Privacy Policy

Safeguarding your Privacy is one of our main objectives!

This document will allow you to learn about our privacy policy to understand how your personal information is managed when you use our services and to allow you to give your express, informed consent, if necessary, for the processing of your personal data in the website sections where you are asked to provide personal data. We would like to remind you that various sections of our website (hereinafter referred to as “Site”) in which we collect your personal data contain specific information pursuant to 13 of EU Regulation 2016/679 (hereinafter: “Regulation”) which you must read and accept before providing the requested data. The information and data you have provided or otherwise acquired when registering for the various services (such as, for example: request for information, consultancy, subscription to the newsletter, online and offline marketing and communication activities, participation in events, press office and PR activities, sales communications, etc, together referred to hereinafter as: “Services“), will be processed in observance of the provisions contained in the Regulation and the confidentiality obligations that inspire our business. Pursuant to the General Data Protection Regulation – EU Regulation 2016/679, information about you will be processed on the basis of the principles of legality, correctness, transparency, restriction of purpose and storage, minimisation of data, exactness, integrity and confidentiality. Hidde Heydendael (Data Controller) pursuant to article 13 of the General Data Protection Regulation – EU Regulation 2016/679 is providing you with the information below regarding the processing of your personal information provided to use the services offered by the data controller and by the website https://www.seasonspercussion.com/ and all its sub-domains (hereinafter referred to as the Site).

A) Purpose of data processing:

Pursuant to and in accordance with the Regulation, collected personal data will be processed via automated filing in the information system by the data controller for the purposes connected with the data controller’s data processing activities and for services: 1.1. to assist you in using the services and, generally, for service management; 1.2. to send you communications about the ways to use the services; 1.3. to send you commercial communications about the data controller’s activities; 1.4. To send you commercial communications about other subjects’ activities, only further to your express consent. If such consent is not sent, it is understood to be NOT provided.

B) Mandatory or optional nature of providing data and consequences to refusing data

The legal basis of processing Personal Data for the purposes set out in section 3 (a-b-c) is article 6(1)(b) of the Regulation as processing is necessary for the provision of contracted services. Providing Personal Data for these purposes is optional but if not provided will make it impossible to activate the services requested. The purposes as per section 3(d) is the legitimate processing of Personal Data pursuant to article 6(1)(c) of the Regulation. Once Personal Data has been provided, processing may be necessary to fulfil legal obligations. Therefore, providing data is optional, but any refusal may mean it is impossible to access the services offered by this website.

C) Parties to which data may be communicated – realm of data diffusion

The personal data that you have provided may be communicated solely to: 4.1. affiliated or subsidiary companies that are part of our group, for the pursuit of the same purposes for which the data was collected; 4.2. public or private bodies for the fulfilment of obligations provided for in by-laws, the law or EU legislation; 4.3. some of your personal data may be shared with Recipients who may be outside the European Economic Area. We assure you that the processing of your Personal Data by these Recipients will take place in full observance of the Regulation. Transfers can be based on a decision of adequacy or on the Standard Contractual Clauses approved by the European Commission. More information is available from the Data Controller.

D) The Data Subject’s Rights pursuant to article 15, 18, 20, 77 of the Regulation

5.1. the right to obtain confirmation of the existence or non-existence of personal data concerning themselves, even if not yet recorded, and for it to be communicated in an intelligible form.

5.2 the right to obtain an indication of the origin of said personal data (article 15), of processing purposes and methods, of logic applied in the event of processing using electronic tools, of the data controller’s identification, of the processors and the appointed representative, of the subjects or categories of subjects to whom personal data may be communicated or that may learn about said personal data as the appointed representative in the State territory, of managers or appointees.

5.3 the right to obtain the updating, rectification or integration of data, and also cancellation, transformation to anonymous format or blocking of data processed in violation of the law, including data that is not required to be stored in relation to the purposes for which said data was collected or later processed;

5.4 the right to object to processing of personal data concerning him/herself for the purpose of sending advertising or sales materials directly or for market research purposes or for commercial communication.

5.5. The right to lodge a complaint with the regulation authorities (Data Protection Authority), pursuant to article 77 of the Regulations, if you believe that you data is being processed contrary to current legislation.

5.6. the right to ask the data controller for access to your personal data at any time, or for it to be rectified or removed, or to object to it being processed, you have the right to request the restriction of processing in the cases provided for in article 18 of the Regulation, and to obtain a structured, commonly used format of your data that is also legible for an automatic device, in the cases provided for in article 20 of the Regulation.

E) Legal basis of processing

We inform site users that the legal basis of data processing is the Italian nation (part of the European Community);

F) Storage period for data

Personal Data will be stored for the time strictly necessary to achieve the same purposes. In all cases, as data is processed to provide Services, we will process Personal Data up to the time permitted by Italian legislation for the protection of its own interests (Art. 2946 Civil Code and following).

Personal Data processed for the purposes listed in section A will be stored until the time foreseen by the specific obligations or applicable law. For example, as already specified, traffic data will be storied for judicial purposes for seven years from their creation; otherwise data will be stored for 3 years.

Your Personal Data will be used for information purposes (section A.1.3) until your consent is withdrawn or up to three years after you have ceased to be our customer, or simply registered on the Site, and have not purchased any products or services. Notwithstanding the possibility for us to store you Personal Data until the time limit foreseen by Italian law to protect our interests (Art. 2947(1)(3) c.c.). More information about the data storage period and criteria used to determine said period can be requested by writing to the Data protection Controller.

G) Titolare del trattamento e responsabile

The Data Controller is Hidde Heydendael, Via Pagliucola, 27 — 51100 Pistoia PT — tel. 0039 334 1347327 — email: hiddehey@gmail.com

H) Amendments

This privacy policy takes effect from 25 May 2018. We reserve the right to amend or simply update the content, in part or fully, also due to variations in the applicable law. Should the amendments to the herein Policy concern substantial changes to processing or may have an important impact on data subjects, we will suitably notify the data subjects.