Privacy Policy

Information notice on personal data processing

Art. 13 of Regulation (EU) 2016/679 – GDPR

 

1) DEFINITIONS

(1) ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’);

(2) ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

(3) ‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;

(4) ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

(5) ‘recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not;

(6) ‘consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

(7) ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

 

2)  DATA CONTROLLER

1. The controller of the data that concerns you has appointed, as Data Processor, Professional Relo Srl, with its registered office in via Torri Bianche 3, Palazzo Larice, piano 4, 20871 Vimercate (MB), Italy.
2. For any request concerning the processing of your personal data, please contact Mr. Damian Aebischer at email: Privacy@professionalrelo.com

 

3) PURPOSES AND COMPULSORINESS OF DATA PROCESSING

1. Such personal data as you will provide will be processed for one or both of the following purposes:
   1. Immigration procedures, including, without limitation: application for, and issuance of, work permits; application for, and issuance of, residence permits; registration with local municipalities of residence; application for, and issuance of, residence certificates; registration with the national health service; application for, and issuance of, tax codes.
      The processing of such data  is mandatory for the execution of the contractual obligations and the refusal will make it impossible to perform the service.
   2. Destination procedures, including, without limitation: finding homes and schools; entering into leases; utility hook-up.
      The processing of such data  is mandatory for the execution of the contractual obligations and the refusal will make it impossible to perform the service.
2. The processing of such data as you will provide may also concern personal data which are treated as so-called “special categories” of personal data under article 9 of GDPR – that is, data revealing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union type as well as personal data revealing the state of health and sex life. Under article 9 of the Regulation, such special categories of personal data may only be processed for the purposes of fulfilling the obligations, and exercising the specific rights, of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject, or for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

 

4) PROCESSING METHODS

1. Personal data processing means any operation or set of operations performed with or without the use of automated processes and applied to personal data or sets of personal data, such as collection, registration, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction. Personal data is processed by the data controller, the data co-controller and the data processors, each performing a specific function, in accordance with such instructions as given by the data controller and the data co-controller.
   In particular, the data will be processed by using, for example, the IT management platform, ReloTracker, with access limited to registered users. If you are interested in receiving more security information about this platform, please send an email to Mr. Damian Aebischer at email: Privacy@professionalrelo.com
2. Such personal data as received by the data controller will not be disseminated in any way. However, such data may be disclosed to data processors, outside consultants, public authorities and, generally speaking, to all the subjects to whom such data shall be disclosed by law or at the discretion of the data controller, for the purposes of the correct and complete performance of the contract relationship.
3. Furthermore, your personal data will be disclosed to institutions and professionals in their capacity as outside data processors, for the purpose of fulfilling such fiscal and/or social security obligations as imposed on the data controller under current provisions.
4. Where Professional Relo S.r.l. needs to further process your personal data for a purpose other than that for which the personal data were collected, Professional Relo S.r.l. shall provide you, prior to further processing, with information on that other purpose and with any relevant further information.

 

5) DATA STORAGE PERIOD

Your data will be stored as long as required to fully perform the assignment given.
At the end of the assignment, or of the professional mandate, your personal data will be stored for a maximum period of 10 years in accordance with law provisions concerning prescription and forfeiture, for the purposes of defence before the court in case of any disputes, and as long as required to fulfil such storage obligations as imposed on the data controller and the data processor under current provisions, especially for but not limited to tax and social security purposes.

Documents containing personal data that will be stored for a maximum period of 10 years are:

• Lease proposal
• Lease contract
• Schedule Of Condition
• TARI (Garbage Removal) cancellation
• Model RLI (Lease Contract Closure)
• Registered return receipts related to internet closures and modem / decoder return;

At the end of the assignment, Professional Relo will store the following documents including, without limitation:

• Work Permit;
• Registration to the National Health Service;
• Immigration Job Contract signed in front of Immigration Authorities;
• Copy of the Model 209 for the Residence Permit request,
• Copy of the residence permit / s;
• Certificates of birth / graduation / marriage.

The retention period of these documents is limited to the term of validity of the same and is exclusively aimed at their renewal. In the event that, at the time of expiry, Professional Relo is not authorized to proceed with the renewals, we will promptly destroy them.

6) RIGHTS OF DATA SUBJECT

Under article 13 and following articles of Regulation (EU) 679/2016, as regards personal data, the controller shall grant the following rights to the data subject:

• the right to request access to personal data;
• the right to request rectification of personal data;
• the right to request erasure of personal data;
• the right to request restriction of processing concerning the data subject;
• the right to object to processing;
• the right to data portability;
• the right to lodge a complaint with a supervisory authority.