New Deal Advisors SpA, with registered office in Milan – 20123, Via Santa Maria Fulcorina, 2, CF 07625910968, in its quality of Data Controller (“Data Controller”), informs you that your Personal Data (or “Data”) will be processed pursuant to EU Regulation 679/2016 and applicable provisions and laws on privacy matters and confidentiality requirements.
- is applied to Personal Data acquired from persons and other subjects;
- explains methods and purposes based on which New Deal Advisors SpA collects, archives and processes Personal Data.
New Deal Advisors SpA will use the Personal Data for the purposes established in this Policy or for different purposes communicated during the data collecting process.
New Deal Advisors SpA’s aim is therefore to be clear on the purposes and the way Personal Data are handled. New Deal Advisors SpA ensures the confidentiality of the persons/subjects who provide Personal Data.
Personal Data collected and processed
New Deal Advisors SpA collects and processes the following Personal Data:
- professional contact information: e.g. name, position, role, legal entity and organisation, phone and mobile phone number, e-mail address, home address and all data that identify the physical person;
- employees Data: collected to establish and manage the contractual relationship;
- customers’ Data: New Deal Advisors SpA collects customers’ Personal Data strictly related to services provided;
- suppliers’ Data: Data related to legal entities who provide services to New Deal Advisors SpA;
- Data related to signed contracts and engagements;
- Data concerning investigations, litigations and claims: if necessary and permitted, these are collected and processed for the purpose of providing the services for which New Deal Advisors SpA was appointed;
- Data collected from public sources (e.g. Linkedin or similar professional networks, directories and online Data) or social media.
Purposes and legal basis of the processing
The processing of Personal Data are mandatory and necessary to the correct establishment and management of the rights of New Deal Advisors SpA and of third subjects and for the execution of the engagements, without prevailing on personal interests and rights of the physical person involved in the relationship.
New Deal Advisors SpA processes Personal Data for the purposes of:
- establishing, managing and performing of the contractual and pre-contractual relationship with the persons/subject;
- managing the services and activities of New Deal Advisors SpA strictly connected to the relationship currently in force and to the consultancy and professional services provided (e.g. tax, accounting and administrative requirements);
- the management of employees relationships;
- checks on customers and suppliers (e.g. concerning anti-laundering controls, sanctions checks and checks to prevent other crimes) to guarantee the accuracy and authenticity of the data acquired on them and of the data underlying the contract;
- the management of contractual conditions relating to payment terms agreement with suppliers and customers;
- sharing of certain data (professional contacts) on the website of New Deal Advisors or for the publication in articles and magazines relating specific activities in which the person/subject may be involved;
- the communications through e-mail, newsletters and other tools to inform the persons/subjects relating news on markets and services of New Deal Advisors SpA;
- the communications through e-mail, newsletters and other tools to inform the persons/subjects on events organised by New Deal Advisors SpA.
The legal basis to use Personal Data for the purposes set above is the consent to data processing. Providing Personal Data related to legal requirements is mandatory and the consent is not needed.
- the fulfilment of the obligations provided by laws, regulations and any national and/or European applicable laws to ensure New Deal Advisors’ compliance.
The legal basis of the purpose set out above is the fulfilment/compliance with laws and/or regulations in force.
- the communication of information related to New Deal Advisors SpA activities and services, strictly connected to the existing relationship;
- the defence and the protection of New Deal Advisors SpA rights in judicial disputes (claims in case of breaches, disputes, judicial litigations or settlements);
- the protection of company assets.
The legal basis of the purposes set out above is the pursuit of legitimate interests of New Deal Advisors SpA, without damaging personal interests of other persons/subjects.
For the pursuit of the purposes set out above, New Deal Advisors SpA may know directly or indirectly Special Categories of Personal Data (e.g. maternity, injuries). Such Data will be processed on the basis of the consent in accordance with privacy laws and applicable regulations.
For the execution of the purposes listed above, the data processing is necessary and the refusal to provide such data shall entail the impossibility to conclude and manage a contract between you and New Deal Advisors SpA.
Personal data of third parties
New Deal Advisors SpA does not collect Data regarding children or other persons under the age of 16.
Distribution and communication of Personal Data collected
The Data collected will never be distributed, except when the disclosure is required in compliance with the law and applicable regulations.
The data may be shared with (i) persons, legal entities, professional firms that provide services or assistance to New Deal Advisors SpA (e.g. professional firms that provide payroll services and accounting and tax assistance), (ii) customers for the execution of the project, (iii) banking institutions for payments and insurance companies and (iv) parties authorised by law, regulations or by provisions issued by Authorities legitimated by the law (national and international public organisations, judicial institutes within civil, criminal and administrative proceedings, as well as other third parties legitimated by law and / or regulations, national or foreign, or in execution of orders issued by a Public Authority).
The persons/subjects belonging to the above categories will use the Personal Data as Data Controller or as Data Processor.
In case New Deal Advisors SpA staff collects Personal Data, they will process them as Authorized Officers by the Controller.
Processing method and archive
The Data shall be processed through the following actions: collection, recording, organisation, structuring, archiving, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment or combination, restriction, erasure and destruction of Data.
The Data are processed using traditional and IT tools and will be kept on paper files and / or electronic files. In any case, their physical security and confidentiality will be guaranteed in order to protect them against the risk of loss, abuse or alteration.
The processing and archiving of Personal Data takes place in Italy, at the premises of the Data Controller and / or third-party companies selected and duly appointed as Data Processors.
New Deal Advisors SpA will process Personal Data for all the duration of the contractual relationship, afterwards these shall be archived in compliance with the ordinary terms limitation set out under the Italian Civil Code or under specific law provisions, for administrative purposes and/or in order to assert or protect a right or a legitimate interest. In case of litigation, the same Personal Data will be archived until its resolution.
New Deal Advisors ensure that the personal information that it holds is subject to appropriate security measures.
New Deal Advisors SpA reserves the right to retain the Data, unless otherwise indicated by the person/subject, who can be contacted subsequently for any new job opportunities, without prejudice to the right to request the deletion of Personal Data from the archives at any time.
In case of specific request, the contact details will be cancelled. In the event that a third party requests not to receive commercial material, the related data will continue to be archived, but commercial materials will no longer be sent.
Personal Data may be accessible for the purposes for which they are collected:
– to the employees of the Controller, to persons authorized by the Controller and / or to Data Processors;
– to third-party legal entities or other persons/subjects (e.g. hardware and software assistance suppliers, professional firms that provide payroll, accounting and tax services, etc.) that carry out outsourcing activities on behalf of the Data Controller and/or in their capacity as Data Controller/Processors.
Personal Data collected may be transferred for the purposes listed above, in EU and non-EU countries. In this case, New Deal Advisors SpA will adopt/share the measures in accordance with the GDPR to legitimize the transfer of Personal Data in these countries.
Rights of involved subject
Pursuant to the GDPR, New Deal Advisors SpA guarantees to persons/subjects the rights set forth by articles 7 and from 15 to 22 of GDPR. These rights include:
– obtaining (i) confirmation as to whether or not Personal Data concerning them are being processed (even if not yet registered) and (ii) the access/communication in a commonly used form of a copy of Personal Data undergoing processing;
– obtaining the indication: a) of Personal Data source; b) of the purposes of the processing; c) of the identification details of the Controller, of the Processors and the authorized Officers; d) of the subjects or categories of subjects to whom the Personal Data may be disclosed, being them Controllers or Processors;
– obtaining: a) the update, the integration, the rectification of incomplete or incorrect or inaccurate Personal Data; b) the erasure, the transformation into anonymous form and the restriction / suspension of Data, including Data whose retention is unnecessary for the purposes for which the Data were initially collected and/or subsequently processed; c) the attestation that the actions referred to letters a) and b) have been communicated, with regard to their content, to persons/subjects whom the data have been communicated or distributed;
– obtaining the transfer of certain Personal Data to another Controller in a format that is commonly used and in a machine readable format (Data portability);
– objecting the Data Processing, in whole or in part: a) for legitimate reasons, to the processing of Personal Data, even if pertinent to the purpose of the collection; b) to the processing of Personal Data for the purpose of sending advertising material or commercial communication, by e-mail and / or phone and / or paper mail;
– withdrawing the consent: if Personal Data are processed on the basis of the consent, the person can withdraw the consent at any time.
The exercise of these rights and further questions on the collection, processing, transfer of Personal Data and on Processors and Authorized Officers may be made by contacting the Controller via registered letter with a form of acknowledgment of receipt.
The hypotheses of limitations to the rights listed above are foreseen by the art. 23 of the GDPR.
The persons/subjects are also authorised to exhibit a complaint with the Data Protection Supervisory Authority, particularly in the EU Member State where they are resident, where New Deal Advisors SpA is located or where the supposed violation/breach of data protection took place. In Italy, the person/subject can register a complaint to the Italian Data Protection Authority for the protection of Personal Data through the website www.garanteprivacy.it.
This Policy is updated as at May 2018.
This Policy may be subject to changes and updates. It is therefore advisable to regularly check this policy and refer to the latest version.
In case of changes of this Policy, they will be highlighted at the beginning of it.
The Data Controller