Executive Services Business Centres srl is a company that offers business services to anyone making a specific request: furnished offices, meeting rooms and offices rented by the day, domiciliation and registered offices, secretarial services for third parties, translations and interpreting.
Personal data are gathered directly by Executive Services Business Centres srl, or purchased from economic operators who establish databanks and archives for economic or marketing purposes or are retrieved from public registers or lists of public domain (e.g. Kompass-Seat Pagine Gialle, Guida Monaci).
Aim of processing:
The databanks are established for the purpose of commercial information, the sending of advertising material and commercial communications.
The managed databanks :
Further to the stipulation of an e-mail marketing contract, the company Executive Services Business Centres srl, based on specifications set out by the client, extracts the necessary data for the purpose of setting up a databank for the client from its own databank(s). The contract foresees the co-ownership of the process between Executive Services Business Centres srl and the commissioning client.
Information for the interested party: art. 13 of the Privacy Code (Leg. Dec. 196/2003)
The information herein constitutes the main fulfilment to protect the interested party, as it is aimed at
- making known the aims and modes of the processing carried out;
- guaranteeing the obligation of providing the data;
- Describing the categories of subjects to whom the data is provided, or the context of their diffusion;
- guaranteeing the right to exercise rights, that legislation acknowledges to the interested party for his/her own data.
The information states the subject who owns the processing: in our case, as stated, joint ownership of the processing is between Executive Services Business Centres srl and the commissioning client, who jointly determine the purposes and modes for processing the data for the purpose of sending commercial communications.
Consent for processing of data - art. 23 and 24 Privacy Code
The privacy code provides for the obligation of acquiring prior consent from the interested party in order to be able to process his/her personal data.
Consent must be expressed:
- In a specific form;
- Documented in writing.
Consent is effectively provided if preceded by the information sheet.
The obligation of consent is excluded in the event that the processing concerns:
- Data coming from public registers, lists, deeds or documents that can be consulted by anyone;
- Data referring to the carrying out of economic activities.
Consent to the sending of emails
Article 130 of the new Privacy Code (Leg. Dec 196/2003), foresees the obligation of acquiring prior consent from the interested party (both for activities aimed at the final consumer – B2C – and for activities aimed at companies – B2B), for the sending of advertising messages or commercial communications using email.
Gathering data may take place:
- Directly, by entering the information into our online forms;
- Subscribing to our newsletters or mailing lists;
- At third parties, via acquisition of information from lists and databanks from personal data suppliers (e.g. Kompass-Seat pagine Gialle, Guida Monaci).
The information sheets for the interested parties that we draw up are provided:
- At the bottom of our online forms;
- On subscribing to our newsletters or mailing lists;
- By sending a first email for the data collected from third parties which can be followed by the interested party’s consent on receiving the commercial communications, or by the request to oppose or remove the processed data.
Executive Services Business Centres srl requires consent for the following from the interested parties:
- Processing of data (where requested);
- The use of email for marketing purposes.
Executive Services Business Centres srl guarantees that it has obtained:
- Consent for the data acquired via the forms available on the web;
- Consent for the data acquired via newsletters or mailing lists;
- Suitable guarantees from our data suppliers.
Recipients who don’t wish to continue receiving promotional messages from Executive Services Business Centres srl and its client can exercise their right to oppose processing of the data and receiving promotional messages by email, asking for their own information to be cancelled, by writing to the address firstname.lastname@example.org.
At any time, the interested party can request, pursuant to article 7 of the Privacy Code:
- Origin of own data;
- Information about the purposes and modes of processing;
- Removal of their data from the Executive Services Business Centres srl client list;
- Removal of their data from the Executive Services Business Centres srl data bank.