Pursuant to and for the purposes of the current legislation on the processing of personal data, defined in accordance with the provisions contained in the
EU Regulation 2016/679 of April 27, 2016 supplemented by the Legislative Decree Aug. 10, 2018, no. 101,
We inform you that the processing of data provided or otherwise acquired will take place in full respect of fundamental freedoms, always adopting principles based on correctness, lawfulness and transparency, and for purposes not exceeding the purposes of collection, so as to ensure the protection and confidentiality of the data.

Categories of data processed
For the specific services provided by the TERMINTER S.R.L. retail company, door-to-door sales of water purification equipment and infini apparatus, the categories of personal data processed may be:
– data that allow direct identification, such as biographical data (for example: first and last name)
– data that allow indirect identification, such as an identification number (for example: reference address)
– data related to electronic communications and not (for example: email addresses, telephone)

0 -Source from which personal data NOT collected directly from the data subject originate
Where personal data is NOT collected directly from the Data Subject, it comes from:

• Electronic communication received via information request format on the company website
• Communications of the network of distributors/dealers through which Terminter products are marketed

1 – Identity and contact details of the data controller and its representative:
The Data Controller is TERMINTER S.R.L.
Establishment -headquarters (administrative and operational): Industrial Zone 98044 – San Filippo del Mela (ME) – VAT 01145290837
Legal Representative: Sole Administrator Mr. INTERDONATO Orazio (Data Processing Contact Person)
Phone:  0283542351  Reference email address: commercial@terminter.com,  websites: www.terminter.com , www.farmacqua.it 

2 – Purposes of the processing for which personal data are intended – Legal basis for processing
Personal data of Customers, purchasers of products and equipment produced by TERMINTER S.R.L., are acquired to fulfill a legal and/or contractual obligation.
Legal basis -contractual:
Data delivery is a Necessary requirement for the assignment to provide technical support and maintenance services included in the warranty of manufactured products by TERMINTER S.R.L. and purchased by the Client and are processed by the Data Controller without the need for documented express consent, considering that, in the absence of such data, the company cannot proceed with the conclusion of the assignment and guarantee the provision of the service.
Legal basis -legal:
Customers’ personal data are also processed without the need for documented express consent:
– when necessary to comply with legal obligations to which the economic operator is subject, such as during tax compliance or satisfaction of requests from control and/or supervisory bodies.

3 – legitimate interests pursued by the data controller and acquisition of consent
The Data Controller does not pursue any further interest in processing the personal data of Customers for purposes beyond the provision of warranty service activities, such as sales promotion and/or Direct Marketing activities, whereby It is NOT required to request Documented Express Consent.

4 – any recipients or any categories of recipients of personal data
They are third parties, involved in the scope to the specific needs of satisfaction of the task of providing technical support and maintenance services: the distributors / dealers of the sale of products, transportation and shipping companies for the possible delivery of goods to the buyer.
Only the personal data of the interested party strictly necessary for the performance of the requested service or prescribed by the applicable legislation are communicated to the above-mentioned recipients.
Personal data of Customers collected by TERMINTER S.R.L. are also processed by the internal staff of the organization, duly instructed to do so, who need to have knowledge of them in the performance of activities necessary to pursue the purposes expressed above.

5 – retention period of personal data or criteria used to determine this period
The data processed in the sole interest of satisfaction of the supply contract (see paragraph 2), will be processed until the conclusion of the warranty period and for the further duration of any technical assistance assignments signed. Data will then be retained only for the satisfaction of legal and/or tax obligations.
The Data Controller ensures periodic verification of data integrity and updating and defines the time limit by which it will automatically proceed to data deletion in 5 years after the termination of the relationships.

TERMINTER S.R.L. declares that:
– DO NOT transfer Customers’ personal data to a third country or international organization
– DO NOT operate or enable in-house or through third parties, automated decision-making processes, including profiling

RIGHTS OF THE INTERESTED PARTY

Exercise of the right
To ensure the exercise of the Data Subject’s right, the Data Controller has specially identified the dedicated email address and contact reference given in this Information.

Requests must be formally transmitted by the Interested Party, by registered mail AR or email pec to the addresses specified in point 1 of the policy, with “Type of Right Exercised” as the subject line (e.g: Right to Access).
The notice must include the identifying data of the interested party, details of the request, and be accompanied by a copy of the applicant’s ID.
Within 3 working days and before proceeding with the different requests, TERMINTER S.R.L. will activate internal protocols To verify that the sender of the transmission actually coincides with the Interested Party, as a guarantee for the same.

Right to Access
The Data Subject has the Right to obtain confirmation from the data controller as to whether or not personal data concerning him or her is being processed.
In the event of a positive outcome of active processing, the Data Controller will ensure that the data subject, within 10 working days of the sender’s successful confirmation check, can obtain access to the personal data, providing a copy of the same together with the specific information in the latest update.
In case of additional copies requested by the data subject, the data controller may charge a reasonable fee based on administrative costs. If the data subject submits the request by electronic means, and unless otherwise specified by the data subject, the information will be provided in a commonly used electronic format.

Right to Rectification
The Data Subject has the Right to obtain from the data controller the correction of inaccurate personal data or to supplement incomplete personal data.
In the case of active processing, the Controller will ensure the data subject, within 5 working days after the successful confirmation of the sender, corrections and additions of the requested data in its databases and archives.

Right to Cancellation
TheData Subject has the Right to obtain from data controller the deletion of personal data concerning him/her in the following cases:

• personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed (see section 2);
• the data subject objects to the processing and there is no further legitimate reason to proceed with the processing;
• personal data have been unlawfully processed;
• personal data must be deleted to fulfill a legal obligation prescribed in the EU framework.

TERMINTER S.R.L. will activate internal protocols to verify the legitimacy of the request and the characteristic of the data that can be deleted. Following the verifications, the Data Controller guarantees the data subject within 15 working days to obtain confirmation that the personal data has been deleted.

Right to Limitation
The data subject has the Right to obtain from the data controller to temporarily transfer his or her personal data to a system of alienation that tends to freeze them by making them no longer accessible and unrelated to any further form of processing itself.
TERMINTER S.R.L. will activate internal protocols to verify the legitimacy of the request and the characteristic of the data that can be restricted. Following the verifications, the Data Controller will ensure that the data subject will be able to obtain confirmation that the processing of personal data has been restricted within 5 working days.

Right to Portability
The Data Controller acknowledges that the Right to Portability represents the possibility for data subjects not only to obtain and reuse personal data provided to a data controller, but also to transmit these data to a different service provider (belonging to the same or a different business sector).
The status of entitlement is recognized for all data that the data subject has provided to the Data Controller, including information obtained from observation in the activities carried out for the data subject, within the scope of the supply relationship and the provision of services.
The data will be transmitted in a structured format on *.pdf file format to ensure them commonly used and machine-readable requirements.
The request for the exercise of the right to portability must include in detail the data that are the subject of the request, together with the identifying data of the person to whom it is eventually requested to be transmitted.
TERMINTER S.R.L. will ensure within 15 working days from the successful confirmation check of the sender, the transmission of the required data.

It should be noted that data controllers who follow up on portability requests are not responsible for the processing carried out by the individual data subject or the company to which the data in question are transmitted as a result of exercising the right of portability. Indeed, data controllers act on behalf of the data subject, even if personal data are transmitted directly to a different data controller. In this sense, the holder who follows up on the portability request is not responsible for the receiving owner’s compliance with data protection regulations, since the latter is not selected by him.

The Data Controller will notify each of the recipients, to whom personal data have been transmitted, of any rectification or erasure or restriction of processing, unless this proves impossible or involves disproportionate effort.
The Data Controller will notify the Data Subject of these recipients if he or she requests it.

Right to file a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, a data subject who believes that processing concerning him or her is being carried out in violation of his or her rights has the right to lodge a complaint with the supervisory authority.
The Garante per la protezione dei dati personali (Garante Privacy) is the Italian national supervisory authority on personal data protection.
The procedures for forwarding the complaint to the supervisory authority, are clearly stated in full transparency at https://www.garanteprivacy.it/

TERMINTER S.R.L.
Horatio INTERDONATO
Sole Administrator – Treatment Contact Person