Privacy Notice Pursuant to Art. 13 of Regulation n. 2016/679/EU (the “GDPR”)

Alfa Group S.p.A. (“Alfa”), with head office in Via Fiume Giallo, 3 – 00144 Rome, VAT Number and Fiscal Code: 05174111004, in the person of its pro tempore legal representative, in the normal course of its business operations (“Business Operations”), comes into contact with, uses and consequently processes personal data of Alfa’s client company, partner and supplier officers as well as the owners of sole-proprietor firms (the “Referents”) to whom it hereby provides this privacy notice pursuant to Art. 13 of the GDPR. 

1. Personal Data Categories and Purposes of the Processing

Alfa, pursuant to Art. 6 lett. b) of the GDPR, will process Referents’ personal data (name and surname; e-mail; Referent’s job duties; corporate mobile phone number; fiscal code and vat number) exclusively to conclude the contract with the company for which the Referent works and/or to execute precontractual measures adopted upon request of the same. The processing of Referents’ data is necessary in order to carry out Alfa’s Business Operations, otherwise every contractual or precontractual relationship with the company, for which the Referent carries out his/her work, would not be possible. 

Alfa recommends that Referents avoid reporting, supplying or indicating personal data beyond that which is strictly necessary for Business Operations.

2. Processing Methods

Alfa, for the same purposes and/or, in any case, for functional purposes strictly related to the Business Operations, could communicate the Referents’ data to other companies belonging to the same Group and/or recipients who will process the data as Data Processors and/or as individuals acting under the authority of the Data Controller and Data Processor, in order to carry out or supply specific services, such as for example: accounting; overall processing relating to payments, invoicing, administration, accounting etc., and who, where necessary, will be appointed by Alfa as Data Processors pursuant to Art. 28 of the GDPR. 

A list of these recipient categories is present on the following website: https://www.alfagroup.it/privacy-categorie-destinatari. 

Alfa will process Referents’ personal data with suitable manual procedures or electronic instruments, in accordance with the principles of correctness, lawfulness, minimization, transparency and protection of data confidentiality in compliance with obligations provided for by laws, regulations or European Union legislation.

Alfa will store Referents’ personal data for the time necessary to carry out Business Operations and while the Referent continues to carry out the same job duties or role for the client companies/partners/suppliers or sole-proprietor firms with which Alfa conducts business. 

In any case, Alfa will store this data for a maximum period of (2) years, or also for a longer period of time in order to fulfil any legal obligations pursuant to Art. 6 lett. c of the GDPR.

Alfa will not transfer, under any circumstances, Referents’ personal data to a third country or an international organization.

3. Referents’ Rights

The Referents, pursuant to Art. 15 and ss. of the GDPR, can exercise, at any moment, their rights with regard to Alfa as well as request confirmation of whether or not their data is being processed, and in such case, obtain access to such data and to the following information: a) purposes of the processing; b) categories of personal data processed; c) the recipients or categories of recipients to whom the personal data has been, or will be, communicated; d) when possible, the estimated period of time the data will be stored or, if not possible, the criteria used to determine this period; e) the existence of the right to request the correction or deletion of personal data or limitation of the processing of personal data that regards them or to oppose the processing; f) the right to lodge a complaint to a control authority; g) if the data wasn’t collected from the Referent, all the information available regarding its origin; h) the existence of an automated decision-making process; i) copy of personal data that will undergo processing (in the case additional copies are requested, provided it does not infringe upon the rights and freedoms of others, Alfa can charge the Referent a reasonable fee based on administrative costs. The information will be provided in a commonly used electronic format, unless otherwise specified by the Referent). Furthermore, Referents will have the right to obtain: a) the updating, rectification or, if there is interest, integration of the data; b) the deletion, transformation into anonymous form or the blockage of data processed in violation of the law, including that for which storage is not necessary in relation to the purposes for which the data was collected or subsequently processed; c) certification that the rectification or deletion operations have been brought to the attention to, also with regard to their content, any recipients of the data, unless this requirement proves impossible or involves the use of means manifestly disproportionate with respect to the right being protected; d) the right to data portability, or to request that the data be transmitted, if technically possible, to another data controller; e) to oppose, entirely or in part, for legitimate reasons, personal data processing, even if relevant to the purpose of the collection.

4. Contact Information

The Data Controller is Alfa Group S.p.A. (“Alfa”), with head office in Via Fiume Giallo, 3 – 00144 Rome, VAT Number and Fiscal Code: 05174111004, in the person of its pro tempore legal representative.

To exercise the rights referred to above, the Referent must direct his/her request to the following e-mail address: privacy@alfgroup.it