Pursuant to Article 13 of General Data Protection Regulation 2016/679 dated 27/04/2016, hereafter referred as GDPR ( General Data Protection Regulation ), TRENDCOLOR SRL . , with registered office in Via Crocefisso , 8 (MI) (Italy), informs customers and suppliers (simply the ‘concern to) about the following:

• Data controller

 The holder of the data processing is TRENDCOLOR SRL P.IVA. 03958870960 in the figure of his Legal Representative pro tempore – called the “Owner” from now on – with registered office in Viale Crocefisso, 8 Milan (Italy) .

1. Purpose, lawfulness, legal basis and mandatory or optional nature of the processing

Personal Data collected through the relationship between TRENDCOLOR SRL. and the interested party will be processed by TRENDCOLOR SRL . for the following purposes:

1. Purposes relating to the performance of a contract or the provision of a service of which the data subject is either an integrant party or final recipient of the service or the execution of pre-contractual measures taken at his request;
2. Purposes of internal statistical research / analysis within the company on aggregate or anonymous data, without the possibility to identify the user in the figure of his person, aimed to evaluate the functioning of the production process of TRENDCOLOR SRL. , measure traffic and evaluate  production flows;
3. Purposes related to the fulfilment of a legal obligation to which TRENDCOLORSRL. is subject to;
4. Purposes necessary to establish, exercise or defend a right in court or whenever the jurisdictional authorities exercise their jurisdictional duties;

The legal basis for the processing of Personal Data for purposes in point A) is the provision of a service or the reply to a request that does not require consent under the Applicable Regulations.

Purposes in point B) does not involve the treatment of Personal Data, while purposes in point D) represents a legitimate interest treatment Holder’s Personal Data under the Regulations Applicable in that, once the data conferred Personal, the treatment is indeed necessary to fulfil a legal obligation to which TRENDCOLOR SRL. is subject to.

The provision of Personal Data for purposes listed above is mandatory, since their eventual non-conferment would make it impossible to find a request or fulfil a legal and / or contractual obligation to which TRENDCOLOR SRL is subject to the person concerned.

• Recipients and managers external to treatment

Personal Data may be shared, for the purposes specified in point C) of the previous paragraph, with:

1. Subjects required for the provision of the services offered by TRENDCOLOR SRL. including, for example, the sending of e-mails and  he analysis of the operation of the business processes that typically act as in charge for the treatment of TRENDCOLOR SRL .
2. Persons authorized by TRENDCOLOR SRL. to the processing of Personal Data that are committed to confidentiality or have an appropriate legal obligation of confidentiality; (for example, the employees and collaborators of TRENDCOLOR SRL . ;
3. Jurisdictional authorities in the exercise of their functions when required by the Applicable Regulations

• Communication and Diffusion

The personal data of the interested party may be communicated, within the limits strictly relevant to the obligations, accordingly to the purposes reported in paragraph II and paragraph III and in compliance with current legislation on the subject, to the following categories of subjects:

1. Subjects to whom this communication must be made in order to fulfil or to demand the fulfilment of specific obligations provided by laws, regulations and / or Community legislation;
2. Companies belonging to the Group of the Holder or controlling, controlled or connected pursuant to Art. 2359 Cod.Civ. , acting as data controllers or for administrative and accounting purposes (purposes related to the performance of internal, administrative, financial and accounting activities, in particular, functional to the fulfilment of contractual and pre-contractual obligations);
3. External physical and / or legal persons providing services that are instrumental to the activities of the Owner for the purposes referred to in point A above . (eg suppliers, consultants, companies, institutions, professional offices). These subjects will act as data controllers, or independent data controllers.

Personal data will not be subject to diffusion in any way .

The interested party has the right to request TRENDCOLOR SRL. the list of those responsible outside the treatment and the list of system administrators , where there is an interested and legitimate interest on the part of the interested party.

• Data processing methods

The processing of personal data is carried out by means of the operations indicated in art. 4 n. 2) GDPR , for the aforementioned purposes, both on paper and computerized media, by means of electronic or automated tools, in compliance with the regulations in force in particular on privacy and security and in compliance with the principles of correctness, lawfulness and transparency ; protection of the rights of the data subject .

The processing is carried out directly by the owner’s organization, by its managers and / or agents.

• Period of retention of personal data

The personal data will be kept for the entire duration expressed by the contract stipulated with the owner concluded that the data will be kept for the fulfilment of the terms established by law for the conservation of the administrative documents therein, after which they will be deleted or stored in anonymous form no more attributable to a natural person.

• Security measures

– IT, administrative and documental technical measures

 The security measures have been subject to compliance audits on security and cyber-security in the comparison of possible cyber attacks. The same are periodically subject to auditing and conformity audits by technicians specialized in computer security, legal and social security. The result is as follows:

1. Software and databases used comply with the principles of data protection and cyber security
2. Corporate network is protected by firewall
3. An antispam and antivirus system is present
4. System administrators are identified
5. Authorized users are identified
6. The processing and the organizational / technical choices regarding the security of personal data involve the Data Protection Officer
7. Vulnerability tests of information systems and network infrastructure are performed and planned
8. Procedure for managing IT emergencies is present
9. There is a Data-Breach management procedure
10. Automated and structured backup system for data recovery is present

• Data retention and non-EU transfer

Personal data is stored on servers located within the European Union. It is understood that the owner, for any administrative, managerial or for any other nature needs, can move servers even in non-EU territory, the same will be done after concluding the standard contractual clauses of the Commission Europe to and not before to have informed the interested ones by means of a new consent to the treatment .

• Rights of the interested party and how to exercise the rights

In quality of an identified and / or identifiable natural person, the interested party has the rights reported in articles 15, 16, 17, 18, 19, 20, 21 GDPR and precisely the rights of:

1. Transparency;
2. Informative;
3. Access;
4. Correction;
5. Oblivion;
6. Treatment limitation;
7. Data portability;
8. Opposition to Treatment.

It remains that the interested party has to promptly communicate to the Holder any corrections, additions and / or updates to your data.

For the exercise of the rights in art. 15 and following indicated in the IX paragraph of this information and the GDPR or for questions or information regarding the processing of your data and the security measures adopted, may in any case forward the request to our company to the following address:

Massimiliano Testa c / o Trendcolor Srl

Telephone: +39 02 9901151

E-mail : info@trendcolor.it

Pec: trendcolor@pec.trendcolor.it