Information on the processing of GDPR data – EU Regulation no. 679/2016

Premise
Euro Executive srl with legal and operational headquarters in Padua (PD) Via D. Turazza, n.48 int. 32, e-mail: privacy@euroexecutive.it, carries out credit management and recovery activities, both in the field of prevention and reminder and collection, in addition to all those ancillary and complementary activities useful for carrying out the main ones, also by virtue of license from the Padua Police Headquarters.

Scope and Purpose
Pursuant to Article 13 of EU Regulation 679/2016 (GDPR), the data is collected, processed and stored exclusively for the purpose of:
– to be able to carry out credit management and recovery services, in addition to related and functional activities, or any acquisition of impaired loans from third parties (non-performing loans);
– comply with the regulatory provisions on credit recovery (pursuant to Article 115 of the TULPS);
– comply with the legislation to combat money laundering (Legislative Decree 90/2017);
– comply with the fiscal and fiscal provisions deriving from the conduct of the business activity;
– fulfill all obligations and obligations arising from the conduct of the business activity, described in the introduction.

Processing methods
The data is collected, processed and archived in paper, telematic and IT form, both by internal and external personnel.
In both cases, the processing takes place on the basis of formalized assignments (both for the managers and for the appointees) prior to the start of the processing phase, and at the same time as adequate information and instruction on the security measures and procedures to be adopted for ensure an adequate level of safety. The data will be kept for a time not exceeding that strictly necessary for the performance of the assigned task. All data will be processed in compliance with the principles of lawfulness, correctness, and proportionality, with the methods strictly necessary to pursue the purposes inherent in the contractual relationship and for the time necessary to define any accounting and / or administrative operation and for the fulfillment of tax matters.

Mandatory or optional nature of providing data
Euro Executive aims to process the data necessary (by way of example and not limited to: company name, information on offices, turnover, bank references for the transfer of sums, etc.) to carry out its business, both with reference to specific regulations sector (for example linked to the PS license and anti-money laundering legislation) both for internal and organizational statistical purposes.
Failure to provide such data by the interested party would make it impossible to carry out the activity, both according to the organizational procedures in use and the current regulations on the subject, other than those relating to “Privacy”.
All data transferred to Euro Executive by the customer / principal that refers to third parties (for example debtors and / or guarantors and / or co-obligors) are processed on the basis of a declaration certifying that the owner has previously collected them and treated in accordance with current legislation.
With references to debtors, Euro Executive processes the related data, as Data Processor, for the sole purpose of being able to carry out its own characteristic activity. These are transferred by the principal (Data Controller) on the basis of an assignment, in relation to the arising of an obligation that arose previously and not yet satisfied. During the processing, the data may be updated. The debtor has the right to authorize the Euro Executive for different treatments and purposes.

Subjects to whom the data may be communicated and the scope of dissemination of the data
The data may be communicated and / or transferred to third parties, both in Italy and abroad, in order to achieve the purpose of the assignment. By way of example, the subjects to whom the data may be transferred or communicated can be: interested party, professionals, collaborators, consultants, judicial authorities, banks, credit and financial institutions, insurance companies, public administration, partner companies, other recovery companies receivables, commercial information companies (for the acquisition of additional information) collection and collection agents, with whom Euro Executive has reached commercial agreements for the achievement of corporate purposes.
Data relating to customers and debtors are not disclosed; except in the case of the publication of the list of present and past customers: however, the dissemination of data and use for advertising purposes by third parties are excluded.

Rights exercisable by the interested party
General aspects
In compliance with the provisions of the GDPR (article 15 and following), the Data Controller facilitates the exercise of the rights of the individual concerned, bearing in mind that the related interactions and communications must always comply with the following criteria:
– concise, transparent, intelligible and easily accessible form, with simple and clear language.
The information is provided in writing or in other ways, including by electronic means.
Terms and timing
The Data Controller provides the interested party with information relating to the action taken regarding a request, within one month of receipt of the request.
In accordance with the provisions of the GDPR, this term can be extended by two months, if necessary, taking into account the complexity and number of requests, in this case, the Data Controller informs the interested party of this extension.
Exercisable rights
The interested party has the right to obtain confirmation as to whether or not personal data concerning him is being processed.

Furthermore, the interested party has the right to obtain access to personal data as well as to the following information:
– the purposes of the processing;
– the categories of personal data in question;
– the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if they are recipients of third countries or international organizations;
– when possible, the retention period of the personal data envisaged or, if not possible, the criteria used to determine this period;
– the existence of the right of the interested party to ask the data controller to correct or delete personal data or limit the processing of personal data concerning him or to oppose their treatment;
– the right to lodge a complaint with a supervisory authority;
– if the data are not collected from the interested party, all available information on their origin;
– the existence of an automated decision-making process, including the profiling referred to in Article 22, paragraphs 1 and 4, and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the interested party.
If personal data are transferred to a third country or to an international organization, the interested party has the right to be informed of the existence of adequate guarantees pursuant to Article 46 relating to the transfer.
The Data Controller provides a copy of the personal data being processed, and if the interested party requests further copies, he / she may charge a reasonable fee based on administrative costs.
The interested party also has the right to obtain the correction of inaccurate personal data concerning him without undue delay, and taking into account the purposes of the processing, the interested party has the right to obtain the integration of incomplete personal data, including by providing an additional declaration.
The data subject has the right to obtain from the data controller the cancellation of personal data concerning him without undue delay and the data controller is obliged to cancel the personal data without undue delay, if one of the following reasons exists:
a) the personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;
b) the interested party revokes the consent and if there is no other legal basis for the processing (by way of example, a legal obligation);
c) the interested party opposes the processing and there is no legitimate overriding reason to proceed with the processing (by way of example, a legal obligation);
d) the personal data have been unlawfully processed;
e) the personal data must be deleted to fulfill a legal obligation under the law of the Union or of the Member State to which the data controller is subject;
f) the personal data have been collected in relation to the offer of information society services;
If the Data Controller has made personal data public and is obliged to delete them, taking into account the available technology and the implementation costs, it adopts reasonable measures, including technical ones, to inform the data controllers that they are processing personal data of the request of the interested in deleting any link, copy or reproduction of his personal data.
The interested party has the right to obtain from the data controller the limitation of the processing when one of the following hypotheses occurs:
a) the data subject disputes the accuracy of the personal data, for the period necessary for the data controller to verify the accuracy of such personal data;
b) the processing is unlawful, the interested party opposes the cancellation of personal data and requests that its use be limited;
c) although the data controller no longer needs them for processing purposes, the personal data are necessary for the data subject to ascertain, exercise or defend a right in court;
d) the interested party opposed the processing pursuant to article 21, paragraph 1, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party.
If the processing is limited, such personal data are processed, except for storage, only with the consent of the interested party or for the ascertainment, exercise or defense of a right in court or to protect the rights of a other natural or legal person or for reasons of significant public interest of the Union or of a Member State.
The request for the exercise of the rights of the interested party can be made by sending an email to the address below.

Owner and manager of data processing – Contact methods
In order to carry out the commissioned services, the principal is the Data Controller, EURO EXECUTIVE srl is the Data Processing Manager.
For economic and administrative relations with the principal, owner and data processor is EURO EXECUTIVE srl, based in Padua, Via D. TURAZZA 48 int. 32, and can be reached by e-mail at the following address: privacy@euroexecutive.it, or at the telephone number (+39) 049 8076988 – fax (+39) 049 8076990.

Dissemination and availability of the information note
This information note is made available through:
– the company website: www.euroexecutive.it;
– delivery and acceptance at the time of data collection;
– the general conditions of sale, where provided.