Privacy Policy

Pursuant to Article 13 of Legislative Decree No. 196/2003, we hereby inform you that the personal and tax data acquired, even verbally, with reference to the business relations established, provided directly by the interested parties, or otherwise acquired as part of the company's activity, will be processed in compliance with the above-mentioned regulations, including the confidentiality obligations provided for therein.

1. Purpose of processing

The data provided are processed for the following purposes:

Customer information / GDPR.

Information pursuant to Article 13 of Regulation (EU) 2016/679 on the protection of personal data (GDPR) and request for consent for the processing of personal data.

Data controller.

ATL S.R.L., with registered office in Bergamo, Viale Papa Giovanni XXIII° 45, tax code no. 04348320161, in its capacity as ‘Data Controller’ of the personal data communicated by the Data Subject (‘Personal Data’) provides this information notice pursuant to Article 13 GDPR (‘Information Notice’).

Purpose of processing and legal basis.

The collection and processing of Personal Data is carried out:

even without the consent of the data subject (Article 6(b), (c) and (f), GDPR), for the following purposes:
the execution of the Contract and the provision of related services requested by the Data Subject;
the fulfilment of any legal and/or regulatory obligations (e.g. invoicing, bookkeeping);
the protection of ATL S.R.L.'s rights, both in and out of court;
with the consent of the data subject (Article 7, GDPR) - which may subsequently be revoked at any time - for the following purposes:
direct and indirect marketing and market research: by sending (by e-mail, traditional paper mail, telephone, fax and/or SMS/MMS, push notifications) newsletters, commercial communications relating to ATL S.R.L.'s products, organised events and open houses, invitations to trade fairs of interest to the interested party, as well as by carrying out (by telephone, online, or e-mail) statistical analyses, surveys and market research, including customer satisfaction activities. In the event of consent to profiling, as indicated in letter e) below, ATL S.R.L. may use the information collected to send commercial communications deemed to be of potential interest to the interested party;
profiling: collection of information on behaviour and business habits in the sector in which the Company operates in order to improve the services offered on the basis of customers' needs and, specifically, for the analysis by the Company of information concerning the choices, preferences, interests and habits of the Data Subject acquired in the context of the use of the Services.

Nature of the provision of Personal Data and consequences of a refusal to provide it.

The provision of Personal Data for the purposes referred to in letters a) of article 2 above is therefore mandatory. The non-availability of the data and/or the eventual express refusal to process them will make it impossible for ATL S.R.L. to execute the contract signed or the possible violation of requests from the competent Authorities.

The provision of data for the purposes referred to in article 2 letter B) above is optional, with the consequence that the interested party may decide not to provide his/her express consent, or to revoke it at any time. Should the data subject fail to give his/her specific consent to the processing, it will not be possible for ATL S.R.L. to carry out the activities referred to therein.

Personal data processed.

Within the scope of the purposes of the processing operations outlined in Article 2 above, only Personal Data relating to:

identification and contact data acquired during the conclusion of the Contract or voluntarily communicated by the Data Subject in any form, including:
personal data essential for identification (e.g. name and surname, tax code, addresses, email, PEC, employer company, role and/or company classification, etc.).

Data Update.

At any time, the Data Subject may ensure that the Personal Data processed for the purposes set out in this information notice are correct and, in the event of any variation thereof, he/she may also request that such data be updated by sending an e-mail to info@atlantis-land.com, or by post to the Company's head office.

Mode of treatment.

The processing of Personal Data is carried out by means of the operations indicated in Article 4(2), GDPR, namely: collection, recording, organisation, structuring, updating, storage, adaptation or modification, extraction and analysis, consultation, use, communication by transmission, comparison, interconnection, restriction, deletion or destruction.

ATL S.R.L. guarantees the security of the data and, in general, the confidentiality of the Personal Data processed, putting in place all the necessary technical and organisational measures adequate to prevent the loss of Personal Data, unlawful or otherwise incorrect use thereof, as well as unauthorised access by third parties.

The processing by ATL S.R.L. of Personal Data shall be based on the principles of correctness, lawfulness, transparency and protection of the confidentiality of the data subject and of his/her rights, in accordance with the principles expressed by the GDPR and the Privacy Code.

The processing of Personal Data by ATL S.R.L. may be carried out by means of paper, computer and telematic tools and shall include - in compliance with the limits and conditions laid down by privacy regulations - all the operations or series of operations necessary for the processing in question. The processing of Personal Data shall be carried out in compliance with the rules of confidentiality and security provided for by European legislation, the law, consequent regulations and internal provisions.

Communication of data.

ATL S.R.L., for the purposes set out in Article 2 above, may make the Personal Data of the Data Subject available:

to its employees and collaborators, acting in their capacity as authorised data processors (or so-called 'processors') and/or to agents/consultants engaged by the Controller who need to process Personal Data in order to perform their duties;
third parties who carry out activities in outsourcing on behalf of the Data Controller, providing specific services in their capacity as Data Processors pursuant to Art. 28 of the GDPR. For information on the names and references of the Data Processors, the Data Subject may contact ATL S.R.L. at the e-mail address info@atlantis-land.com or by telephone on 02-86897001;
to judicial or supervisory authorities, administrations, public bodies and organisations (domestic and foreign), in accordance with the provisions of the law and following a formal legitimate request by such parties.

Personal Data shall not be disclosed or transferred to third parties. It is understood that, in the event of any extraordinary corporate transactions (e.g. sale or lease of a company, merger, etc.) involving the Data Controller, Personal Data may be transferred or assigned to third party purchasers/tenants or assignees by the Data Controller in accordance with the relevant regulations.

Transfer of data abroad.

Personal Data are currently stored on servers located at the Company's premises.

The data controller does not transfer personal data to third countries or international organisations.

However, it reserves the right to use cloud services; in which case, the service providers will be selected from among those who provide adequate guarantees, as provided for in Article 46 GDPR 679/16.

Data retention periods.

Personal Data will be kept for the period of time strictly necessary for the purposes of the processing indicated in Article 2 above and, specifically:

for the purposes set out in Article 2, I: the time necessary for the performance of contractual obligations and, in any case, no longer than 10 years from the time of collection of the Personal Data for the fulfilment of regulatory obligations and, in any case, no longer than the time limits set by law for the prescription of rights;
for the purposes indicated in Article 2(II)(d) (i.e. for the purposes of direct and indirect marketing and market research): 24 (twenty-four) months from the time consent to the processing is given or until such time as consent is withdrawn or cancellation is requested;
for the purposes indicated in Article 2(II)(e) (i.e. for profiling purposes): will be retained for the maximum time identified by the Data Protection Authority for profiling and personalised marketing equal to 12 (twelve) months from the time consent to the processing was given or until the consent is revoked or a request for cancellation is made.

Rights of the data subject.

With regard to Personal Data, the Data Subject may exercise, at any time, the rights recognised by the GDPR, set out below:

access to personal data pursuant to Art. 15: obtain confirmation as to whether or not personal data concerning him/her are being processed and, if so, access to the following information: the purposes, the categories of data, the recipients, the storage period, the right to lodge a complaint with the Supervisory Authority, the right to request rectification or erasure or restriction of processing or to object to processing, and the existence of an automated decision-making process;
request for rectification of personal data pursuant to Art. 16: to obtain, without undue delay, the rectification of inaccurate Personal Data concerning him/her and the possible supplementation thereof if incomplete;
deletion of personal data pursuant to Art. 17: obtain, without undue delay, the deletion of Personal Data concerning him/her;
limitation of processing pursuant to Article 18: "limitation" means the marking of the data stored with the aim of limiting its processing in the future, which will entail ATL S.R.L.'s obligation to suspend the processing of Personal Data;
portability of data ex art. 20: in the case of automated processing carried out on the basis of consent or in performance of a contract, to receive in a structured, commonly used and machine-readable format the data concerning him/her;
objection to processing 21: to object to the processing of Personal Data, unless there is a legitimate interest of the Controller to continue the processing. The Data Subject also has the right to object to processing where their Personal Information is used for direct marketing purposes;
oppose automated decision-making, including profiling pursuant to Art. 22, Personal Data shall not be subject to any automated decision-making process by ATL S.R.L. through the use of personal information or profiling of the Customer, unless the Data Subject consents thereto;
Revocation of consent: where the Data Subject has provided consent to the collection, processing and transfer of his or her Personal Data, he or she has the right to revoke this consent for that specific processing at any time. Once notification of withdrawal of consent has been received, ATL S.R.L. shall no longer process the Personal Data;
lodge a complaint pursuant to Article 77 with the competent Supervisory Authority based on habitual residence, place of work or place of infringement of the data subject's rights; for Italy, the competent authority is the Garante per la protezione dei dati personali, which can be contacted using the contact details given on the website http://www.garanteprivacy.it/.

The aforementioned rights may be exercised by sending a specific request to ATL S.R.L. by e-mail, to info@atlantis-land.com, or by post to the Bergamo offices, Viale Papa Giovanni XXIII° 45.

Requests relating to the exercise of the rights of the Data Subject shall be processed without undue delay and, in any event, within 30 days of receipt of the request.

ATL S.R.L. may amend or update this information notice, including in order to comply with new obligations imposed by the laws in force or for technical requirements.

(a) for requirements preliminary to the conclusion of contracts of sale, for the execution thereof and for the protection of claims arising therefrom;

(b) to fulfil any kind of obligation under applicable laws or regulations, in particular, in tax matters;

d) for the registration of access to the Company's website and the use of the services provided with that site;

(e) for the purpose of monitoring the development of customer relationships and/or the associated risks and improving those relationships;

(f) for commercial purposes and strategic and operational marketing;

(g) for statistical purposes.

2. Treatment modalities

The processing of the data may consist, in addition to their collection, in their registration, storage, modification, communication, deletion and will be carried out both on paper and with the aid of electronic computer and telematic tools, according to methods and with tools suitable to guarantee the security and confidentiality of the data themselves, in compliance with the provisions of Articles 31 et seq. of Legislative Decree 196/2003, concerning the "minimum security measures for the processing of personal data".

In particular, all technical, IT, organisational, logistical and procedural security measures will be adopted, as provided for by Legislative Decree 196/2003 and 'Annex B' to the same decree, so that the minimum level of data protection required by law is guaranteed. Furthermore, the methodologies applied guarantee that access to the data is permitted only to persons entrusted with the processing by our Company.

We also point out that your data may also be viewed by the companies that oversee our management system and our website, and that our structure has appointed external data processors limited to technical access for maintenance purposes.

3. Provision of data

The provision of data is

(a) Mandatory for the fulfilment of purposes related to obligations under laws or other binding regulations;

b) Necessary for the correct establishment and continuation of the relationship with you. Any refusal to provide the above data, although certainly legitimate, could compromise the proper conduct of the relationship with our Company and, in particular, could make it impossible for us to execute your/your orders, as well as to carry out the provision of the services requested and the related invoicing.

4. Communication of data

The personal data collected for the achievement of the above-mentioned purposes may be communicated, to the extent of their specific competence, to public and private entities, natural and/or legal persons and having commercial purposes and/or management of information and/or payment systems, including external entities performing specific tasks on behalf of our Company.

In particular, the data may be communicated to the following categories of persons:

(a) commercial network employees,

(b) banking institutions and companies specialising in payment processing,

(d) persons entrusted with the auditing of our company's financial statements

(e) public authorities or administrations for legal compliance

(f) Italian and foreign distributors and suppliers

(g) financing and transport companies

(h) persons entrusted with the sending of information material concerning products distributed or own services

The data may also be disseminated, but only in aggregate, anonymous form and for statistical purposes.

To the extent strictly necessary for the performance of the ongoing contractual relationship with you, your personal data may be disclosed to third parties (such as suppliers) located abroad, within or outside the European Union.

5. Data controller

The data controller on behalf of Atlantis is the company ATL S.R.L. with registered office in Bergamo, Via Papa Giovanni XXIII° 45.

6. Data controller

The person in charge of the processing of your data, domiciled for this purpose at the Company's head office, is the Head of Internal Information Systems. Interested parties who wish to assert their rights listed in this information notice are invited to write to info@atlantis-land.com. The data subject may request the updated list of internal and external Data Processors, included in the privacy organisation chart, at the following e-mail address info@atlantis-land.com .

7. Rights of the data subject

You may at any time exercise your rights vis-à-vis the data controller, pursuant to Article 7 of Legislative Decree No. 196/2003, which we reproduce in full for your convenience.

Article 7 - Right of access to personal data and other rights

1. The data subject shall have the right to obtain confirmation as to whether or not personal data concerning him/her exist, even if not yet recorded, and communication of such data in intelligible form.

2. The person concerned has the right to be informed:

(a) the origin of the personal data;

(b) the purposes and methods of processing;

(d) the identification details of the holder, the persons responsible and the representative designated pursuant to Article 5(2);

e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, as managers or appointees.

3. The data subject has the right to obtain:

(a) the updating, rectification or, where interested therein, the integration of data;

b) the deletion, transformation into anonymous form or blocking of data processed in breach of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;

c) certification that the operations referred to in points a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, unless this proves impossible or involves a manifestly disproportionate effort compared to the right protected.

4. The data subject has the right to object, in whole or in part:

a) for legitimate reasons to process personal data concerning him/her, even if pertinent to the purpose of collection;

b) the processing of personal data concerning him/her for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.

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