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INFORMATION ON THE PROCESSING OF PERSONAL DATA

Introduction

In compliance with the provisions of the EU Privacy Regulation 2016/679 (hereinafter referred to as the “Regulation” or “GDPR”), Relavo & Partners S.à r.l. with registered office in Gonderange in rue Belle-Vue 2, L-6181, Grand Duchy of Luxembourg (hereinafter also referred to as “the owner”) provides you with the information required regarding the purposes and methods of processing of your personal data that are necessary to be able to effectively fulfill the professional assignment assigned, as well as the scope of communication and dissemination of the same, the nature of the data in our possession and their provision in relation to the relationship.

1 - Who is the data controller of the personal data?

Relavo & Partners S.à r.l. is the data controller of the customer’s data. “Data controller” means the natural or legal person who determines the purposes and means of the processing of personal data

​2 - What personal data do we process?

Personal data means, pursuant to art. 4 of the Regulation, any type of information relating to an identified or identifiable natural person. Relavo & Partners S.à r.l. will process, in compliance with the principles set out in art. 5 of the GDPR, the common identification data of customers (for example name, surname, date and place of birth, personal contact details, VAT number, bank details, address of residence, province and postcode). If the customer is a company, the common personal data of its employees, customers and management may be processed.

​3 - On what legal bases will we process your data?

The processing can be validly carried out when there is a basis for the legal bases provided for in the Regulation. Specifically, the processing of common data will be based on art. 6 of the GDPR 1st paragraph:

  • - lett. b): execution of a contract or pre-contractual measures;

  • - lett. c): fulfillment of the legal obligations to which we are subject;

  • - lett. f): legitimate interest of the owner since, given that there is a relevant and appropriate relationship between the owner and the interested party (the latter being a customer of the company), in the context of the collection of personal data it is reasonable that the interested party may receive informative communications and requests related to the activity of the owner.

​4 - For what purposes will we process your data?

Your personal data will be processed exclusively for the following purposes:

  • - correct and complete execution of the professional assignment received;

  • - fulfillment of the legal obligations to which the owner (for example in the field of anti-money laundering) and the interested party are subject, also towards the financial administration;

  • - management of relationships with credit institutions;

  • - ascertainment, exercise or defense of a right or legal claim.

5 - What do the processing methods consist of?

The processing will be carried out, in compliance with the aforementioned purposes, with or without the aid of electronic tools by the owner and/or employees and/or collaborators of the owner specifically authorized for this purpose.

​6 - Who are the subjects who may access your data or to whom they may be communicated?

Your data may be communicated, in accordance with the Regulation, the sector legislation and this information notice:

  • - to professionals to whom Relavo & Partners S.à r.l. entrusts the management of professional assignments received from the client;

  • - to third-party companies or other subjects who carry out activities on behalf of the owner, also in their capacity as external data controllers;

  • - to any subjects to whom the processing is addressed, such as, for example, insurance companies and credit institutions, technicians responsible for the maintenance and/or repair of hardware, software and all IT and telematic equipment;

  • - to employees and collaborators, specifically authorized;

  • - to subjects who can access the data by virtue of provisions of law, regulation or community legislation, within the limits set by such provisions;

  • - to subjects to whom they must be communicated by law.

​7 - Is it necessary to provide the personal data requested by the owner?

The release of the data requested by Relavo & Partners S.à r.l. is mandatory for the fulfillment of the purposes indicated above, in particular for the correct and profitable execution of the professional assignment. The client is hereby informed that failure to provide or partial provision of the requested data may result in the impossibility of carrying out the assignment or its partial execution.

​8 - How are your data protected?

In order to guarantee an adequate level of data protection to limit the risk of improper use or unlawful use of the same, technical and organizational security measures have been adopted that comply with the parameters established by art. 32 of the GDPR. In particular, we use commercially reasonable technical and organizational measures and controls to protect the customer's personal information from loss, abuse and unauthorized access.

​9 - How long will your data be stored?

In accordance with art. 5 I° paragraph lett. e) of the GDPR, we will process your data only for the time necessary to pursue the purposes indicated above. In particular, the data provided will be stored by the owner according to the following parameters:

  • - for administration, accounting and management of any litigation: 10 years from the termination of the contractual relationship or for the time required and/or imposed by regulatory obligations and in any case until the expiry of the limitation periods in order to be able to assert any existing legal claims;

  • - for the entire duration of the assignment received;

  • - for the management of the internal archive, the data will be stored for the period necessary to allow the correct maintenance of the archive itself for internal organizational purposes.

10 - Where will your data be transferred?

The management and storage of personal data will take place within the European Union and/or in non-EU countries for which an adequacy decision by the European Commission is in force.

​11 - What rights does the Regulation grant you?

The GDPR grants data subjects the right to ask the Data Controller, at any time, for access to their personal data, their rectification or erasure, the right to object to their processing and/or to request their limitation in the cases provided for by art. 18 of the Regulation, as well as to obtain the data concerning them in a structured, commonly used and machine-readable format, if the conditions set out in art. 20 of the Regulation apply. Requests must be sent in writing to the Data Controller at the following address: admin@relavo.eu. The interested party always has the right to lodge a complaint with the authority to the Guarantor for the Protection of Personal Data pursuant to art. 77 of the Regulation, if he/she believes that the processing of his/her Personal Data is contrary to the legislation in force.

12 - How do we manage the changes made to this Policy?

Should there be substantial changes to this Policy, we will promptly inform you of such changes.

​13 - Who are the data controllers appointed by the data controller?

The deeds of appointment of the data controllers or sub-processors, of the internal authorized subjects and any other information regarding your data can be provided to you by means of your written request to be sent to the email address: admin@relavo.eu.