Our Privacy Policy

Marco Ortelli S.r.l., with its registered office at Via Nazario Sauro 9 – 20813 Bovisio Masciago (MB), Tax Code 09315200965
and VAT No. 09315200965 (hereinafter, the “Data Controller”), in its capacity as data controller, hereby informs you pursuant to Article
13 of Legislative Decree No. 196 of 30 June 2003 (hereinafter, the “Privacy Code”) and Article 13 of EU Regulation No. 2016/679 (hereinafter,
the “GDPR”) that your data will be processed in the manner and for the purposes described below:

1. Subject of the Processing
Marco Ortelli s.r.l. processes personal data, including identifying information (e.g. first name, surname, company name,
address, telephone number, email address, bank and payment details) – hereinafter “personal data” or simply “data”)
provided by you when entering into contracts for the services of Marco Ortelli S.r.l.

2. Purposes of processing
Your personal data is processed:
A) even without your express consent (Art. 24(a), (b), (c) of the Privacy Code and Art. 6(b), (e) of the GDPR) and in
accordance with the General Authorisations issued by the National Data Protection Authority, for the following Service Purposes:
– to conclude contracts for the services purchased;
– to fulfil pre-contractual, contractual and tax obligations arising from existing relationships with you;
– to fulfil obligations laid down by law, by a regulation, by EU legislation or by an order
from the Authority (such as in relation to anti-money laundering);

B) Only with your specific and separate consent (Articles 23 and 130 of the Privacy Code and Article 7 of the GDPR), for the following
marketing purposes:
– to send you, via email, post and/or telephone, newsletters, commercial communications and/or
advertising material regarding products or services offered by Marco Ortelli S.r.l., and to assess your level of
satisfaction with the quality of our services;
– to send you, via email, post and/or telephone, commercial and/or promotional communications from third parties
(e.g. business partners).

3. Methods of processing
The processing of your personal data is carried out by means of the operations indicated in Article 4 of the Privacy Code
and Article 4(2) of the GDPR, namely: collection, recording, organisation, storage, consultation,
processing, modification, selection, extraction, comparison, use, interconnection, blocking,
communication, erasure and destruction of data. Your personal data is processed both
on paper and electronically and/or automatically.
Marco Ortelli S.r.l. will process personal data for the time necessary to fulfil the purposes set out above
and, in any event, for no longer than 10 years from the termination of the relationship for Service Purposes and for no longer than 2
years from the collection of the data for Marketing Purposes.

4. Access to data
Your data may be made available for the purposes set out in Articles 2.A) and 2.B):
– to employees and contractors of Marco Ortelli S.r.l. in Italy and abroad, in their capacity as data processors and/or
internal data controllers and/or system administrators;
– to third-party companies or other entities (for example, credit institutions, professional firms, consultants,
insurance companies for the provision of insurance services, etc.) that carry out outsourced activities on behalf
of Marco Ortelli S.r.l., in their capacity as external data processors.

5. Disclosure of data
Without the need for express consent (pursuant to Article 24(a), (b) and (d) of the Privacy Code and Article 6(b) and (c) of the GDPR),
Marco Ortelli S.r.l. may disclose your data for the purposes set out in Article 2.A) to supervisory bodies,
judicial authorities, insurance companies for the provision of insurance services, as well as to those entities
to whom disclosure is required by law for the fulfilment of the aforementioned purposes.
These entities will process the data in their capacity as independent data controllers.
Your data will never be disclosed outside the scope of legal obligations without your express consent.

6. Data transfer
Personal data is stored on servers located within the European Union. It is understood, however,
that Marco Ortelli S.r.l. reserves the right, should it become necessary, to move the servers outside the EU. In such
a case, Marco Ortelli S.r.l. hereby guarantees that the transfer of data outside the EU will take place in accordance with
the applicable legal provisions, subject to the conclusion of the standard contractual clauses provided for by the
European Commission.

7. Nature of data provision and consequences of refusal to provide data
The provision of data for the purposes referred to in Article 2.A) is mandatory. Without such data, we will not be able to provide you with
the Services referred to in Article 2.A).
The provision of data for the purposes referred to in Article 2.B) is, however, optional. You may therefore decide not to
provide any data or subsequently withdraw consent to the processing of data already provided: in such a case, you
will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by
Marco Ortelli S.r.l.
You will, however, continue to be entitled to the Services referred to in Article 2.A).

8. Rights of the data subject
As a data subject, you have the rights set out in Article 7 of the Privacy Code and Article 15 of the GDPR, namely the rights
to:
i. obtain confirmation as to whether or not personal data concerning you exist, even if not yet
recorded, and their communication in an intelligible form;
ii. obtain information regarding:
a) the source of the personal data;
b) the purposes and methods of processing;
c) the logic applied where processing is carried out with the aid of electronic means;
d) the identification details of the data controller, data processors and the representative, if appointed, in accordance with
Article 5(2) of the Privacy Code and Article 3(1) of the GDPR;
e) the subjects or categories of subjects to whom the personal data may be disclosed or who
may become aware of it in their capacity as designated representative within the territory of the State, data processors
or persons in charge of processing;
iii. to obtain:
a) the updating, rectification or, where interested, integration of the data;
b) the erasure, anonymisation or blocking of data processed in breach of
the law, including data which need not be retained for the purposes for which the data
were collected or subsequently processed;
c) confirmation that the operations referred to in points (a) and (b) have been brought to the attention, including
as regards their content, of those to whom the data have been disclosed or disseminated,
except where this proves impossible or involves a use of means
manifestly disproportionate to the right being protected;
iv. object, in whole or in part:
a) on legitimate grounds, to the processing of personal data concerning you, even if relevant to
the purpose of collection;

b) to the processing of your personal data for the purposes of sending advertising material or
direct sales material, or for carrying out market research or commercial communications,
through the use of automated calling systems without the intervention of an operator, via email
and/or through traditional marketing methods, by telephone and/or post.
Please note that the data subject’s right to object, as set out in point b) above, for the purposes of
direct marketing via automated means extends to traditional methods and that, in any case, the
data subject retains the right to exercise the right to object even only in part. Therefore,
the data subject may choose to receive only communications via traditional methods or only
automated communications, or neither type of communication.
Where applicable, they also have the rights referred to in Articles 16–21 of the GDPR (right to rectification, right to be forgotten, right to
restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint
with the Data Protection Authority.

9. How to exercise your rights
You may exercise your rights at any time by sending:
– a registered letter with acknowledgement of receipt to Marco Ortelli s.r.l. – Operational headquarters at Via Nazario Sauro 9, 20813
Bovisio Masciago (MB)
– an email to privacy@marcoortelli.it

10. Data controller, data processors and persons authorised to process data
The data controller is Marco Ortelli S.r.l. – Via Nazario Sauro 9, 20813 Bovisio Masciago (MB).
The up-to-date list of data processors and persons authorised to process data is kept at the registered office of the
data controller.