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PRIVACY POLICY

In Courtyard Ltd

80133, Naples Piazza G. Bovio 22

tel. 081 3187864

Share capital: Euro 10,000.00

RI of Naples, tax code and VAT number 09813361210

REA NA-1059313

pec: incortilesrl@pec.it

The company In Cortile srl treats as data controller the personal data provided directly or indirectly, also through its collaborators, by customers, contacts or potential customers (hereinafter jointly referred to as "Customers") in compliance with this information on the treatment of personal data.

1.     Personal data processed by In Cortile srl


In Cortile srl collects the following categories of personal data:

      contact details of the Client or the Client's employees if the latter is a legal entity

      Customer identification data and functional to the controls necessary for the purposes of the applicable legislation, including the legislation on the matter of anti-money laundering

      information provided by the Customer with reference to the assignment entrusted to In Cortile srl;

(hereinafter jointly referred to as the "Personal Data").

1.     Purpose of processing Personal Data

 

In Cortile srl processes Personal Data for the following purposes:

1.     correct and complete execution of professional assignments,

b. administrative/accounting purposes

c. compliance with the applicable legislation (together with point "A" defined as "Contractual Purposes")

2.     to assert and defend one's rights, also in the context of debt collection procedures, also through third parties

3.     for customer segmentation by type or sector of interest

(together with the letter "D" defined as "Purpose of Legitimate Interest")

1.     in the event that the Customer has benefited from the services of In Cortile srl or has requested them, for sending professional communications via email or promotions, including training events organized by In Cortile srl, it being understood that the Customer may, at the time of conferring the assignment and at any subsequent time, request not to receive any more commercial communications with "Marketing Purposes".

 

 

2.     Legal bases for the processing of personal data


The processing of Personal Data is necessary with reference to the Contractual Purposes given its essentiality in order to:

      execute the professional assignment received

      comply with the provisions of the applicable legislation


The processing of Personal Data for the Purposes of Legitimate Interest is carried out pursuant to article 6, letter f), of Regulation (EU) 2016/679 on the protection of personal data 2016/679 (the "Privacy Regulation") for the pursuit of the legitimate interest of In Cortile srl which is equally balanced with the interest of the Customer, as the personal data processing activity is limited to what is strictly necessary for the execution of such activities and the segmentation is carried out only within the limits indicated above. Processing for Legitimate Interest Purposes is not mandatory and the Customer may oppose such processing in the manner described in this information and in this case In Cortile srl will not be able to process Personal Data for this purpose, unless In Cortile srl demonstrates the presence of overriding legitimate reasons.

Finally, the treatment is optional for the Marketing Purposes. If the Customer, in accordance with article 130 of Legislative Decree 196/2003, requests not to receive commercial communications from In Cortile srl, he will not be able to receive communications on initiatives and services offered by In Cortile srl

1.     Personal Data processing methods


Personal Data can be processed with manual or IT tools, suitable for guaranteeing security, confidentiality and avoiding unauthorized access, dissemination, modification and theft of data thanks to the adoption of adequate technical, physical and organizational security measures.

1.     Scope of communication and data dissemination


For the above Contractual Purposes, Personal Data may be transferred to the following categories of recipients, located within and, within the limits set out in Section 8 below, outside the European Union: (a) third party suppliers assistance and consultancy services for In Cortile srl with reference to the activities of the technological, accounting, administrative, legal, insurance, IT sectors (by way of example only); (b) counterparties and their advocates; (c) subjects and authorities whose right of access to Personal Data is expressly recognized by law, by regulations or by provisions issued by the competent authorities.

For the above Legitimate Interest Purposes, Personal Data may be transferred to the following categories of recipients, located within and, within the limits set out in Section 8 below, outside the European Union: (a) third party suppliers of assistance and consultancy services for In Cortile srl with reference to credit recovery and assignment activities; (b) the In Cortile srl Offices; and (c) competent authorities.

For the above Marketing Purposes, Personal Data may be transferred to the following categories of recipients, located within and, within the limits set out in Section 8 below, outside the European Union: (a) third parties suppliers of assistance and consultancy services for In Cortile srl with reference to the sending of commercial communications; and (b) the In Cortile srl offices

A complete list of data processors is available, upon request, through the methods indicated in this statement.

1.     Data transfer abroad


Personal Data may be transferred outside the national territory to countries located in the European Union, but could also be transferred outside the European Union. With reference to transfers outside the territory of the European Union to countries not considered adequate by the European Commission, In Cortile srl adopts suitable and appropriate security measures to protect Personal Data. Consequently, any transfer of Personal Data to countries located outside the European Union will take place, in any case, in compliance with the appropriate and appropriate guarantees for the purposes of the transfer itself, such as the standard contractual data protection clauses, pursuant to applicable legislation and in particular articles 45 and 46 of the Privacy Regulation.

In any case, the Client has the right to obtain reference to the appropriate or opportune guarantees adopted for the transfer of the Personal Data and the means to obtain a copy of such Personal Data or the place where they have been made available.

1.     Rights of the interested party


The Customer may, at any time and free of charge, by sending a request for assistance, exercise the following rights:

1.     obtain from In Cortile srl confirmation of the existence of data concerning him and be informed about the content, verify its accuracy and request its integration, update or modification;

2.     obtain the cancellation, transformation into anonymous form or blocking of any data processed in violation of the applicable law;

3.     object in whole or in part, for legitimate reasons, to the treatment;

4.     revoke, at any time, the consent to data processing (in relation to treatments for which such consent is possibly necessary), without prejudice to in any way the lawfulness of the treatment based on the consent given before the revocation.

 

 

5.     Data retention terms


Personal Data will be kept for the period of time necessary for the pursuit of the purposes for which such data were collected, as stated in this statement. In any case, the following storage terms will apply with reference to the processing of Personal Data for the purposes set out below:

      for the "Contractual Purposes" and "Legitimate Interest" the Personal Data is kept for a period equal to the duration of the professional appointment (including any renewals) and for the 10 years following the term, termination or withdrawal from the same, except in cases where retention for a subsequent period is required for any disputes, requests from the competent authorities or pursuant to the applicable legislation;

      for "Marketing Purposes" relating to the sending of commercial communications, Personal Data is kept for up to 24 months following the last contact with In Cortile srl understood as the last task assigned, participation in events or initiatives organized by In Cortile srl or opening of commercial communications sent by In Cortile srl, it being understood that the Customer may at any time request not to receive more commercial communications from In Cortile srl

 

 

1.     Changes and updates


This information may be subject to changes and additions, also as a consequence of the updating of the legislation on the processing of applicable personal data. The changes will be notified in advance and the Clients will be able to view the text of the information which is constantly updated.

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