Following the entry into force of the new European Regulation (EU) 2016/679 (so-called GDPR) concerning privacy and in consideration of the importance that we recognize to the protection of your personal data, we have proceeded to update our privacy information based on principle of transparency and all the elements required by Article 13 of the GDPR. KeepBu.com with registered office in Haller utca 23-25. A. ép. fszt., 1096 – Budapest – Hungary – HU-26758820 (hereinafter, “Owner“), as data controller, informs you pursuant to art. 13 Legislative Decree 30.6.2003 n. 196 (hereinafter, “Privacy Code“) and art. 13 EU Regulation n. 2016/679 (hereinafter “GDPR“) that your data will be processed in the following manner and for the following purposes:
- Subject of processing
The Owner processes personal, identifying data (for example, name, surname, company name, address, telephone number, e-mail address, bank and payment details) – later, “personal data” or even “data” communicated by you on the occasion of the conclusion of contracts for the owner’s services.
- Purpose of the processing
Your personal data is processed:
- A) without your express consent (art. 24 letter a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes:
- conclude the contracts for the owner’s services;
- fulfill the pre-contractual, contractual and fiscal obligations deriving from existing relationships with you;
- to fulfill the obligations provided for by the law, by a regulation, by EU legislation or by an order of the Authority (such as in the field of anti-money laundering);
- exercise the rights of the Owner, for example the right to defend in court;
- B) Only with your specific and distinct consent (Articles 23 and 130 of the Privacy Code and Article 7 of the GDPR), for the following Marketing Purposes:
- send you via e-mail, mail and / or text message and / or telephone contacts, newsletters, commercial communications and / or advertising material on products or services offered by the Data Controller and detection of the degree of satisfaction with the quality of services;
- send you via e-mail, mail and / or text message and / or telephone contacts commercial and / or promotional communications from third parties (for example, business partners, insurance companies, other companies of the Card Protection Plan Group). We inform you that if you
- are already a customer of ours, we will be able to send you commercial communications relating to the services and products of the Data Controller similar to those that you have already received, unless you disagree (Article 130 c. 4 of the Privacy Code).
- Method and duration of treatment
The processing of your personal data is carried out by means of the operations indicated in the art. 4 Privacy Code and art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subject to both paper and electronic and / or automated processing. The Data Controller will process the personal data for the time necessary to fulfill the aforementioned purposes and in any case for not more than 10 years from the termination of the relationship for the Service Purposes and for no more than 2 years from the collection of data for the Marketing Purposes.
- Access to data
Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):
- to employees and collaborators of the Owner or companies of the Card Protection Plan Group in Italy and abroad, in their capacity as appointees and / or internal processors and / or system administrators;
- to third-party companies or other subjects (for example, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) that carry out outsourced activities on behalf of the Owner, in their capacity as external managers of the treatment.
- Data communication
Without the need for express consent (pursuant to art. 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies (such as IVASS), Judicial Authorities, insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is obligatory by law for the fulfillment of the said purposes. These subjects will treat the data in their capacity as independent data controllers. Your information will not be disseminated.
- Data transfer
Personal data is stored on servers located within the European Union. In any case, it is understood that the owner, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller ensures from now on that the extra-EU data will be transferred in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.
- Nature of data provision and consequences of refusal to respond
The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we cannot guarantee the services of the art. 2.A). The provision of data for the purposes referred to in art. 2.B) is instead optional. He may therefore decide not to give any data or subsequently deny the possibility of processing data already supplied: in this case, he will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Data Controller. However, he will continue to be entitled to the Services referred to in art. 2.A).
- Rights of the interested party
As an interested party, you have the rights set forth in art. 7 Privacy Code and art. 15 GDPR and precisely the rights of:
- obtain confirmation of the existence or not of personal data concerning you, even if not yet recorded, and their communication in intelligible form;
- obtain the indication: a) of the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with the aid of electronic instruments; d) of the identification data concerning the data controller, data processors and the representative designated pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or appointees;
obtain: a) updating, rectification or, when interested, integration of data; b) the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including data which does not need to be kept for the purposes for which the data was collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the event that such fulfillment occurs it proves impossible or involves a manifestly disproportionate use of resources with respect to the protected right;
- object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by phone and / or mail. Please note that the interested party’s right of objection, set out in the previous point b), for direct marketing purposes by automated means, extends to the traditional ones and that the possibility for the interested party to exercise the right of opposition also remains valid only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.
Where applicable, it also has the rights set forth in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right to limitation of treatment, right to data portability, right to object), as well as the right to complain to the Guarantor Authority.
- Mode of exercise of rights
You can exercise your rights at any time by sending:
- a registered letter a.r. to: Export Company Kft., Haller utca 23-25. A. ép. fszt. – 1096 Budapest – Hungary an e-mail to the address: email@example.com
- Owner, manager and appointees
The Data Controller is Export Company Kft. With registered and operational headquarters in Haller utca 23-25. A. ép. fszt. – 1096 Budapest – Hungary. The updated list of data processors and data processors is kept at the registered office of the Data Controller.