PRIVACY POLICY FOR CUSTOMERS AND SUPPLIERS

As Data Controller, X DataNet Srl (hereinafter “Data Controller” or “X DataNet”), with registered office in Via Punta 13/15 in Mirandola (Modena, Italy), will process the personal data (for example and depending on the purpose of the processing, name and surname, email address, postal address, company role, etc.) of legal representatives, employees and collaborators (hereinafter “data subject”) of potential or actual Customers, or of Suppliers.

Such personal data may be provided by the data subject himself, by the Customer or by the Supplier or, with regard to the data of legal representatives, from publicly accessible sources.

Personal data will be processed for the purpose of:

• a. managing and executing pre-contractual and contractual activities (in this case, the legal basis for such processing is the Data Controller's legitimate interest in entering into contractual relationships with the Customer or Supplier);
• b. fulfilling legal obligations related to the execution of the contract, for example in tax, administrative and accounting matters (in this case the legal basis for such processing is the fulfillment of legal obligations);
• c. limited to potential Customers, making commercial proposals via email or telephone relating to the Data Controller's services and products (in this case the legal basis is the Data Controller's legitimate interest in entering into contractual relationships with the Customer);
• d. limited to actual Customers, send an annual customer satisfaction questionnaire (in this case the legal basis for this processing is the legitimate interest of the Data Controller in improving its products and services).

The nature of the processing is optional; however, in the absence of the data provided for purposes a) and b), it will not be possible for the parties to proceed with the negotiation and execution of the Contract.

Personal data will be processed, in paper form and/or with the aid of electronic means, by authorized personnel and system administrators appointed by X DataNet, as well as by other data processors for the provision of various services, such as tax, commercial, IT and documentation services. Finally, the data may be disclosed to authorized parties pursuant to provisions of law, regulations, and EU legislation.

Personal data will be retained, respectively, for the period strictly necessary to:

• a) and b) the management of pre-contractual and contractual obligations and for the additional period required by applicable tax, administrative, accounting, and civil law regulations. The Contract and the related personal data will be retained for ten years from its conclusion, without prejudice to any additional retention period necessary to manage any disputes;
• c) until the data subject objects, unless it is demonstrated that the processing is necessary for compelling legitimate reasons that prevail over the rights and freedoms of the data subject;
• d) until the data subject objects, unless it is demonstrated that the processing is necessary for compelling legitimate reasons that prevail over the rights and freedoms of the data subject.

Upon expiration of the retention period, the data will be deleted or irreversibly anonymized.

If personal data is transferred outside the European Union, such transfer will take place exclusively in compliance with the guarantees provided by the General Data Protection Regulation (Regulation (EU) 2016/679), such as, by way of example, on the basis of an adequacy decision or by signing of the Standard Contractual Clauses adopted by the European Commission.

The data subjects may request access to their data, their rectification or erasure, restriction or objection to their processing where there are legitimate reasons, as well as lodge a complaint with the competent supervisory authority.

To exercise these rights, you can contact the Data Controller by sending an email to  privacyteam@xdatanet.com  or by sending a certified email to  amministrazione@pec.xdatanet.com  or by sending a registered post to the address indicated above.

X DataNet has appointed a Data Protection Officer (DPO) who can be contacted at the email address dpo@xdatanet.com