Privacy Policy

Processing of Personal Data under Article 13 of Regulation (EU) No. 2016/679

In accordance with Regulation (EU) 679/2016 on data protection (GDPR – General Data Protection Regulation), effective from May 25, 2018, the processing of personal data must always adhere to the principles of fairness, lawfulness, transparency, and protection of confidentiality and the rights of the data subject.

The following privacy policy outlines how Proger srl has implemented the new directives to ensure greater control and protection of personal data. Here, you will find details on the information we collect, why we process your personal data, and your rights.

1. Data Controller – Data Protection Officer

The Data Controller is Proger srl, headquartered at Via Napoli 125, 80013 Casalnuovo di Napoli, NA (hereinafter referred to as the “Controller”). The Data Protection Officer can be contacted via email at [email protected] for information regarding the data processing.

2. Categories of Data

The data processed by the Controller includes, or may include:

· Personal details (name, surname), business address, and contact information (landline, mobile phone, email address);

· Banking and/or payment details;

· Marketing data.

3. Purpose and Legal Basis of Processing – Legitimate Interest

Data will be processed differently depending on the type of user: customer, former customer, or potential customer.

· For customers and former customers, Proger manages the current or past contractual relationship, invoicing, and payments. It also manages the development, updates, and support for the solutions used; commercial relationships; and promotional and marketing offers. The administrative management of former customers’ data complies with the laws of the countries involved in the commercial relationship.

· For potential customers, data processing involves the periodic communication of company activities via email or SMS.

Commercial and promotional communications regarding software solutions, projects, initiatives, surveys, or market research are directed at individuals who have previously expressed interest in the Controller’s activities.

4. Methods of Processing

Your data is collected and processed lawfully and fairly for the purposes outlined above. Processing may involve electronic and automated tools, including entry into and organization within databases, in compliance with GDPR security measures to ensure data security and confidentiality.

Your data may be collected and processed using servers and solutions not located at Proger’s premises due to the use of Cloud technology. In such cases, Proger commits to relying on third-party solutions that ensure the highest standards of data protection for the corporate data managed by Proger.

5. Retention Period

Data will be retained for no longer than ten (10) years for administrative and commercial purposes and, in any case, for the time strictly necessary to pursue the Controller’s legitimate interest. Periodically, Proger may request your consent to extend this period via a specific communication.

6. Rights of Access, Deletion, Restriction, and Portability

The Controller informs you that you are entitled to the rights set out in Articles 15 to 20 of the GDPR. For instance, by sending a specific request to [email protected], you can:

· Obtain confirmation of whether your personal data is being processed;

· If data is being processed, access the data and information related to the processing;

· Request the rectification of inaccurate data and the completion of incomplete personal data;

· Request the deletion of your data, where one of the conditions set out in Article 17 of the GDPR applies;

· Request the restriction of data processing under the conditions provided in Article 18 of the GDPR.

7. Right to Object

Under Article 21 of the GDPR, you also have the right to object at any time to the processing of your data carried out for the Controller’s legitimate interest by writing to [email protected]. If you object, your data will no longer be processed unless there are legitimate grounds that prevail over your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

8. Right to Lodge a Complaint with the Supervisory Authority

The Controller also informs you that you may lodge a complaint with the Data Protection Authority if you believe your rights under the GDPR or any other applicable regulations have been violated. Details on how to file a complaint can be found on the Authority’s website: www.garanteprivacy.it.