Pursuant to Legislative Decree no. 196/2003 and EU Regulation no. 679/2016 (GDPR), and in relation to the personal data that concerns you and will be processed, we inform you as follows.
1. PROCESSED PERSONAL DATA, PURPOSES, AND LEGAL BASIS OF PROCESSING
The term “Data” refers to the personal data of physical persons processed by TapMyLife S.r.l. for the establishment and execution of the contractual relationship with its clients/suppliers. This includes, for example, data directly referring to the individual client/supplier, or to the legal representative of the corporate client/supplier, the employees/consultants involved in the activities under the contract, as well as any other information necessary for the execution of the contract and/or the provision of the service(s). In particular, the Data will be processed for the purposes indicated below.
A. Management of the contractual/commercial relationship, the purposes include: fulfilling specific requests from the client/supplier before the conclusion of the contract; the conclusion, modification, and execution of the contract; providing and managing related services; handling complaints.
The legal bases for processing data in relation to the aforementioned purposes are:
· Fulfillment of contractual obligations and/or execution of pre-contractual measures taken at the request of the data subject, for contracts directly signed with the data subject;
· Legitimate interest (in managing and executing the contract) for processing data of the employees/consultants of the supplier/client involved in the activities covered by the contract.
B. Administrative and accounting, the purposes include: invoicing; managing payments, delays, and non-payments; communication of the same Data between group companies, for organizational, administrative, financial, and accounting purposes related to the aforementioned activities.
The legal bases for processing data in relation to the aforementioned purposes are:
· The necessity of fulfilling the legal obligation to maintain accounting records;
· Legitimate interest in managing the administrative aspects of the contractual relationship.
C. Fulfillment of legal obligations Required by national law or European Union law, or by collective agreements in accordance with national law, such as the fulfillment of obligations set forth by community and national regulations, particularly concerning health and safety at work, and crime prevention (anti-mafia legislation, anti-corruption, Legislative Decree 231/2001). The legal basis for processing is the necessity of complying with a legal obligation to which the data controller is subject.
D. Exercise and/or defense of rights in judicial proceedings and debt collection, Such as the management of any judicial disputes, protection, and recovery of debts, either directly or through third parties (lawyers/agencies/credit recovery companies). The legal basis for processing is legitimate interest.
2. RETENTION PERIOD
The data will be processed for the duration of the contractual relationship and, after its termination, until the expiration of the limitation period for any claims arising between the parties. In the case of legal disputes, for the entire duration of the proceedings and until the final decision becomes definitive.
3. DATA PROCESSING METHODS
Personal data may be processed with both analog and electronic means or automated systems, with methods and procedures strictly necessary to pursue the purposes outlined above.
4. SCOPE OF DISCLOSURE, AUTHORIZED SUBJECTS FOR DATA PROCESSING
Data may be disclosed to external subjects acting as independent data controllers, such as public or private entities authorized to process Data (e.g., public administrations, banks, credit institutions, accountants, notaries, lawyers, and other professionals). Data may be processed, on behalf of the data controller, by external subjects designated as data processors who perform specific activities on behalf of the data controller, such as its distribution network, credit recovery companies, and legal, fiscal, and administrative consultants. Data may be processed by the employees of the company functions tasked with pursuing the aforementioned purposes, who have been expressly authorized to process the data and have received appropriate operational instructions. Data is not subject to dissemination.
5. PROVISION OF DATA
Failure to provide personal data may result in the partial or total inability to comply with legal obligations or to enter into or execute the contract or service correctly. In such a case, while the data
subject is free not to provide their data, the Data Controller reserves the right to suspend, interrupt, or not establish the contractual relationship.
6. DATA CONTROLLER
The Data Controller is TapMyLife S.r.l., with registered office at 24126 Bergamo, Via Campagnola no. 40, VAT and Tax Code 03985800162, email: privacy@tapmylife.com. The Data Controller may process the data directly, through its authorized employees, or through external collaborators, who act as Data Processors. An updated list of Data Processors is available from the Data Controller upon request.
7. RIGHTS OF THE DATA SUBJECT
The personal data protection regulations (Articles 12-22 of EU Regulation 679/2016) guarantee the data subject the right to be informed about the processing of the Data and the right to access the Data at any time, and to request updates, integration, and rectification. Where applicable, the data subject also has the right to request the deletion of the Data, to limit their processing, to data portability, to object to the processing, and not to be subjected to decisions based solely on automated processing. Where the processing of personal data is based on the consent of the data subject, they have the right to withdraw the consent. For the exercise of their rights, as well as for more detailed information about the processing of Data, the data subject can contact TapMyLife S.r.l. by emailing privacy@tapmylife.com. If the data subject believes their rights have been violated, they may file a complaint with the Italian Data Protection Authority.
8. PROCESSING OF THIRD-PARTY DATA
The client/supplier is informed that if they employ their own employees or collaborators (including subcontractors) to execute the contractual relationship, the personal data of these individuals may be processed by TapMyLife S.r.l., acting as the data controller, for the purposes outlined in point 1. Such processing will follow the same purposes, methods, and data retention periods as described in this notice; data subjects also have the same rights identified in point 7. The client/supplier is required to properly inform their employees and collaborators about such processing, including by providing them with this notice.
