RES S.R.L., with its corporate office at VIALE PIERO E ALBERTO PIRELLI, 6 CAP 20126 – MILANO (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 no. 2016/679 (hereinafter “GDPR”) that your data will be processed in the manner and for the following purposes:

1. Treatment of the object
The Data Controller processes personal, identifying and non-sensitive data (in particular, name, surname, tax code, VAT number, email, telephone number – hereinafter, “personal data” or even “data”) communicated by you during the registration on the website of the owner and/ r when registering for the application services offered by the same portal and by the owner.

2. Treatment purposes
Your personal data is processed:

A) without your express consent (art.24 letter a, b, c Privacy Code and art.6 letter b, and GDPR), for the following service purposes:

– allow you to register on the website;
– manage and maintain the website;
– allow you to subscribe to the newsletter service provided by the Owner and any other Services you may request;
– fulfill the pre-contractual, contractual and tax obligations deriving from any relationships with you in existence;
– fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority;
– prevent or discover fraudulent activities or abuses harmful to the website;
– exercise the rights of the owner, for example the right to defense in court..

B) Only subject to 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 email newsletters, commercial communications and / or advertising material on products or services offered by the Owner
We would like to point out to you that if you are already our customer, we will be able to send you commercial communications relating to the owner’s services and products similar to those you have already used, except for your dissent (art.130 c. 4 of the Privacy Code).

3. Processing methods
The processing of your personal data is carried out by means of the operations indicated in art. 4 Privacy Code and art. 4 no. 2) GDPR and precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electronic and/or automated processing.
The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the Service Purposes relationship and for no more than 2 years from the collection of data for Marketing Purposes..

4. 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 Data Controller or of the RES Group companies to which the Data Controller belongs, in their capacity as persons in charge and/or internal managers of the processing and / or system administrators;
– to RES Group companies to which the Data Controller belongs (for example, for support activities in the study of the feasibility of the customer’s project, for technical project management activities, for the storage of personal data, etc.) or to third parties (for example, provider for the management and maintenance of the website, suppliers, credit institutions, professional firms, etc.) who carry out outsourcing activities on behalf of the Owner, in their capacity as external data processor.

5. Disclosure of data
Without your 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, Judicial Authorities as well as to all other subjects to whom communication is mandatory by law for the fulfillment of the aforementioned purposes. Your information will not be shared.

6. Transferring data 
The management and storage of personal data will take place on servers located within the European Union of the Data Controller and/or third-party companies appointed and duly appointed as Data Processors. The data will not be transferred outside the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the location of the servers to Italy and / or the European Union and/or non-EU countries. In this case, the Data Controller ensures as of now that the transfer of non-EU data will take place in accordance with the applicable legal provisions by stipulating, if necessary, agreements that guarantee an adequate level of protection and / or by adopting the standard contractual clauses provided by the European Commission.

7. Nature of the provision of data and consequences of refusing to respond
The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we will not be able to guarantee you registration on the site or the services of art. 2.A).
The provision of data for the purposes referred to in art. 2.B) is optional. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided.  In this case, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Data Controller.  In any case, you will continue to be entitled to the services referred to in art. 2.A).

8. Rights of the interested party 
In your capacity as an interested party, you have the rights referred to in art. 7 Privacy Code and art. 15 GDPR and precisely the rights of:
i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
ii. obtain the indication: a) of the origin of the personal data; b) the purposes and methods of treatment; c) the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the owner, of the managers and of the representative appointed 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 agents;
iii. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment occurs proves impossible or involves the use of means manifestly disproportionate to the protected right;
iv. 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 the collection; b) to the processing of personal data concerning you for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by email and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition also only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication.
Where applicable, you also have the rights referred to in articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority..

9. How to exercise your rights
You can exercise your rights by sending:

– a registered letter with return receipt to: RES SRL Viale Piero and Alberto Pirelli, 6 20126 – Milan Italy

– an email to info@res-it.com

– a certified email to: res@pec.res-it.com

10. Children
This site and the owners services are not intended for minors under the age of 18 and the owner does not intentionally collect personal information relating to minors. In the event that information on minors were unintentionally registered, the Data Controller will delete them in a timely manner, at the request of the users.

11. Owner, manager and agents
The data controller is RES SRL
The updated list of data processors and appointees is kept at the headquarters of the Data Controller.

12. Modifications to this policy 
This information may change. We therefore recommend that you regularly check this Notice and refer to the most updated version.