POLICY ON THE PROCESSING OF PERSONAL DATA PURSUANT TO

ART 13 REGULATION ( EU ) 2016/679 ( “GDPR” )

1. Data controller

Sword Principles S.r.l., VAT nr 02736750189, with registered office in Piazza Vittorio Veneto 5, Vigevano (PV) — 27029 (referred to hereafter as “SP “).

2. Which personal data do we process and where is it collected from?

We collect the following categories of  data directly from you ( being the “interested” party ) for the purpose of pursuing those goals as futher specified in the present policy: personal  data and contact details.

3. For what purpose do we process your personal data?

SP will process your  data for the following purposes:

1. a)   “service” reasons for the provision of services/products offered by SP. Absent the aforementioned personal details, SP cannot proceed to the provision of products/services;
2. b)   administrative, accounting and legal purposes connected to the management of services/products provided by SP. The legal basis of the data processing for the purpose described in subsection 3 a. above resides in the need to abide by national and supranational regulations according to art. 6.1 lett. c) GDPR, which SP is subject to, for example, for fulfilling financial or accountancy obligations;
3. c)   only after prior specific and separate consent from the interested party will the data be disclosed to third parties—nominated outside processors responsible for data processing according to GDPR article 28 , for the purpose of headhunting or recruting ; and
4. d)   only after prior specific and separate consent from the interested party, for sending commercial communications by means of both automated contact services ( e.g. sms, emails and instant messaging) and traditional contact services ( e.g. operator-managed phone calls and traditional mail ). Commercial communications may concern promotions linked to SP products and/or services, offers, promotions, products and services from third parties with which SP has concluded trade agreements, without disclosing the data to them.
5. For how long will we store your data?

We will store your data until withdrawal of consent, in a manner compatible with technical procedures for erasure and backup.

5. Who will process your data?

For the purposes related to articles 3 a., 3 b. and 3 d., your data will be processed solely by employees of SP business functions appointed to the pursuit of the purposes stated above, who have been expressly authorized to the processing and have received suitable operating instructions.

For the purposes related to article 3c., by writing to the [email protected] address you will have access to a complete list of all subjects to whom, after your specific and separate prior consent, we will have disclosed your personal details and who will have consequently been nominated outside processors responsible for data processing according to GDPR article 28.

6. What are your rights?

You may request of SP access to personal details about you, their rectification or erasure, integration of incomplete personal details, the restriction of processing in those cases pursuant to art. 18 GDPR. You also have the right to data portability or to receive personal details in a structured format, of common use and readable by automatic data processing machines, and, if technically feasible, to disclose those details to other processors without hindrance. Finally you have the right to withdraw consent at any time.

You may exercise your rights by writing to [email protected]. Furthermore, you may at any and all times lodge complaint with the supervisory authority for Personal Data Protection, and seek other means of legal remedy as envisaged by applicable laws.