Pursuant to Articles 13 and 14 of Regulation 2016/679/EU (hereinafter referred to as the “GDPR”), Brianzatech of Ryon James Bennett (hereinafter referred to as the “Controller”), with registered office at Via John Fitzgerald Kennedy, 19, 20871 Vimercate MB, in its capacity as the “Data Controller,” informs you that your personal data collected for the purpose of entering into a contract with the Customer and/or in the course of performing and/or executing said contract will be processed in compliance with the aforementioned regulations, in order to guarantee the rights, fundamental freedoms, and dignity of individuals, particularly with regard to confidentiality and personal identity. Please be informed that if the services provided to you involve the processing of personal data of third parties under your control, it is your responsibility to ensure compliance with the legal obligations towards the data subjects, making their processing by us lawful.

Source, Purpose, Legal Basis, and Nature of the Processed Data

The processing of your personal data, which you have directly provided, is carried out by Brianzatech for the purpose of entering into and/or performing and/or executing the contract with the Customer.

It is also possible that the personal data of third parties provided by the Customer to the Company will be processed. In such cases, the Customer acts as an independent data controller and assumes the consequent legal obligations and responsibilities, indemnifying the Company from any disputes, claims, and/or requests for compensation for damages that may arise from the data subjects.

In compliance with current regulations on personal data protection and without requiring specific consent from the data subject, the data will be stored, collected, and processed by the Company for the following purposes:

• Compliance with contractual obligations, performance, and/or execution of the contract with the Customer and/or management of any pre-contractual measures;
• Fulfillment of any legal obligations, including tax and financial obligations arising from business activities, and obligations related to administrative and accounting activities;
• Sending, either directly or through third-party providers of marketing and communication services, newsletters and communications for direct marketing purposes via email, SMS, MMS, push notifications, fax, postal mail, telephone with operator, regarding products provided by other companies in accordance with Article 130(1) and (2) of Legislative Decree 196/03 (hereinafter referred to as the “Code”);
• Communication of data to third-party companies for sending newsletters and marketing communications via email, SMS, MMS, push notifications, fax, postal mail, telephone with operator, in accordance with Article 130(1) and (2) of the Code.

The legal bases for processing for the purposes indicated in points a) and b) above are Articles 6.1(b) and 6.1(c) of the Regulation.

Providing data for these purposes is optional, but failure to provide such data and refusal to do so would make it impossible for the Company to perform and/or enter into the contract and provide the requested services.

The legal basis for processing personal data for the purposes outlined in points c) and d) is Article 6.1(a) of the GDPR, as the processing is based on consent. Please note that the Controller may collect a single consent for the marketing purposes described herein, in accordance with the General Provision of the Data Protection Authority “Guidelines on Promotional Activities and Anti-Spam” of July 4, 2013. The provision of consent for the use of data for marketing purposes is optional, and should the data subject wish to object to the processing of data for marketing purposes, or revoke the consent given, they may do so at any time without any consequences (other than not receiving further marketing communications) by following the instructions in the “Data Subject Rights” section of this Policy.

It is also noted that for processing conducted for the purpose of sending direct advertising or for the Company’s own sales or market research regarding products or services similar to those used by the Customer, the Company may use the email addresses or contact details provided by the Customer in compliance with Article 130(4) of the Code and the Data Protection Authority’s Provision of June 19, 2008, even in the absence of explicit consent. The legal basis for processing for this purpose is Article 6(1)(f) of the GDPR, without prejudice to the right to object to such processing at any time, by following the instructions in the “Data Subject Rights” section of this Policy.

Communication

Data may be communicated to third parties appointed as data processors under Article 28 of the GDPR, particularly to banks, insurance companies, service providers necessary for the Company’s business, or to consultants where necessary for tax, administrative, contractual, or other legitimate reasons under applicable regulations.

Your personal data or third-party personal data in your control may also be disclosed to external companies appointed to fulfill the obligations deriving from the task assigned to Brianzatech. Only the necessary data will be provided for the activities required. All employees, consultants, temporary workers, and/or any other “natural person” performing activities based on instructions received from Brianzatech under Article 29 of the GDPR are appointed as “Data Processors” (also referred to as “Processors”). Brianzatech provides appropriate operational instructions to its Processors or any designated Controllers, particularly regarding the adoption and compliance with security measures to ensure data confidentiality and security. In relation to personal data protection, the Customer is invited, pursuant to Article 33 of the GDPR, to report any circumstances or events that could result in a potential “data breach” to allow immediate evaluation and action to mitigate such events by sending communication to Brianzatech at the contact details below.

The data will not be disseminated.

Brianzatech remains obligated to communicate data to public authorities upon specific request.

International Transfer

The transfer of your personal data abroad may occur if necessary for the management of the assignment received. For processing information and data communicated to these entities, equivalent protection levels will be requested as those used for the personal data of Brianzatech employees. In any case, only the necessary data will be communicated for the purposes outlined, and the legal instruments provided under Chapter V of the GDPR will be applied.

Processing Methods, Logics, and Retention Period

Your data is collected and recorded in a lawful and fair manner for the purposes outlined above, in compliance with the principles and provisions of Article 5(1) of the GDPR.

The processing of personal data is carried out using manual, IT, and telematic tools strictly related to the purposes themselves, ensuring security and confidentiality.

Personal data will be processed by Brianzatech for the duration of the assignment and also thereafter to assert or protect its rights, or for administrative purposes and/or to comply with obligations arising from the applicable regulatory and legal framework, in accordance with specific legal data retention obligations.

Data Subject Rights

In compliance with, within the limits of, and under the conditions established by data protection regulations regarding the exercise of data subjects’ rights concerning the processing outlined in this Policy, you have the right to request confirmation of whether your personal data is being processed, access your personal data, and request rectification, deletion, notification of rectifications and deletions to those to whom the data has been transmitted, restriction of processing in the cases provided by law, data portability of the personal data you have provided in the cases indicated by law, and to object to the processing of your data. Specifically, you have the right to object to decisions based solely on automated processing of your data, including profiling. If you believe that the processing of your data violates the GDPR, you have the right to lodge a complaint with the Data Protection Authority pursuant to Article 77 of the GDPR.

If you would like to request further information on the processing of your personal data or to exercise your rights, you can contact Brianzatech in writing at info@brianzatech.com.

Data Controller

Ryon James Bennett – Brianzatech of Ryon James Bennett
Via John Fitzgerald Kennedy, 19, 20871 Vimercate MB
Email: info@brianzatech.com
VAT No. 11764920960
REA MB-2671667