Newsletter Policy

PRIVACY POLICY - Information document pursuant to Article 13 of EU Reg. 2016/679 (GDPR) - Notice concerning processing of personal data collected from the data subject
In compliance with the provisions of EU Reg. 2016/679 (European General Data Protection Regulation (link to: https://eur-lex.europa.eu/legal-content/IT/TXT/HTML/?uri=CELEX:32016R0679&from=IT)]), we are duly informing you about the processing of your personal details supplied. This notice does not apply to any other website you can visit by clicking on the links on the Internet sites of the data controller, since it is not responsible in any way for the Internet sites of others. 
This notice is provided in accordance with Art. 13 of EU Reg. 2016/679 (European General Data Protection Regulation) and is also inspired by the provisions of Directive 2002/58/EC, as updated by Directive 2009/136/EC (https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:337:0011:0036:it:PDF), concerning cookies and the Measures of the Data Protection Authority of 08 May 2014 concerning cookies.
Personal data which may be processed: “personal data”: any information regarding an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; (C26, C27, C30).
Specific notices
Specific notices could be printed on Website pages in relation to particular services or processing of the Data supplied.
Cookies
For more information on the cookies utilised by this website, please read the cookie policy at this link

1. In accordance with Articles 4 and 24 of EU Reg. 2016/679, the DATA CONTROLLER is TRADE PROMOTIONS S.r.l. a socio unico, Via Venezia 85, 35010 Vigonza (PD) with VAT No. and Tax code 04582970283,  info@womsh.com in the person of its legal representative pro tempore.


2. PURPOSES AND LEGAL BASIS FOR PROCESSING
Details supplied about natural persons shall be processed in compliance with the conditions of lawfulness pursuant to Art. 6 of EU Reg. 2016/679, for the following purposes:
- with your consent until you object to processing: for direct marketing activities of the Data Controller, newsletters about products or other information about our services, market research or other sample research and direct sales for receiving - via automated e-mail messages, fax, MMS or SMS messages or other type of message, and by telephone with operator and the post - informative material for conducting customer satisfaction survey, for sending promotional, commercial and advertising material or material concerning events and initiatives of the Data Controller – consent (Art. 6, paragraph 1, letter a)) as the legal basis for processing.
3. RECIPIENTS OR CATEGORIES OF RECIPIENTS OF YOUR DATA
Your personal data supplied shall be disclosed to recipients, who shall process your data as processors (Art. 28 of EU Reg. 2016/679) and/or as natural persons acting under the authority of the Data Controller and Processor (Art. 29 of EU Reg. 2016/679), for the purposed listed in point 2. Precisely, your data shall be disclosed to:
- persons who provide information systems management services used by TRADE PROMOTIONS S.r.l. a socio unico and telecommunications networks; - self-employed professionals, offices or companies for performance of assistance and consulting services; - persons who provide information systems management services used by TRADE PROMOTIONS S.r.l. a socio unico and telecommunications networks, including e-mail, newsletters and Internet site management; - third parties who collaborate with the Data Controller for direct marketing activities; - the authorities for fulfilment of obligations of law and/or provisions of public organs, when requested. Persons belonging to the above categories act as Processor of your data, or work independently as separate Data Controllers. The list of Processors is constantly updated and can be obtained by writing to info@womsh.com or at the registered office of TRADE PROMOTIONS S.r.l. a socio unico.
4. STORAGE PERIOD OF YOUR DATA AND CRITERIA FOR DETERMINING THE PERIOD
Processing shall be carried out in an automated manner and manually, with procedures and instruments for ensuring utmost security and privacy by duly appointed persons.
In compliance with the provisions of Art. 5, paragraph 1, letter e) of EU Reg. 2016/679, your personal data collected shall be stored in a form allowing for identification of the data subjects for a length of time not exceeding achievement of the purposes for which they were processed. Storage of data of natural persons depends on the purpose of processing:
- for receipt of newsletters or promotional communications in general by e-mail (at most 24 months). The time is determined based on criteria the data subject can obtain information about by writing to info@womsh.com at the registered office of the Data Controller.

5. NATURE OF PROVISION OF DATA OR REFUSAL
Apart from what is specified for browsing data, you are free to provide your personal information. Providing your data is either optional or necessary, depending on the purpose for which they are processed. Not providing data marked with an asterisk * shall make it impossible to obtain what you requested or use the services of the data controller.
6. RIGHTS OF DATA SUBJECTS
You can exercise your rights as granted by Articles 15, 16, 17, 18, 19, 20, 21, 22 of EU Regulation 2016/679, by contacting the Data Controller, or the Data Processor at this address info@womsh.com. You have the right at all times to ask the Data Controller for access to your personal data, rectification, erasure of the same and to restrict processing. In addition, you have the right to object at any time to processing of your data (including automated processing, such as profiling), and the right to portability of your data.  Without prejudice to additional administrative or jurisdictional petitions, if you believe your data have been processed against the provisions of EU Reg. 2016/679, according to Art. 15, letter f) of the aforesaid EU Reg. 2016/679, you have the right to lodge a complaint with the Data Protection Authority and with reference to Art. 6, paragraph 1, letter a) and Art. 9, paragraph 2, letter a), you have the right to withdraw the consent given at any time. If you ask for data portability, the Data Controller will provide your personal data to you in a structured form commonly used and legible by an automatic device, without prejudice to paragraphs 3 and 4 of Art. 20 of EU Reg. 679/2016.
 
Date of update 13 March 2019