personal data who have committed to confidentiality or have an adequate legal obligation of confidentiality.
Your personal data will not be transferred outside the European Economic Area (except in cases of sharing with companies belonging to the Tecnopool group).
The legal basis for processing your data for the purposes mentioned in points 2) 3) is Art. 6(1)(a) of the GDPR, namely your consent. The legal basis for processing your data for the purpose mentioned in point 2)3) is Art. 6(1)(f) of the GDPR, namely the Controller’s legitimate interest in managing and monitoring its direct marketing activities.
Providing your personal data for the purposes mentioned in points 2)3) is optional, but failure to do so would prevent Tecnopool from sending you commercial communications.
- RETENTION PERIOD
Personal data is kept only for the period necessary for the purpose for which it is processed or for the terms provided for by applicable national/community laws, rules, and regulations. Consistent with applicable regulations, your data will not be kept until the withdrawal of your consent but, for marketing and profiling purposes, will be processed for a maximum term of 24 months. At the end of this period, your data will be permanently deleted or anonymized, unless you renew your consent to receive our commercial communications.
- CONSENT WITHDRAWAL AND DATA SUBJECT RIGHTS
We remind you that under Art. 7(3) of the GDPR, you have the right to withdraw your consent at any time by sending communication via registered letter to Tecnopool spa located at via M. Buonarroti 81, 35010 San Giorgio in Bosco (PD) or by sending an email to marketing@tecnopool.it.
In any case, withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal.
The Data Subject has the right to ask the Controller at any time:
– Right to Information: Possibility of asking which of their personal data are being processed and the criteria underlying such processing
– Right of Access: To obtain a copy of their Personal Data and additional information about ongoing processing
– Right to Rectification or Update: Of their Personal Data
– Right to Withdraw Consent: The possibility of withdrawing previously given consent for processing personal data for a specific purpose
– Right to Object: The possibility of objecting to the processing of personal data
– Right to Object to Automated Processing: Possibility of objecting to a decision based on automated processing (if present)
– Right to Erasure (Right to be Forgotten): The possibility of requesting the deletion of personal data
– Right to Restrict Processing: When requesting data correction or objecting to processing, pending the Controller’s evaluation
– Right to Data Portability: To obtain a copy of Personal Data in a structured, commonly used, and machine-readable format, or to request its transmission to another Controller
The Controller will provide the Data Subject with information related to one or more of the actions listed above without undue delay and, in any case, no later than one month from the request. This term may be extended by two months, taking into account the complexity and number of requests, with consequent information and update to the Data Subject regarding such extension and the reasons for the delay, always to be provided within one month of receiving the request.
The Data Subject also has the right to lodge a complaint with the competent Supervisory Authority (for Italy: http://www.garanteprivacy.it).
The Data Subject may exercise the rights under this article by sending an email to the following address:
- CHANGES
The Controller reserves the right to update this Policy at any time and inform users through the most appropriate tools. For any further information or questions, it is possible to contact the Controller at the email address: marketing@tecnopool.it.