Fisiolink Srls, (VAT and Tax Code: 04054810249) (hereinafter “Mobelt“), represented by its legal representative pro tempore, with registered office in Arzignano (VI), Piazza Campo Marzio, 15, as the Data Controller pursuant to Articles 4(7) and 24 of EU Regulation no. 2016/679 (GDPR), hereby informs you, in accordance with Article 13 of the GDPR, that your personal data described in the following Article 1 will be processed for the purposes outlined in the following Article 2.
1. Category of personal data subject to processing.
1.1. The Data Controller will process your personal data pursuant to Art. 4 no. 1) of the GDPR (e.g. name, surname, e-mail address (ordinary and/or certified), so-called financial/banking data).
2. Purpose and legal basis of the processing.
2.1 In compliance with Art. 6(1)(b) and (c) and Recitals 44 and 45 of the GDPR (as well as in compliance with EDPB Guidelines no. 2/2019), your personal data will be processed by Mobelt for the following purposes:
a. Execution of your request to register on the website www.mobelt.it (hereinafter referred to as the “Site”);
b. Execution of a purchase order and consequent conclusion of the related sales contract (including, as necessary and provided for in the context of a usual contractual relationship: e.g. corrections of delays, errors or defects in the execution of a contract; return of goods or payment received) between you and Mobelt, concerning one or more goods offered for sale by Mobelt within the Site;
c. Execution of a pre-contractual measure formulated by you on the Site (e.g. contact, request for information);
d. Fulfillment of one or more legal obligations connected, directly or indirectly, to the pre-contractual or contractual relationship between you and Mobelt (e.g. fraud prevention; accounting, tax or administrative burdens).
In this regard, Mobelt specifies that, in compliance with Art. 2 quinques of the amended Legislative Decree no. 196/2003 (Privacy Code), registration on the Site is only allowed for individuals over 14 years of age or, in the absence thereof, for the legal guardian of the related minor. Also, in compliance with Art. 13(2)(e) of the GDPR, failure to provide your personal data for the processing purposes referred to in Art. 2.1 will result in the impossibility of a correct and complete execution of any pre-contractual or contractual relationship between you and Mobelt, including the consequent fulfillment referred to in Art. 2.1 above.
2.2. In compliance with Art. 6(1)(f) and Recital 47 of the GDPR and in compliance with Art. 130(4) of the Privacy Code, your personal data will be processed by Mobelt for the execution of the following purpose:
a. Marketing activities (to be intended as commercial, advertising and promotional communication or market research), to be carried out through so-called automated means (e.g. email) and/or traditional means (e.g. mail);
b. Profiling pursuant to Art. 4 no. 4) of the GDPR concerning the analysis of personal preferences and interests, to be carried out on the basis of products purchased and/or selected by you within the Site.
In compliance with Art. 13(2)(c) of the GDPR, Mobelt informs you of your right to revoke, at any time, the consent given for one or more of the processing purposes indicated in Art. 2.3, without prejudice to the lawfulness of the processing based on the consent given before the revocation.
3.1. In compliance with Article 13(1)(e) of the GDPR, Mobelt informs that your personal data may be communicated to one or more recipients pursuant to Article 4(9) of the GDPR (which generally belong to the following categories: controlled, controlling, or otherwise affiliated companies of Mobelt; IT companies, including those that provide hosting, mail service or IT storage; various professional consultants (e.g., tax, legal); transport and/or shipping companies; analysis companies; marketing and/or communication companies), for the correct execution of the processing purposes described in Articles 2.1, 2.2 and 2.3.
3.2. Mobelt also specifies that your personal data will not be subject to any dissemination.
4. Retention Period.
4.1. In compliance with Article 13(2)(a) of the GDPR, Mobelt communicates that:
i) the retention period of your personal data processed for the execution of the purpose referred to in Article 2.1 letter a) will last until you decide to irreversibly delete the account created on the Site or until Mobelt decides to delete your account in the event of a violation of the documents outlined on the Site (which may be extended to comply with legal and/or judicial obligations);
ii) the retention period of your personal data processed for the execution of the purposes referred to in Article 2.1 letters b) to d) will coincide with a period not exceeding the pursuit of the underlying purposes (which, approximately, can last up to ten years from the definitive termination of the contractual relationship between you and Mobelt or from the last pre-contractual request made by you to Mobelt, and may be extended to comply with legal and/or judicial obligations);
iii) the retention period of your personal data processed for the execution of the purpose referred to in Article 2.2 will last until you decide to communicate the relevant opposition pursuant to Article 21 of the GDPR;
iv) the retention period of your personal data processed for the execution of the purposes referred to in Article 2.3 letters a) and b) will last until you decide to communicate the revocation pursuant to Article 17 of the GDPR of one or more consents possibly given previously.
Mobelt specifies that your personal data will be stored in archives (telematic and/or paper) located at one or more premises of the Data Controller (or of companies directly or indirectly related to it), but in any case within the EU.
6. Rights of the data subject.
6.1. With regard to their personal data, Mobelt informs that, in compliance with WP Art. 29 Guidelines No. 260/2018 (now EDPB), you have the right to exercise the following rights: right of access under Art. 15 of the GDPR: the right to obtain confirmation of whether or not personal data concerning the data subject is being processed, as well as the information referred to in Article 15 of the GDPR (e.g. purpose of processing, retention period); right of rectification under Art. 16 of the GDPR: the right to correct, update or supplement personal data; right to erasure under Art. 17 of the GDPR: the right to obtain erasure or destruction or anonymization of personal data, subject to the conditions listed in the same article; right to restriction of processing under Art. 18 of the GDPR: a right with a markedly precautionary connotation, aimed at obtaining restriction of processing where the conditions set out in the same article are met; right to data portability under Art. 20 of the GDPR: the right to receive the personal data provided to the controller in a structured, commonly used and machine-readable format (and, where requested, to transmit them directly to another controller), subject to the specific conditions indicated in the same article (e.g. legal basis of consent and/or performance of a contract; personal data provided by the data subject); right to object under Art. 21 of the GDPR: the right to obtain permanent cessation of a particular processing of personal data; right to lodge a complaint with the Supervisory Authority (i.e. the Italian Data Protection Authority) under Art. 77 of the GDPR: the right to lodge a complaint where it is believed that the processing under analysis violates national and Community legislation on the protection of personal data.
6.2. In compliance with Art. 12, paragraph 1 of the GDPR, Mobelt undertakes to provide the communications referred to in Articles 15 to 22 and 34 of the GDPR in a concise, transparent, intelligible, easily accessible and simple and clear language: such information will be provided in writing or by other electronic means or, at the request of the data subject, will be provided orally provided that the identity of the data subject is proven by other means.
6.3. In compliance with Art. 12, paragraph 3 of the GDPR, the controller informs that it undertakes to provide information regarding the action taken in response to a request under Articles 15 to 22 of the GDPR without undue delay and, in any case, no later than one month from the receipt of the request; this period may be extended by two months if necessary, taking into account the complexity and number of requests (in such cases, the controller undertakes to inform the data subject of such extension and the reasons for the delay, within one month of receipt of the request).
6.4. You may exercise, at any time, the aforementioned rights (with the exception of the right under Art. 77 of the GDPR) by using the contact details set out in the following Article
7. Contact details.
7.1. Mobelt can be contacted at the following address: email@example.com
7.2. The Data Protection Officer (DPO) under Art. 37 of the GDPR, appointed by Mobelt, can be contacted at the following address: firstname.lastname@example.org
Arzignano (VI), August 2023
(on behalf of its legal representative pro tempore)