POLICY FOR REQUESTS CONCERNING RIGHT OF ACCESS, RECTIFICATION, CANCELLATION, RESTRICTION, OPPOSITION AND PORTABILITY

1. In the context of the GDPR, the following rights are provided for the data subject:

access rectification cancellation (oblivion) restriction portability The right of access is the data subject's right to obtain communications in relation to the purposes for which his or her personal data are possibly processed, the period for which the personal data are processed, the recipients of the personal data, the logic to which any automated data processing responds and (when based on profiling) the possible consequences of such processing. The right of rectification is the data subject's right to obtain rectification or integration of inaccurate personal data concerning him/her (without delay). The right to erasure (or 'oblivion') is - as far as relevant here - the right of the data subject to obtain the deletion of personal data concerning him/her in the following cases:

• the data are no longer necessary for the purposes for which they were collected;
• the data subject has withdrawn his or her consent;
• the data subject has objected to the processing of personal data concerning him or her; or
• the processing of his or her personal data does not comply with the law.

However, the further retention of personal data by the Company is lawful if it is necessary to enable it to fulfil a legal obligation or to establish, exercise or defend a right in court. The right of restriction is the right of the data subject to obtain that personal data concerning him or her be only stored without any other use being made of them - as far as is relevant here - in the following cases

• the data subject contests the accuracy of the personal data, for the period necessary for the controller to verify the accuracy of such personal data;
• the processing is unlawful and the data subject objects to the deletion of the personal data and requests instead that their use be restricted;
• although the controller no longer needs the personal data for the purposes of processing, the personal data are necessary for the establishment, exercise or defence of legal claims;
• the data subject has objected to the processing, pending verification as to whether the legitimate reasons of the controller prevail over those of the data subject.

The right to object is the data subject's right to obtain the cessation of processing in cases where the personal data are processed for direct marketing purposes (or where the personal data are processed for the legitimate interest of the data controller and the data subject disputes the existence of this interest). On the other hand, this policy does not cover cases of objection to processing carried out on the basis of the legitimate interest of the data controller, as the company does not appear to carry out processing on this legal basis. The right of portability is the right of the data subject to receive in a commonly used, machine-readable and interoperable format the personal data concerning him/her processed by automated means, if they are processed under contract or on the basis of consent.

2. Any request concerning the above rights, sent by an individual whose personal data are processed by the Company, shall be handled without delay.

It has been decided to entrust the management of this policy to the following corporate function: Internal Manager.

All communications relating to this procedure - outgoing and incoming, internal and external - must be sent to info@becchettiassociati.it.