As expressly indicated in art. 4 paragraph 1 letter a) of the Privacy Code, data processing means "any operation or set of operations, carried out without the aid of electronic instruments, concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction of data, even if not registered in a database".
The data processor is Epic SIM SpA (hereinafter "Epic") with registered office in Milan (20123 - MI), Piazza Cadorna 6 and with headquarters in Milan (20121 - MI), Foro Buonaparte 12.
People in charge of the processing
Epic is responsible for processing the data for the purposes set in this notice. The data provided will be treated, for the purposes specified in section 4 below, from employees and partners of Epic in charge of the processing. The data provided will be processed by third parties responsible to perform data processing operations on behalf of Epic, and specifically appointed for this purpose, for example:
- companies whose activities are related to sending communications to customers, both in paper and electronic formats;
- companies that provide storage of documentation;
- companies whose activities are related to the evaluation of the quality of the services provided, customer satisfaction, or similar services carried out on behalf of Epic;
- companies that perform services related to the provision, measurement and optimization of websites and communication campaigns carried out through the Internet or other offline channels;
The list of those responsible and in charge of data processing is constantly updated and can be requested by sending a notice as indicate in the related paragraph.
Data transfer abroad
The data provided may be transferred outside of the national territory in compliance with the purposes of paragraph 4 to companies belonging to the categories listed in paragraph 6, registered in countries outside of the European Union.
Aims of the treatment
The data collected will be processed by Epic, even without the explicit consent pursuant to Article 24, paragraph 1, letter b) of the Privacy Code, exclusively for the purposes described below:
- allow access and usage of the reserved area of the website and of the services therein available to users;
- respond to user's requests for information;
- respond to customer's comments and messages;
- generally fulfill legal obligations;
- only if you have given your specific consent for this purpose, where required by law, for commercial purposes, for example in order to inform you of any further initiatives that might be of your interest or to perform market research.
Epic will not proceed to the collection or the processing of sensitive information (eg. membership in trade unions, political parties or other associations, health-related data).
Provision of data
We inform that you are free to give your personal data for the purposes mentioned above or not to. However, it is our obligation to inform you that your refusal to do so will make the purposes set out in paragraph 4 and the provision of the services and information you requested unachievable.
Categories of individuals to whom the data may be disclosed
The information you provide may be disclosed for the purposes described in section 4, to the following subjects:
- companies that perform banking, financial and insurance services with which Epic has entered or will enter into agreements (mainly banking, financial and insurance intermediaries) to execute orders received by you, that is, to provide the services you requested;
- credit rating agencies and intermediaries assessing financial risks;
- companies and professionals working in the real estate appraisal or notarial fields;
- companies managing national and international systems for the control of frauds against banking, financial and insurance intermediaries;
- companies managing payment services, credit cards, etc;
- companies responsible for auditing services;
- companies with which Epic already has or will stipulate agreements or collaborations aiming at receiving goods or services from such companies;
Your data will not be disclosed, made available or given out for consultation in any form to people other than those mentioned in this point or other indeterminate subjects.
Methods of data processing
The data processing will be carried out through manual, computer or electronic devices aimed at storing, managing and transmitting it. Specific security measures are taken to ensure the security and confidentiality of personal data and to protect and prevent their loss, illicit or incorrect use or unauthorized access.
To preserve the data collected, the site is protected by the latest generation systems. In addition, the navigation software prevents access to the Website that are not compliant with its operating specifications. Furthermore, the Website uses the appropriate safety standards for the transmission of certain information.
Rights of the interested parties
Epic, in full compliance with the provisions of Articles 7 and 8 of the Privacy Code, informs you that you have right to:
- know the existence of personal data concerning you, which must be made available to you in an intelligible form;
- know the origin of data concerning you;
- know the purposes and methods of treatment;
- know the logic applied in case of data treatment with electronic instruments;
- know the details of the owner and the managers of the treatment;
- know the individuals or groups to whom personal data may be disclosed;
- update, rectificate or integrate the personal data concerning you;
- the cancellation, transformation into anonymous form or blocking of data concerning you, and whose treatment had not been properly authorized;
- oppose to data processing, for legitimate reasons pertinet to the purpose of the collection;
- oppose to the processing of data provided for commercial purposes and sending of advertising material;
To exercise the rights provided in Article 7 of the Privacy Code just summarized, you can contact the responsible for data processing in Epic following what prescribed by Article 9 of the same code. In particular, you may send a notice to Epic, Foro Buonaparte 12, 20121 Milan, Italy, or, you can send an email to email@example.com
To oppose to the sending of advertising material, send an email to firstname.lastname@example.org with subject NO NEWS at any time.