Version 1.0 of 24 April 2021
Dear User, pursuant to articles 12, 13 and 14 of the European Regulation no. 679/2016 “General Regulation for the Protection of Personal Data”, we are hereby providing you with the Information on the processing of your Personal Data.
We remind you that you have the right to read it before communicating your Personal Data to us, or to exercise your right to object to one or more of the purposes (purposes) of the processing indicated in this Information Notice in the relevant section.
The Data Controller is:
EDS SPORTSMAN LIMITED
39 Hendon Lane, Finchley
London N3 1RY, United Kingdom
The main processing operations carried out are related to the fulfilment of the Employment Contract and all the obligations related to it (both of a fiscal and legal nature, as well as of an organisational and operational nature), to the fulfilment of the contract with the client and all the obligations related to it (both of a contractual and of a fiscal and operational nature), as well as to the acquisition of new clients and the increase of the volume of business through those already acquired, by means of contact through the website, marketing initiatives and others.
The main risks related to the above-mentioned processing operations are identifiable in the possibility that one or more actions aimed at finding new business may violate the rights and freedoms of the Data Subjects, for example by causing annoyance to the Data Subject by receiving unwanted commercial offers. EDS SPORTSMAN LIMITED shall, however, take all technical and organisational measures to ensure that those who receive advertising or commercial offers from EDS SPORTSMAN LIMITED have in fact given their consent. In addition, it will ensure that the frequency of sending and the methods chosen do not exceed what is considered to be a legitimate propaganda activity.
In general, an identifiable risk is the possibility that unauthorised persons or third parties come into contact with personal data of Data Subjects of which EDS SPORTSMAN LIMITED is the Data Controller. However, in accordance with the legislation in force, EDS SPORTSMAN LIMITED takes all appropriate technical and organisational measures in order to reduce to an acceptable minimum the risk that such an eventuality may occur.
The purposes for which we process your Personal Data are as follows:
1) If you are an employee or collaborator of EDS SPORTSMAN LIMITED Fulfillment of your obligations under your Contract of Employment or Collaboration. For example: processing of payroll, management of work shifts, management of sick days, holidays, contributions, training courses etc. In this case, the Consent is not required because the Legal Basis of the Processing is the Execution of the Employment Contract itself or, in some cases, the Legitimate Interest of the Data Controller, if it is necessary to proceed with processing activities involving Interested Parties who are employees or collaborators of EDS SPORTSMAN LIMITED and at the same time it is impossible to ask them for their free Consent.
2) If Customer of EDS SPORTSMAN LIMITED Fulfillment of the obligations relating to the contract of sale, assistance and/or services signed with the interested party and all the pre-contractual measures related to it, such as quotation, negotiation, insertion in the internal management system, etc. In this case, Consent is not required as the Legal Basis of the Processing is the contract signed with the Data Subject and all the pre-contractual measures relating thereto.
3) In the case of a natural person who is not a customer of EDS SPORTSMAN LIMITED, the processing of personal data is not required as the legal basis for the processing is to be found in the contract signed with the Data Subject and all pre-contractual measures relating to the data subject. In this case Consent is required and constitutes the Legal Basis for the Processing itself.
4) Management of the acquired customer base, including retailers who are natural persons. In this case the Legal Basis of the Processing is the Contract signed between the parties, and therefore Consent is not required, as well as the Legitimate Interest as “there is a relevant and appropriate relationship with the Data Subject”.
A full list of recipients with whom we may need to share your Personal Data in accordance with applicable law is available upon request. Your request must be made to the Data Controller without any special formalities.
The categories of recipients to whom your Personal Data will be disclosed are:
1) Public bodies in charge of Social Security, Workers’ Insurance and Tax Assessment (e.g.: INPS, INAIL, Agenzia delle Entrate etc.) and any public body to which EDS SPORTSMAN LIMITED is required to provide the Data of its employees, collaborators, retailers or customers by law.
2) Companies and Professionals in charge of the management, maintenance and remote assistance of EDS SPORTSMAN LIMITED’s IT equipment.
3) Professionals in the field of Accounting and Payroll Management.
4) Companies that manage EDS SPORTSMAN LIMITED’s web equipment.
5) Software Houses and Manufacturers of Software Solutions used by EDS SPORTSMAN LIMITED for the Processing of Personal Data.
6) EDS SPORTSMAN LIMITED’s own customers, should it be necessary, due to compelling operational needs, to communicate to them the contact details of employees or contractors of EDS SPORTSMAN LIMITED.
All the Recipients listed shall, from time to time, be appointed as Data Processors and instructed by EDS SPORTSMAN LIMITED in accordance with the provisions of the Law and shall be required to keep the information transmitted confidential and to erase or return it once the processing has been completed.
EDS SPORTSMAN LIMITED does not and will not transfer your Personal Data to international organisations or data controllers located outside the European Economic Area. Should EDS SPORTSMAN LIMITED decide to do so, it will scrupulously comply with the provisions of EU Reg. 679/2016 on the foreign transfer of personal data and will take care to inform You, in accordance with the provisions of the Law, before making the transfer.
EDS SPORTSMAN LIMITED will store Your Personal Data according to these criteria:
1) In case of Personal Data subject to retention obligations established by Italian or European law: within and not beyond the limits dictated by the relevant legislation, after which they will be deleted or made anonymous.
2) In case of Personal Data referring to Employees or Collaborators (except for point 1): until the end of the employment or collaboration relationship with EDS SPORTSMAN LIMITED, after which they shall be erased or made anonymous.
3) In the case of Personal Data of customers who are natural persons granted for the purposes (purposes) referred to in point 3) of the Purposes: until the Data Subject revokes his/her consent and in any case no longer than 5 years after the consent has been given.
4) In the case of retailers of EDS SPORTSMAN LIMITED natural persons: until the end of the contract signed, without prejudice to point 1), at the end of which they will be deleted or made anonymous.
Below we set out the rights you have under the European Regulation 679/2016. To exercise one or more of the following rights, it is sufficient for you to contact EDS SPORTSMAN LIMITED at the contacts indicated above without any particular formality.
RIGHT OF ACCESS
Art. 15 EU Reg. 679/2016
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data relating to him are being processed and, if so, to obtain access to the personal data and the following information:
1) the purposes of the processing;
2) the categories of personal data concerned;
3) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if they are recipients in third countries or international organisations
4) where possible, the proposed period for which the personal data will be stored or, if that is not possible, the criteria used to determine that period
5) the existence of the right of the data subject to request from the controller the rectification or erasure of personal data or the restriction of the processing of personal data concerning him or her or to object to the processing of personal data concerning him or her
6) the right to lodge a complaint with a supervisory authority;
7) where the data are not collected from the data subject, all available information as to their source
8) the existence of an automated decision-making process, including profiling as referred to in Article 22(1) and (4), and, at least in such cases, meaningful information about the logic used, as well as the importance and the envisaged consequences of such processing for the data subject.
RIGHT OF RECTIFICATION
Art. 16 EU Reg. 679/2016
The data subject shall have the right to obtain from the controller the rectification of inaccurate personal data concerning him or her without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, including by providing a supplementary declaration.
RIGHT TO ERASURE
Art. 17 EU Reg. 679/2016
The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall be obliged to erase the personal data without undue delay if any of the following grounds applies:
the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
the data subject withdraws the consent on which the processing is based in accordance with point (a) of Article 6(1) or point (a) of Article 9(2) and if there is no other legal basis for the processing;
the data subject objects to the processing pursuant to Article 21(1) and there is no overriding legitimate ground for processing, or objects to the processing pursuant to Article 21(2);
the personal data have been unlawfully processed;
the personal data must be erased in order to comply with a legal obligation laid down by Union or Member State law to which the controller is subject;
the personal data were collected in connection with the provision of information society services as referred to in Article 8(1).
RIGHT TO RESTRICTION OF PROCESSING
Art. 18 EU Reg. 679/2016
The data subject shall have the right to obtain from the data controller the restriction of processing when one of the following applies:
the data subject disputes the accuracy of the personal data, for the period necessary for the controller to verify the accuracy of those personal data;
the processing is unlawful and the data subject objects to the erasure of the personal data and requests instead that their use be restricted;
although the controller no longer needs the personal data for processing purposes, the personal data are necessary for the establishment, exercise or defence of legal claims by the data subject;
the data subject has objected to the processing pursuant to Article 21(1), pending verification as to whether the legitimate reasons of the controller prevail over those of the data subject.
For the purposes (purposes) for which You have given Your Consent, You are granted the right to withdraw Your Consent, i.e. to unilaterally withdraw from the processing operations related to the Purposes for which You have given Your Consent. Processing carried out before your revocation will, in accordance with the law, be lawful.
If you believe that a processing carried out by us has caused you prejudice or damage, or if you believe that there have been improprieties or unlawful acts in the processing of your Personal Data carried out by us, you are guaranteed the right to lodge a Complaint with the Supervisory Authority, according to the procedures established by the latter, available at the following address:
Partial or complete refusal to provide your Personal Data to EDS SPORTSMAN LIMITED will result in:
1) If you are an employee or collaborator of EDS SPORTSMAN LIMITED: you will not be able to enter into any work relationship or collaboration.
2) If you are a customer of EDS SPORTSMAN LIMITED: you will not be able to complete the sale or signing of any service and/or support contract.