PRIVACY NOTICE (Art. 13 e 14 GDPR)
1. OWNER AND OFFICER’S IDENTITIES AND CONTACTS
SKY SERVICES SpA, legal address Via Guantai Nuovi n. 16 – 80100 Napoli (NA),VAT number: IT07445910636, as controller, inform you according art. 13 of UE Regulation nr. 2016/679 (from now “GDPR”) that your data will be processed with the following manners and for the following purposes.
2. SUBJECT OF THE PROCESSING
SKY SERVICES SpA processes personal and identity data (such as name, surname, company name, address, telephone number and e-mail) – from now “personal data” or “data”, as provided by you for the following purposes:
- To obtain the supply of the services provided by Sky Services Spa, or in order to guarantee the correct execution of airport handling operations as requested by the Client in accordance with a contract for the supply of the required service.
- For the selection and recruitment of the employees with an undersigned employment agreement between the parties.
- For sourcing or signing supply agreement between the parties.
3. PURPOSES OF THE PROCESSING AND LEGITIMATE INTERESTS
Your personal data are processed:
A) Without explicit consent (art. 6 lett. b), e) GDPR), for the following purposes:
- In case processing of data is mandatory for the execution of an agreement or pre-contractual obligations required by the same subject (personal data related to agreements or pre-contractual activities with clients, suppliers; data of employers in recruitment and selection phase)
- To fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as for anti-money laundering);
- To exercise the rights of the owner, for example the right of defense in court.
B) For marketing purposes (submission of commercial information, newsletters, and so on), simultaneously is made aware by the owner of data processing this privacy notice. Data are inserted in the mailing list of the company and will be used only for advertising and information messages on the services supplied by the company. The processing of your data will happen only for the purposes indicated above and processed by the person in charge of managing the service. You can revoke consent to processing of your data by sending an e-mail to the following address: firstname.lastname@example.org.
4. DATA RECIPIENT AND DATA SUBMISSION
Your data will be accessible for the purposes as per art. 3.A) e 3.B) to the employees and members of the staff (also external), as responsible or in charge of data and/ or system managers.
In case of SKY SERVICES SpA employees’ personal data, they can be transmitted to the following recipients:
- Work consultant for the tax fulfilment of paycheck.
- Accountant for digital transmission of 770 and CU models.
- Doctor in charge for the compulsory supply of medical examinations in the field of occupational health.
- Human resources responsible for the delivery of payckeck and for employment manager in the field of administration duty (vacations, disease, permits, and so on).
- The responsible of safety and protection of the employees for the supplying of the service.
In case of personal data are necessarly used in the management of airport handling services, data can be transmitted to the following recipients:
- Internal employee who processes the data for the provision of the service (Sky Services FBO manager).
Personal data are saved on server located in the EU. If needed, the controller, can move the server in a non EU country. In this case, the controller, ensure that the moving to a non EU country will be done in accordance with the applicable law, after the stipulation of standard clauses as required by European Commission.
Without the need of an explicit consent art. 6 lett. b) and c) of the GDPR), the Data Controller will be allowed to communicate your data for the purposes referred to in art. 3.A) of this privac notice to Supervisory Bodies (such as IVASS), Judicial Authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is mandatory by law for the accomplishment of mentioned purposes. These subjects will process data as independent controllers of their processing.
5. PROCESSING MANNERS AND RETAINING PERIOD
Your data processing will be realized through operations indicated in art. 4 n. 2) GDPR, specifically of collecting, recording, managing, saving, reading, processing, use, interconnection, blocking, communication, erasing and destruction of data. Your personal data will be subject to paper and digital processing, partly automated. The controller will process personal data for the time needed to fulfil the purposes stated above and not for more than 10 years after the end of the relations for the service mission.
6. DATA SUBJECT RIGHTS
As data subject, you have the rights as stated in art. 15 GDPR:
- To obtain the confirmation of the existence of personal data about you, also if not yet recorded, and their communication in a clear form.
- To obtain the confirmation:
a) of the source of personal data;
b) of processing purposes and modes;
c) of the approach in case of processing through electronic devices;
d) of identification data of the controller, the responsible and the representative as for art. 3, comma 1, GDPR;
e) of subjects and categories of subjects to whom data can be communicated and that can acknowledge as representative in charge in the country area, of responsible and in charge.
- To obtain:
a) the update, the correction or integration of the data;
b) the erasing, transformation in an anonymous way or the block of the data processed against the law, including data that do not need to be recorded in relation with the purposes for which the data have been recorded or processed;
c) the document that attests that the operations as stated in letters a) and b) have been shared – also for their contents – with data recipients, except in the case that this is impossible or disproportionate in relation with the right.
- To oppose, totally or partly:
a) to legitimate reasons albeit related to the aim of data collection, to His/her data processing;
b) to his/her data processing for the purpose of sending advertising messages or direct sale messages or for the purpose of marketing research and commercial messages, through automated system of calling without telephone operator, through e-mail and/or traditional marketing, through phone call and/or paper post.
The right of opposition, stated in the previous point b), to direct marketing purposes through automated modes extend to traditional modes. Data subject can oppose partly too. Therefore, the subject can decide to receive only traditional marketing proposal or receive only automated proposal, or none of the two.
- Right to correct personal data in case they have been modified and no longer meets the data previously recorded or communicated (art. 16 del GDPR).
- Right to erase data (“right to be forgotten” art. 17 of GDPR). Sky Services SPA in one of the following case, will erase the data base and the archives where the data are saved:
a) data are no longer needed for the purposes that required their collection and processing;
b) the subject revokes the consent and if there is no legal basis for processing;
c) the subject opposes to the processing as for art. 21, paragraph 1 of GDPR, and there is no reasonable reason to proceed with the processing, or opposes to data processing as for art.21 paragraph 2;
d) data have been illegally processed;
e) data must be erased to fulfil a legal duty established by EU law or the subject member country law;
f) under 18’s data are processed as stated in art. 8, paragraph 1 of GDPR.
- Right to limitation of processing (art. 18 GDPR). The subject has the right to have a limited processing in the following cases:
a) the subject questions the accuracy of data, for the period needed by the controller to verify the accuracy of such data;
b) the processing is illegal and the subject opposes to erase data and instead ask a limited use;
c) although the controller no longer need the data, data are needed by the subject to check, practice and defend the rights in a legal action;
d) the subject opposes the processing as for art.21, paragraph 1 of GDPR, while waiting the check if the controller’s interests are more significant than the subjects’ interests.
- Right to opposition (art. 21-22 of DGPR): the subject has the right to oppose in any moment, for reasons linked to his/her specific situation, to his/her data processing as stated in art.6, paragraph 1, letters e) or f), including the profiling according to these dispositions. Sky Services SPA does not take decisions for these data starting from digital processing only.
SKY SERVICES SpA notifies to all the subjects the possible changes, limitations or erasing of the data.
SKY SERVICES SpA refrains from further processing of personal data unless there are no legitimate reasons to proceed with the processing that prevail over the interests, rights and freedoms of the interested party or for the assessment, exercise or defense of a right in judicial venue.
7. EXERCISE OF A RIGHT MANNER
You can exercise your rights in any moment sending an e-mail to the address: email@example.com
8. NATURE OF DATA COLLECTION AND CONSEQUENCES OF A DECLINE TO ANSWER
The provision of data for the purposes referred to in art. 3. is mandatory. In case of absence of data collection, we will not be able to grant you our offered services as per art.2.