Note d’information et demande de consentement pour le traitement des données personnelles.

Invent S.r.l.

DISCLOSURE

on PROTECTION AND processing of personal data [i]

Invent s.r.l., a single member company, with registered office in Noventa di Piave (VE), via Alessandro Volta n. 54, share capital of € 500,000.00, fully paid up, registered in the register of companies in Venice, registration number, VAT number and tax code 04096150281 (hereinafter “Invent” or the “Holder”), provides the underestimation of information to pursuant to Regulation no. 2016/679 / EU (so-called General Data Protection Regulation or “GDPR”) and additional legislation, also under Italian internal law, applicable in the matter of protection and processing of personal data (overall, hereinafter the “Privacy Law”) , with particular regard to the processing of personal data of interest to each potential and / or current customer (hereinafter referred to as the “Customer”) contacted by Invent, also through its sales staff (in any case framed), or with whom a contract and / or order relating to the sale and / or supply of products and / or services by Invent (hereinafter the “Processing”).

Please note that (i) personal data means any information concerning an identified or identifiable natural person; an identifiable natural person can be identified, either directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online ID or one or more characteristic elements of his physical identity, physiological, genetic, psychological, economic, cultural or social; while (ii) processing (such as processing) means any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, registration, ‘organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction;

I. Holder and manager of the processing and responsible for the protection of personal data

The Data Controller is Invent in the person of the legal representative pro tempore. The Data Controller may in particular be contacted by fax at 0421/572963 and by e-mail at inventsrl@legalmail.it.

The Data Controller and the Data Processor, according to the needs and opportunities of the case, will be able to designate one or more subjects authorized to the Treatment.

II. Object of the Treatment

The personal data processed by Invent are: (a) personal data necessary or useful to allow Invent to make contact with each individual Customer to whom the data refer and to put in place the pre-negotiation measures aimed at illustrating and offering to the Customer the products and / or services sold and / or supplied by Invent and / or to allow Invent to draw up the commercial proposals for the Customer and to transmit them to the Customer and / or to conclude the related contracts and / or orders with the Client and / or, finally, to execute such contracts and / or orders, including, purely by way of example, the application and verification of the use of any facilitations under hypotheses granted to the Customer – such as, in particular, the name , the tax code, the e-mail address, the telephone number, the address of the Customer, as well as any additional personal data that the Customer deems useful to provide to Invent -; furthermore – if and to the extent that the additional information indicated below can be detected and are available in consideration of the time-based technologies available to Invent that are included or incorporated into the products and / or services provided by Invent to the Customer (on which Invent does not release any warranty to the Customer) – (b) personal data concerning the type, operation, status and consumption of the systems and / or products supplied or sold by Invent to the Customer and / or plants and / or products anyway present in the house or in the real estate unit owned or in the availability of the Customer – as, in particular, information relating to plants or energy products, photovoltaic, thermal, home automation, air conditioning, air conditioning, burglar alarm and / or other equipment, including for example, information about the status, temperature, production and / or consumption of such plants and / or products, also with regard to to the light or gas utilities to which they are connected – data that may be known by Invent following the conclusion or effect of the execution of contracts with the Customer or in any other way.

Personal data processing that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or union membership, as well as genetic data, biometric data intended to uniquely identify a physical person, are not the object of the processing of personal data to the health or sexual life or sexual orientation of the person and / or other sensitive data referred to in Legislative Decree n. 196/2003 (if and as applicable). Should one or more of these data be communicated to Invent by the Customer on their own initiative, they will be immediately canceled.

III. Purpose of the Treatment

The collected data are processed by Invent for the following purposes:

Offers and contracts for products and services Invent

(i) contact the Customer, including through its sales personnel, employees, agents or independent collaborators, and implement pre-negotiation measures aimed at illustrating and offering the Customer the products and / or services sold and / or provided by Invent and / or conclude and / or execute the related contracts and / or orders (including, purely by way of example, the application and verification of the use of any facilities in cases granted to the Customer);

Monitoring of plants and / or products

(ii) verify and monitor the type, operation, status and consumption of plants and / or products supplied or sold by Invent to the Customer and / or plants and / or products present in the house or in the real estate unit of property or availability of the customer, as well as the related utilities and related products and related consumption;

Further commercial offers

(iii) drafting and transmitting to the Customer, by e-mail, telefax and / or paper mail, commercial proposals of Invent different and further from that for which Invent initially collected the personal data of the Customer;

(iv) to have third parties issue and transmit to the Customer, by e-mail, telefax and / or paper mail, further commercial proposals of said third parties, even of different types;

Regulatory obligations and legitimate interest of the owner

(v) comply with any type of obligation, duty or duty of Invent and make any fulfillment foreseen for Invent by the applicable regulations, with particular regard to the relationship with the Customer connected with the contracts concluded with the Customer, and this also in the comparisons with public administrations and / or sector authorities and / or for tax purposes;

(vi) pursue the legitimate interest of Invent in exercising its rights, including in judicial or administrative matters.

IV. Consequences of failure to communicate personal data

It is hereby informed that the Processing, although not obligatory (without prejudice to the obligations that may derive from it referred to in paragraph III, points (v) and (vi)), is necessary as specified below:

(i) the communication by the Customer of the name and at least a telephone number or e-mail address is necessary in order to allow Invent to make contact and put in place the pre-negotiation measures with the Customer to illustrate and offer him the products and / or services sold and / or supplied by Invent;

(ii) communication of date and place of birth, address of residence, tax code, any number of batch I.V.A. as well as the title of availability and the address of the property on which to perform the work and / or provide the service (where applicable), as well as any other information required for the conclusion and / or execution of contracts and / or orders for the sale and / or supply of products and / or services sold and / or supplied by Invent under the said contracts and / or applicable regulations, is necessary in order to allow Invent to conclude the contracts with the Customer and / / o to provide for the execution of the relative report, including, where appropriate, the application and verification of the use of any economic benefits offered to the Customer;

(iii) if, moreover, the Customer intends to receive commercial proposals from Invent or third parties, it is necessary the communication – in addition to the above data – also of all the other data indicated in the appropriate “Data Collection Form” reported at the end of this information.

The failure to communicate the personal data indicated above implies, respectively, as specified in points (i), (ii) and (iii) above, the impossibility for Invent to make contact and implement the aforementioned pre-negotiation measures with the Customer and / or to conclude and execute the above-mentioned contract and / or order with the latter (including, where appropriate, the application and verification of the use of any economic benefits offered to the Customer) and / or to draw up and transmit – or have them drawn up and forwarded – further commercial offers to the Customer.

The provision of other personal data of the Client being processed is optional.

V. Methods and conservation of the treatment

Personal data processed may be processed using both paper and electronic files and archives (including portable devices) and by means of collection, registration, organization, storage, consultation, adaptation, modification, selection, extraction, comparison and use. , making available, interconnection, blocking, communication, transmission, cancellation and destruction necessary to meet the aforementioned purposes.

The processing will be in compliance with the principles of lawfulness, correctness, updating, relevance and non-excess of the Privacy Law, in compliance with the purposes of the treatment specified above and for the time necessary to achieve the same purposes.

In particular, the processing will take place with the preservation of personal data that are the subject for the duration of the contractual relationships established with the customer and following the termination of such relationships – as in the absence of the relative establishment – for a time not exceeding from the last in the temporal order between the moment of the initial collection of the Customer’s personal data and, if there is a subsistence, the moment of termination of the last contractual relationship that has been established with the Customer. Personal data, after this period, will then be deleted, unless anonymously converted.

In any case, the preservation of personal data subject to processing remains longer than is necessary to meet the conservation obligations to which the Data Controller is bound, for fiscal or other purposes, pursuant to the applicable law, and / or, however, in order to cope with a legitimate interest of Invent in the exercise of its rights.

YOU. Communication of personal data

Personal data processed may be disclosed, to the extent that this is within the purposes of processing, to the following categories of private and / or public subjects:

(i) subjects who have commercial or similar reports with Invent aimed at providing Invent with the components used for the realization of the products and / or services offered to the Customer;

(ii) subjects who carry out activities in outsourcing or in any case on behalf of Invent, in particular in the production and production of products and services related to energy and energy saving and / or in the sector of ICT services and technologies and / or housing systems and real estate units;

(iii) individuals who provide advice or provide collaboration to Invent, in any form or manner, including Invent’s employees and agents and self-employed or professional collaborators whose Invent uses;

(iv) subjects who have commercial or similar reports with Invent aimed at drafting and communicating commercial offers to the Customer;

(v) entities in the distribution, transport, supply or services related to natural gas or electricity, including merely the regulatory authority for energy networks and the environment;

(vi) subjects in the banking and insurance sector;

(vii) however, any public administration, authority and / or state, regional and / or local authority, however defined, having jurisdiction pursuant to applicable law, including, purely indicative, the administration of finances and the agency revenue, judicial or administrative authorities.

Personal data processed will not be disclosed to the public.

VII. Absence of profiling

Personal data subject to processing are not subject to any automated decision making or profiling process.

VIII. Transfer of personal data

The Data Controller does not intend to transfer the personal data processed in a third country outside the EU and / or to an international organization.

IX. Customer rights

The processing is carried out with the consent of the Customer, who has the right to revoke such consent at any time, without this, however, may affect the lawfulness of the processing based on consent given prior to revocation and, in any case, the necessary treatment due to execution of a contract with the Customer, fulfillment of the obligations of Invent or of a legitimate interest of the latter.

Under the GDPR, the Customer also has the right to:

obtain from the Data Controller access to your personal data and information relating to them, the correction or integration of those incomplete, the cancellation of the same when one of the conditions indicated in art. 17, paragraph 1 of the GDPR and in compliance with the exceptions set out in paragraph 3 of the same article, the limitation of the processing of your personal data to the recurrence of one of the hypotheses indicated in art. 18, paragraph 1 of the GDPR;
obtain from the Data Controller your personal data in a structured and machine-readable format, also in order to communicate such data to another Data Controller;
to propose a complaint to the supervisory authority (Authority for the protection of personal data – www.garanteprivacy.it).
As far as may be applicable, the remaining rights deriving from the Customer by the Privacy Law, such as art. 7 of Legislative Decree n. 196/2003, which, in particular, the right to obtain confirmation of the existence or not of personal data processed, their communication in an intelligible form, the indication of the origin of the same, the identification details of the Data Controller and responsible for the processing, their updating, rectification and integration, cancellation, transformation into anonymous form or blocking of personal data processed in violation of the law; the right to object, in whole or in part, for legitimate reasons to the processing of personal data being processed, even if relevant to the purpose of collection, and to the processing of personal data for the purpose of sending advertising material or direct sales or for the carrying out market research or commercial communication.

The Customer may exercise the aforementioned rights, in particular, by sending notice to the Data Controller by fax or e-mail.

X. Publication and updating of the information

This information note – also published on the Invent website at wwwinventsrl.it – ​​may be subject to updates and / or modifications: any updates will be given to the Customer by publishing the updated text of the information in the aforementioned website Invent internet.

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MANIFESTATION AND REVOCATION OF CONSENT

I declare that I have read, understood and accepted the “Information on the protection and processing of personal data” above and, as a person (Customer) to which the personal data referred to in it refer, I consent to the processing by the subjects and according to the methods illustrated in the aforesaid information for the purposes indicated therein and hereafter referred to and authorized by the selection of the relative box:

□ the purposes of monitoring plants and / or products specified in paragraph III. point (ii);

□ the purposes of the additional Invent commercial offers specified in paragraph III. point (iii);

□ the purposes of the additional commercial offers of third parties specified in paragraph III. point (iv).

Without prejudice to the provisions of paragraph IV .. the Customer may change the choice relating to the prior consent, communicating it to the Data Processor.

It is understood that, regardless of the foregoing, the Processing will in any case be considered legitimate – and to the extent necessary it is also consented by the Customer who relates to Invent as indicated in the above disclosure – for the purposes of establishment and execution of the contracts referred to in paragraph III. point (i), of the fulfillment of the regulatory obligations and of the legitimate interests of the Owner referred to in paragraph III respectively. point (v) and in paragraph III. point (vi) above.

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The appropriate “Data Collection Form” prepared by Invent is here enclosed as an integral part of the “Information on protection and processing of personal data” above.

[i] The Information on the protection and processing of personal data above refers to the personal data of Customers (current and / or potential) of Invent. If appropriate (as in particular for agents), the information can be integrated with a special space (in epigraph or in the margin) indicating the identification details of the salesman who makes the first contact with customers.