Information on the processing of personal data

(according to EU regulation 2016/679)


25 MAY 2018



(pursuant to Regulation (EU) 2016/679)


The undersigned GARBIN GIUSEPPE, BILATO ALESSANDRO and PADOAN MATTEO, in their capacity as Data Controllers of the company ESSEGI SYSTEM SERVICE SRL, with registered office in VIA ZAMBON, 14/16 - 36051 CREAZZO (VI), inform you pursuant to art. 13 of Regulation (EU) no. 2016/679 (hereafter “GDPR”) that your personal data shall be processed for the following purposes: 


1. Subject of the Processing

The Data Controllers process identifying personal data, (for example, name, surname, company name, address, telephone number, email address, bank and payment details) - hereinafter, "personal data" or also "data") that you have provided when concluding contracts or orders for the services of the Data Controllers.


2. Purpose of the processing  

Your personal data are processed:

  1. Without the need for express consent (art. 24 lett. a) b) c) of the Personal Data Protection Code and art. 6 lett. b), e) GDPR), for the following Service Purposes: 
  • to conclude contracts for the services provided by the Data Controllers;
  • to fulfil any pre-contractual, contractual and tax obligations arising from current relations with you;
  • to fulfil the obligations established by law, by a regulation, by EU legislation or by an order of the Authority (such as for anti-money laundering purposes);
  • to exercise the rights of the Data Controllers, for example the right of defence in court;


  1. Only following your specific and distinct consent (articles 23 and 130 of the Personal Data Protection Code and art. 7 of GDPR) for the following Marketing Purposes: 
  • to send via email, mail and/or sms and/or telephone contacts, newsletters, commercial communications and/or advertising material on products or services provided by the Data Controllers and surveys on the degree of satisfaction regarding the quality of the services;
  • to send via email, mail and/or sms and/or telephone contacts, commercial and/or promotional communications of third-parties.

Please note that if you are already a customer, we may send you commercial communications relating to services and products of the Data Controllers, similar to those you have already used, subject to your lack of consent (Article 130 par.4 PDPC).


3. Processing methods

Processing of your personal data consists in the operations or group of operations indicated in art. 4 of the PDPC and art. 4 no. 2 of the GDPR more precisely: the collection, registration, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, erasure and destruction of data. Your personal data are processed using both paper and electronic and/or automated means.

The Data Controllers shall retain the Personal Data for the time necessary to fulfil the aforementioned purposes and, in any case, for no more than 10 years from the termination of relations for Service purposes, and for no more than 2 years from the collection of data for Marketing purposes.


4. Access to data

Your Data may be made accessible for the purposes indicated in arts. 2.A) and 2.B):

  • to employees and collaborators of the Data Controllers in their capacity as persons assigned to the processing and/or in charge of the processing and/or system administrators; 


5. Disclosure of personal data

Without the need for express consent (pursuant to Art. 24 letter a), b), d) of the PDPC and art. 6 lett. b) and c) GDPR) the Data Controllers is authorised to disclose your Data for the purposes indicated in art. 2.A) to Supervisory Bodies (such as IVASS), Judicial Authorities, to insurance companies for the provision of insurance services, in addition to all subjects to whom such disclosure and communication is mandatory by law in order to fulfil said purposes. These subjects shall process the data in their capacity as independent data controllers.

Your personal data shall not be disseminated.


6. Transfers of Personal data 

Personal data are stored on servers located: at the registered office in Via Zambon, 14/16 Creazzo (VI), within the European Union, and at the Microsoft Corporation offices, outside the European Union (contract stipulated with the company Microsoft Ireland Operations Ltd, VAT no.: IE8256796U).

It remains understood that the Data Controllers, as and where necessary, shall have the right to move the servers again, also outside the EU. In this case, the Data Controllers hereby guarantee that the transfer of data to non-EU locations shall take place in accordance with the applicable laws in force, following the stipulation of the standard contractual clauses provided by the European Commission.


7. Nature of the collection of data and consequences of refusing to reply

Collection of personal data for the purposes indicated in art. 2.A) is mandatory. Without such data we can not guarantee the Services indicated in art.2.A).

Collection of personal data for the purposes indicated in art. 2.B) is however optional. You can therefore decide not to consent to the collection of any data or to subsequently withdraw your consent to process data already provided: in this case, you will not receive newsletters, commercial communications and advertising material concerning the Services provided by the Data Controllers. However, you will continue to be entitled to the Services referred to in art. 2.A).


8. Rights of the data subject

In your capacity as the Data Subject, you are granted the rights foreseen by Art. 7 of the PDPC and art. 15 GDPR and, more specifically the rights to:

  1. obtain confirmation as to whether or not personal data concerning you exists, regardless of their being already recorded, and communication of such data in an intelligible form;
  2. obtain indications on:
  1. the source of the personal data;
  2. the purpose and processing methods;
  3. the logic applied to processing if the same is carried out with the use of electronic means;
  4. the personal data of the Data Controllers, the persons in charge and the designated representatives pursuant to art.  5, par. 2 of the PDPC and art. 3 par. 1 of GDPR;
  5. the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of such data in their capacity as designated representatives for the Country, or persons in charge or assigned to such processing activities; 
  1. to obtain:
  1. updating, rectification or, where interested therein, integration of the data;
  2. erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is necessary for the purpose for which they were collected or subsequently processed;
  3. certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected; 
  1. to object, totally or partially to:
  1. for legitimate reasons, the processing of one’s personal data, despite them being relevant to the purpose of the collection;
  2. the processing of your personal data for the distribution of advertising materials or direct sales or for market research or business communication; using automated calling or call communication means without the intervention of an operator by email and/or traditional marketing methods by telephone and/or mailing of printed media. Please note that the data subject's right to object, as illustrated in point b) above, for direct marketing purposes by means of automated methods, also extends to traditional methods and, in any case, the data subject retains the possibility to exercise the right to object, either totally or partially. Therefore, the data subject can decide to only receive communications using traditional methods or only automated communications or neither of the two types of communication.

Where applicable, the data subject also has the rights referred to in articles 16-21 GDPR (Right of rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to lodge claims with the Supervisory Authority.


9. Cookie Policy

This Application uses Cookies.

Technical and aggregated statistic cookies

Activities strictly necessary for functioning aspects

This Application uses cookies to save the User's browsing session and to perform other activities strictly necessary for the functionality of this Application, for instance, in relation to the distribution of traffic.

Activities regarding the saving of preferences, optimisation and statistics

This Application uses cookies to save browsing preferences and optimise the user's browsing experience. These Cookies include, for instance, those for setting the language and currency or for the management of statistics by the website Data Controller.

Other types of cookies or third-party tools that could install them

Some of the services listed below collect statistics in an aggregated and anonymous form and may not require the consent of the User or they could be managed directly by the Data Controller - depending on the description - without the support of third parties.

If any of the tools indicated below include services managed by third parties, these could - in addition to what is specified and also without the knowledge of the Data Controller - perform User tracking activities. We recommend users consult the privacy policy of the services listed for further information on the same.


The services contained in this section allow the Data Controller to monitor and analyse traffic data and are used to track User behaviour.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the collected Personal Data for the purpose of tracking and examining the use of this Application, generating reports and sharing them with other services developed by Google.

Google may use the Personal Data to contextualise and personalise the adverts on its own advertising network.

Personal Data collected: Cookies and User data.

Processing location: S – Privacy Policy – Opt Out. Subject that has joined the Privacy Shield.

How can I express consent to the installation of Cookies?

In addition to the instructions provided in this document, the User can manage Cookie preferences and settings directly in the browser and prevent - for example - third parties from installing them. The browser settings can also be used to delete the Cookies installed in the past, including the Cookie in which the consent to the installation of cookies by this site is saved. The User can find information on how to manage Cookies on some of the most popular browsers, for instance at the following addresses: Google ChromeMozilla FirefoxApple Safari and Microsoft Internet Explorer.

As regards to Cookies installed by third parties, the User can also manage such settings and revoke the consent by clicking the relative opt out link (if available), using the tools described in the third party's privacy policy or by contacting the same directly.

Notwithstanding the foregoing, the User can consult all the information provided byEDAA (EU), Network Advertising Initiative (USA) and Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. These services can be used to manage tracking preferences of most advertising tools. The Data Controller, therefore, strongly advises Users to use these resources in addition to the information provided in this document.


10. Exercising of rights

You may exercise your rights at any moment in time by sending: 

- a registered letter with advice of receipt to ESSEGI SYSTEM SERVICE srl, VIA ZAMBON, 14/16 - 36051 CREAZZO (VI) - ITALY;

- an email to


11. Data Controller, Data Processor and designated processing officers

The Data Controllers are GARBIN GIUSEPPE, BILATO ALESSANDRO and PADOAN MATTEO with legal and operational headquarters in VIA ZAMBON, 14/16, CREAZZO (VI). 

The updated list of the Data Processors and designated processing officers shall be filed and retained by the Data Controllers.



The Data Controllers




Require informations

Information pursuant to art. 13 Regulation (EU) 679/2016. The data provided with the completion of this information request form will be processed and printed. Your data will be used exclusively to respond to your specific requests. Your data will not be communicated or disclosed to third parties. The data controller is TouchMultimedia S.r.l. to which you can apply for the exercise of rights under Article 15 of Regulation (EU) 679/2016. To view the complete information, refer to the privacy page.

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