Privacy policy pursuant to the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL, regarding the “securities services” offered by VALMED srl

Information to be provided to VALMED srl’s clients and suppliers

In accordance with the Regulation on the protection of individuals with regard to the processing of personal data and on the free movement of such data, namely Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereafter, also, the Regulation), VALMED srl informs its clients and suppliers that it would act as Data Controller in the provision of its "securities services".
Accordingly, VALMED srl has prepared the privacy policy, for natural persons who have relations with its clients. The content of the Information is also valid for personal data of natural persons, (such as representatives of the clients or the suppliers) directly collected by VALMED srl

Information to be provided to natural persons who have relations with VALMED srl’s clients

In accordance with the Regulation on the protection of individuals with regard to the processing of personal data and on the free movement of such data, namely Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereafter, also, the Regulation), VALMED srl in its role as Data Controller, provides to the Data Subjects (i.e. the natural persons who have relations with its clients) with the following information.

Source of personal data
The personal data held by VALMED srl are collected from third parties, namely, clients of VALMED srl with whom the Data Subjects concerned have a relationship. The above mentioned third parties transfer the data (or request their transfer) to VALMED srl for the performance of its "securities services".

Categories of personal data processed
The term “Personal data” means any type of information, identified or identifiable, relating to a Data Subject. The Data Subject’s personal data processed by VALMED srl are those collected from the source described above and could include name, surname, nationality, contacts (including address, phone number and email address), date and place of birth, civil status, economic and financial information, details of ID documents. Usually, VALMED srl does not process special categories of personal data (i.e. special categories of personal data are information revealing the ethnic or racial origin of the Data Subject, his/her political opinions, religious or philosophical beliefs or trade union membership, as well as genetic data, biometric data aimed at uniquely identifying a natural person, data regarding health or sexual life and sexual orientation of the person). Should VALMED srl collect or process special categories of personal data in order to achieve the purposes indicated below, VALMED srl will always process these data in compliance with the provisions of the law and with the requirements indicated in this data protection policy.

Purpose of the processing for which the data are intended. Mandatory and optional nature of the data provision.
The processing of the data indicated above is carried out in compliance with the Regulation and with the principles and obligations of confidentiality and privacy to which VALMED srl also adheres.

The personal data are processed for the following purposes:
1. Purposes closely related and essential to the provision of VALMED srl’s services. The provision of personal data necessary for such purposes is not mandatory, but the refusal to provide them may result in the impossibility of VALMED srl to provide the service. Their processing does not require the consent of the Data Subject;
2. Purposes connected to the obligations laid down by laws, regulations and directives issued by the Supervising Authority (Garante) and Supervisory Bodies of the financial system. The provision of personal data necessary for these purposes is mandatory and the processing does not require the consent of the Data Subject.
The Data Subject’s personal data collected for the above mentioned purposes are not used by VALMED srl for marketing, commercial or promotional purposes.

Categories of recipients to whom the personal data are disclosed. In order to carry out some of its activities, VALMED srl outsources services to companies belonging to the but VALMED srl also of third parties, which fall into the following categories:
• companies providing banking, financial and insurance services;
• entities who offer services for the acquisition, registration and processing of data deriving from documents and media provided or originating from the Data Subjects.
• entities who carry out activities of printing, transfer, enveloping, transport and sorting of communications to the Data Subjects;
• entities who carry out activities of archiving the documentation relative to the relations with the Data Subjects;
• entities providing hardware outsourcing and data processing services.
The personal data collected may also be communicated to the competent Authorities to provide answers to their requests in accordance with the regulation applicable time by time, in particular referring to the prevention of money laundering and terrorist financing. Personal data are not object to disclosure.

Transfer of personal data outside the European Economic Area
VALMED srl may have to transfer the personal data collected to countries outside the European Economic Area, whose legal provisions on the protection of personal data are different from those of the European Union.
In this case, VALMED srl ensures the protection of personal data by signing Standard Contract Clauses or other protection tools defined by law.

Retention period of personal data
VALMED srl keeps personal data for a period of 10 (ten) years starting from the termination of the contractual relationship with its clients, with out prejudice to the provisions of art.17 of the Regulation.

Exercising the personal data access right and other rights.
With relation to the provided personal data, the Data Subject can exercise the following rights guaranteed by the Regulation:
a) access right;
b) right to rectification, modification and cancellation of personal data or the right of restriction of the processing of the former;
c) right to object the processing;
d) right to withdraw the consent
e) right to send a complaint to the competent Supervisory Authority (Garante)

The right to portability of the data cannot be exercised, as the data are not collected directly by VALMED srl and the latter processes them on the basis of a contract with its clients and not with the Data Subject concerned.
The Data Subject can exercise any of the above mentioned rights from point a) to point e) sending a written communication:
- via email to: This email address is being protected from spambots. You need JavaScript enabled to view it.
- via recommended letter to: VALMED srl Via dell’Industria 3, TOVO DI SANT’AGATA (SO), addressed to the Chief Data Officer.

Data Protection Officer
The owner of the treatment of the company VALMED srl declares:
• havelessthan 250 employees
• to have customers including companies with reduced data volumes
• that data processing is not on a large scale,
therefore does not appoint the Data Protection Officer (DPO).